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["About this workbook"]
["This workbook contains all of the responses received to the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (Regulation 18: Spatial Options and Key Policy Areas). For more details of the consultation itself please visit strategiclocalplan.org. \n\nPlease use all of the tabs across the bottom of the workbook to see all of the responses made. Use Ctrl+F to search, and choose 'Within Workbook' if you want to search across all sheets/tabs.\n\nThis workbook does not offer any interpretation or provide responses to any comments made. Comments are included verbatim and are the views of the individual contributors."]
["Sheet Tabs ","Details "]
["Questionnaire Responses","This sheet is a complete list of responses to the questionnaire responses received via the consultation platform and email. Note - this tab does not include site submission made with a HELAA submission form."]
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["In Person Events","This sheet contains the comments left on post-it-notes at in person public events"]
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["Young People ","This sheet contains comments left in the 'Hearing from young people' folder 'Questions for Young People' project on the consultation portal. "]
["Housing 13-25 year olds","This sheet contains comments left in the 'Hearing from young people' folder 'Housing Questions for 13-25 year olds' project on the consultation portal. "]
["Draft Vision","This sheet contains comments left in the Draft Vision project on the consultation portal. Please also see 'Questionnaire Responses' Q4 - Q4a."]
["Strategic Objectives","This sheet contains comments left in the Strategic Objectives project on the consultation portal. Please also see 'Questionnaire Responses' Q5 and Q5a."]
["Climate & Nature","This sheet contains all comments left on the consultation portal in the 'What should the SLP do for Climate & Nature?' project portal."]
["Location for Climate & Nature","This sheet contains all comments left on the consultation portal in the 'Tell us about locations for climate and nature recovery' project portal. Including sites suggested by the community and comments left against those locations. Please also see 'Questionnaire Responses' Q9."]
["Jobs & Retail","This sheet contains all comments left on the consultation portal in the 'Planning for community and business' folder under 'Jobs and Economy' project. Please also see 'Questionnaire Responses' Q18 to Q22."]
["Infrastructure","This sheet contains all comments left on the consultation portal in the 'Planning for community and business' folder under 'Infrastructure' project. Please also see 'Questionnaire Responses' Q23 to Q26 and 'Youth Engagement'."]
["Type & Tenure ","This sheet contains all comments left on the consultation portal in the 'Planning for community and business' folder under 'Type, size or tenure of new homes' project. Please also see 'Questionnaire Responses' Q14 and 'Youth Engagement'."]
["G&T","This sheet contains all comments left on the consultation portal in the 'Planning for community and business' folder under 'Traveller communities' project. Please also see 'Questionnaire Responses' Q15 to Q17."]
["New Homes","This sheet contains all comments left on the consultation portal in the 'Planning for community and business' folder under 'How many new homes' project. Please also see 'Questionnaire Responses' Q12 to Q13."]
["Scenarios","This sheet contains all comments left on the consultation portal in the 'Scenarios' project portal. "]
["Pros & Cons","This sheet contains all comments left on the consultation portal in the 'Scenarios' project portal under the six individual options. "]
["Additional Scenario","This sheet contains all comments left on the consultation portal in the 'Additional Development Scenarios' project portal. "]
["Rural Settlement Hierarchy","This sheet contains all comments left on the consultation portal in the 'Rural Settlement Hierarchy' project portal. "]
["Additional Comments","This sheet contains all comments left on the consultation portal in the 'Additional Comments' project portal. "]
["GWT","Comments received via email from Gloucestershire Wildlife Trust campaign "]
["Notes:"]
["Remember to Ctrl+F to search, and choose 'Within Workbook' if you want to search across all sheets/tabs"]

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["Your role ","Organisation","Q.1 How far into the future should the Strategic and Local Plan cover?","Q.2 Are there any strategic policy topics, not identified in paragraph 2.4 of the consultation document, which should also be considered? ","Q.3 What local policy topics are unique to only a council area, neighbourhood or community? ","Q.4 Do you agree with the draft Vision?","Q.4a If you answered no to the previous question, what changes would you like to see? (for processing purposes neutral or positive comments were also added to this coloumn)","Q.5 Do you agree with the draft Strategic Objectives? ","Q.5a If answered no, what changes would you like to see? (for processing purposes neutral or positive comments were also added to this coloumn)","Q.6 In what ways do you consider the Strategic and Local Plan can most effectively address the impacts of climate change? ","Q.7a What measures and standards should the Strategic and Local Plan introduce in respect of the construction and operation of new buildings?","Q.7b What measures and standards should the Strategic and Local Plan introduce in respect of the retention and reuse of existing buildings? ","Q.8 Should the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? ","Q.9 Are you aware of any land that could be identified for environmental purposes, such as wildlife / biodiversity net gain, recreation, flood risk mitigation, cooling and shading, carbon storage and food production?","If answered yes, please specify.","Q.10 Which key services and facilities do you think are most important to be provided within easy reach of developments? ","Q.11 Should we allocate sites in the SLP specifically for renewable energy generation or storage? ","Q.11a If answered yes, what forms of renewable energy would be appropriate and in which locations? ","Q.12 Should the Strategic and Local Plan use the local annual housing need calculation from the Standard Method? ","Q.12a If answered no, please set out what you consider the councils should use instead. (Note - for processing purposes neutral or positive comments were also added to this coloumn)","Q.13 Are there any constraints or other reasons why the number of houses to be actually planned for in the Strategic and Local Plan should differ from calculated needs? ","If answered yes, please explain further.","Q.14 Are there any specific types, sizes or tenures of housing that the SLP should require for particular groups in the community? ","Q.14a If answered yes, please explain further.","Q.15 Should sites for traveller communities be provided as part of large developments for housing and/or employment?","Q.16 Are there any other ways that sites for traveller communities could be met in our area?","Q.17 What site characteristics and locations would be most suitable for different traveller communities? ","Q.18 What economic and regeneration needs should the Strategic and Local Plan address in supporting businesses to invest, expand and adapt? ","Q.19 How should the Strategic and Local Plan best seek to accommodate employment needs and provide an environment that is attractive to inward investment? ","Q.20 How should the Strategic and Local Plan support and encourage rural employment? ","Q.21 How could the Strategic and Local Plan best enable change and encourage investment to support our city and town centres to adapt, evolve and thrive? ","Q.22 How can the Strategic and Local Plan protect and encourage essential shops, services and facilities in villages and rural areas?","Q.23 What types of infrastructure do you consider are most critical to be delivered alongside new development? ","Q.24 Given their size, if strategic scale new settlements were to form a part of the Strategic and Local Plan, what accompanying infrastructure would be necessary? ","Q.25 What key services and facilities do you consider most important in deciding if a rural settlement is a suitable location for new homes and other forms of development? ","Q.26 Should the Strategic and Local Plan safeguard sites or routes for longer term infrastructure projects? ","Q.27 Are there any additional development scenarios that should be considered? ","Q.27a If answered yes, please describe what they are. ","Q.28 Are the pros and cons identified for the six development scenarios a fair and accurate assessment? ","Q.28a If answered no, which one(s) and what are your reasons? ","Q.29 Which of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? ","Q.30 Are there any places not currently identified in the rural settlement hierarchy, which could/should be included? ","Q.30a If answered yes, please specify.3","Q.31 Is there anything else you would like to raise – has anything been missed, or are there any general comments you would like to make? "]
["Resident","",30,"no","","","","Yes","","ensure homes are built to the best sustainability standards","passive house standards of construction","","No","No","","jobs and schools","Yes","solar, close to settlements they serve","Yes","","No","","No","","Yes","","","","allocate land for employment use","allocate sites for employment use within or adjacent to existing settlements","protect retail and other uses in key areas and encourage additional housing on upper floors, densification, public transport investment, really good cycle links","allow limited housing in villages ","walking and cycling, green space, schools, public transport","schools, employment uses, public transport, shops, doctors,","schools, employment opportunties.","Yes","Yes","larger expansion of existing towns (not just urban extensions)","No","cons for urban extensions, does not assume a comprehensively planning development. urban extensions could provide for jobs, services etc. don't agree journey lengths would be increased as a well deigned scheme would enable internalization","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 6: Sustainable transport scenario","No","",""]
["Planning agent or developer","OBK Land & Planning",10,"","","Yes","","Yes","","","","","","","","","","","Yes","","","","","","","","","","","","","","","","","","","","","","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 5: Rural dispersal;","No","",""]
[null,null,"","","","Yes","","Yes","","Development in areas not liable to flooding","","","No","No","","","","","","","","","","","Yes","Empty use of land where there's access to recycling/waste facilities","Lots of land not near a built up area","","","","","","","","","","","","Yes","","Scenario 6: Sustainable transport scenario;","No","","More affordable housing"]
["Other","The conservation of swifts and cavity nesting bird species","","","Many local authority housing stock have building dependent nesting birds eg the red listed house sparrow and nest faithful swift.  These neting sites are being lost during renovations and need both protection and mitigation during any building works","","","","","","Ensure all new development (houses, public buildings, industrial buildings, home extensions etc.) provide nesting cavities for building dependent species. Universal bricks, based on the design of a swift brick, are used by 4 red listed species (swift, house sparrow, starling and house martin), as well as much-loved blue tits and great tits and overwintering birds and insects. They are an invaluable boost to biodiversity in a built environment.\nBS 42021: 2022 provides full detail and should be referenced in the Local Plan (https://knowledge.bsigroup.com/products/integral-nest-boxes-selection-and-installation-for-new-developments-specification-1?version=standard). BS42021 has been endorsed by the NHBC in NF89 Biodiversity in new housing developments https://www.nhbc.co.uk/binaries/content/assets/nhbc/foundation/biodiversity-in-new-housing-developments.pdf page 42. “Fitting at a ratio of 1 nest brick per house across the development will ensure sufficient nest sites for colonial species. 3-5 can be located in one house, so helping locate them in suitable locations for access to foraging habitat. The British Standard BS42021 sets out details on nest box installation for the above species into domestic and commercial properties.”","","Yes","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","",""]
["I work for a charity or volunteer in the area","",20,"Farm land","Flooding, heritage environment, SSSI","Yes","","Yes","","While not discouraging development, the local plan should set a high bar for water management on sites that might be developed for housing; not just on allocated sites, but on sites that come forward during the plan period.  This should include finance to ensure that organisations appointed to manage SUDs cannot fail, measures to effect a reduction in the threat of flooding in vulnerable downstream neighbourhoods, improvements to infrastructure so that sewers cannot become overwhelmed and roads so choked with traffic that cars stand idling, and proper provision for sustainable modes of transport.\nThere should be an encouragement for owners of listed buildings to embrace low carbon sources of energy, with perhaps a scheme similar to the HAZ, to enable the installation of heat pumps, double-or-secondary glazing, photovoltaic roof slates and solar panels.\nThe design of roads and parking strategies should aim to create a more cycle-friendly environment and also a more pedestrian-friendly environment.\nThere should be a requirement for new and converted homes to have access to an EV charging point.  There should be a requirement for new industrial and commercial properties to contain a proportion of EV charging points.\nCommunity spaces could include drop-off hubs for the delivery of internet and mail-order purchases, from which people can choose to collect goods.\nThere should be greater access to E-bikes throughout our communities.\nThe cycling network between communities needs to be strengthened and made safer.","Encourage developers to aim for zero carbon, in both the development stage and in the running of new buildings.\nEncourage the use of reclaimed materials where practicable.\nEncourage groups of self-builders to work together to source supplies of materials and renewable energy.","Redevelopment of brownfield sites must be encouraged above the use of, say, greenbelt land.  Perhaps such sites could be used for modern farming methods, such as hydroponics.  Perhaps the development of key brownfield sites could be linked to the development of greenfield sites, so that the relative expense of developing the former can be partially offset by the opportunity to develop the latter.  Planning authorities could carry out a ‘de-risking’ strategy for stubbornly undeveloped brownfield sites (as with Healings Mill).","Yes","","","Medical and dental services, schools, general stores, banking facilities, sporting facilities, community halls, play spaces, high speed broadband, places of worship, places for burials and interment of ashes etc","Yes","Ground source heat pumps at central locations in new housing developments and also in rural areas.  Solar panels, pv slates and air source heat pumps in already developed areas. Hydro-electric turbines watercourses.","No","The number derived from the local annual housing need calculation needs to be reduced, to take account of the following factors:\n•\tThe proportion of the total plan area that cannot be developed because it is in a flood plain\n•\tThe proportion of the total plan area where development is restricted because it is in an AONB\n•\tThe proportion of the total plan area that has special characteristics, eg a particular historical environment, that would be harmed by the close proximity of modern development.\n•\tThe proportion of the total plan area that is protected by SSSI or listed Ancient Monument status\n•\tThe proportion of the total plan area that needs to be allocated to major infrastructure, eg roads","Yes","Due to the densely developed nature of Cheltenham and Gloucester, there is a pressure to bring forward sites in areas that are also very much subject to the pressures described in 12a.","Yes","Given the relatively elderly demographic of the northern part of the plan area , there needs to be housing that is suitable for retired people, and is also designed to be easily adaptable for their changing needs, so that they can live independently for longer.  There needs to be accommodation for growing families, that again can adapt to their needs as they grow older.  There needs to be suitable and affordable accommodation for young people, close to the facilities that enable them to socialise and lead healthy lives, without having to leave the area.","Yes","","","Where possible, economic development should be focused on existing centres in order to help them to remain, or become more, vibrant.  Empty sites in town and city centres need to be given new economic uses.  Local planning authorities should encourage ‘in-the-meantime’ uses for some town centre sites, perhaps for the erection of temporary start-up business premises and/or entertainment/leisure venues, so that there is still footfall in those areas, until more permanent premises can be found.","The Strategic and Local Plan could identify the types of businesses that work well in close proximity to each other and encourage them to locate in premises near to each other.  A fast broadband connection throughout all urban and rural areas is vital to ensure good connectivity and thus allow businesses to flourish.  Some businesses don’t need huge physical movements of goods, and these should be encouraged in areas where the road network is less robust, and areas which can be cut off due to floods.","There are modern types of farming and market gardening methods that don’t require huge tracts of land and these may be more manageable for young people who haven’t actually inherited a farm.  Strong internet connections will enable businesses that don’t rely on extensive sewerage networks to flourish in rural areas. Access to renewable energy will also be beneficial. ","The Strategic and Local Plan could incentivise modifications to existing buildings in order to make them more accessible and also more energy efficient.  It can also incentivise the repurposing of existing structures and sites for new businesses and accommodation.","It can help to encourage banks/post offices to maintain a presence.  It can encourage the provision of sustainable transport options and provide well-lit, well-overlooked, safe pedestrian routes, that will make it more possible for residents to use those facilities without having to get into a car.","A sewerage system that is fit for the 21st Century, strongly managed SUDs, roads, strong internet and mobile phone connectivity, schools, health facilities.","Good links to existing settlements, additional infrastructure provision, so as not to disadvantage users of existing provisions.","Would it be possible to live a fulfilling life here and not have ready access to a car?  There needs to be a community hub, shop, local jobs, open space, play areas, safe and sustainable access to other communities and a fast broadband connection.","Yes","","","Yes","","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","Accommodation needs to be made in the plan for residents who will pass away.  As our population increases, so will our need for cemeteries and memorial spaces.  There needs to be a range of different options, from the reuse of existing plots of a certain age, to the establishment of woodland cemeteries.  We must be mindful that, within the Severn Valley, opportunities to accommodate such sites within easy access of communities is limited by the height of the water table and we should take care not to allow housing for the living to take all the high ground.  \nWe could learn from Dutch experiments with amphibious homes and offices – ones that can rise above the water in times of flood and those that don’t rise but can cope in flood conditions.  The Dutch are even now creating such homes in heavily developed areas and areas with a high quality historical environment.\n"]
["Resident",null,15,"the need for cars","","No","where is the explicit removal of the need for cars and associated pollution. ","Yes","","increase urban density to ensure that most people are able to meet needs with out cars.","consider alternative building techniques, passiv Haus etc.","","Yes","Yes","chosen hill border by a417, railway line, m5.","safe cycle routes","Yes","mandatory solar on developments such as warehousing","Yes","","Yes","what kind of house? 4bed executive, v 2 bed terrace, very different areas, markets etc.","Yes","why feed Londoners looking for country retreats or airBNB, or buy to let?","","","","lobby government to partially reverse Brexit and rejoin SM to improve opportunities.","","stop building for Londoners and look at what the local population needs","lost cause, unless you ban out of town and cars.","ensure housing is for people working locally and not commuters.","dedicated cycle paths, public transport.","everything, jobs, health, issue will be more need for cars as a result.","public transport.","Yes","","","Yes","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","No","",""]
["Resident",null,20,"","","","","","","","","","","","","","","","","","","","","","Yes","Of the 3 council areas, Cheltenham appears to not have a requirement for fixed traveller sites or transit sites. Both Gloucester and Tewkesbury are disproportionately affected compared with Cheltenham. As the three areas work together, could work not be done to seek traveller sites and do call for sites within Cheltenham? Granted, it is smaller than the other two but there may still be suitable development sites for travellers there.\n\nRegarding call for sites in general, this is passive. There is no sense that the councils actively seek traveller accommodation. There is a recent case in Tewkesbury where Green Belt land has recently been occupied and developed without authorisation by travellers and they may well be permitted a temporary or permanent permission based on a lack of sites within the borough. The land is not suitable for a traveller site for a variety of reasons. It is frustrating for residents to drive past other sites that certainly seem suitable and unused within the borough and residents feel that the councils could be much more active in seeking new sites out. In addition, residents see settled developments being permitted without regard for the need for traveller sites. Settled developments are much more attractive for developers and councils, predominantly for financial reasons I assume. This is all well and good but the strategic plan and day to day activities in the boroughs need to actually come to terms with the fact that traveller sites need to be taken into account with much more importance than they currently are. The specific example I have mentioned is eroding and harming Green Belt land within Tewkesbury borough. Settled communities seem to be consistently prioritised over traveller for development and there needs to be a change. Otherwise there will be a persistent issue with unauthorised development on Green Belt and other unsuitable land.","","","","","","","","","","","","","","","","","",""]
["Statutory/Specific Consultee","Badgeworth Parish Council","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","",""]
["Local Councillor","Bredon Parish Council",30,"","","","","","","Urban concentration leading to step-change increase in use of public transport. Sprawling the development across green field sites will be an environmental and ecological disaster for the area and the UK","Solar, ground source and other renewable sources should be mandatory","All town/city centre buildings should be repurposed for residential living leaving just ground level retail outlets. Build upwards and embrace urban living.","Yes","","","Leisure, public transport, hospital, schools. All within the existing urban boundaries.","Yes","Solar battery storage, ground source heat (go deep!)","No","Needs change over time. I suspect housing need will go down over a 30 year period. Take time to plan efficient urban concentration and then execute on that plan. Bring people back to the currently dead urban centres.","Yes","The area is geographically constrained. Forget building further urban sprawl on an area that is highly sensitive to flooding. Instead concentrate on increasing residential density in existing urban areas that are not flood prone (Cheltenham, Gloucester). Young people in particular love living in a busy vibrant urban environment. ","","","No","We should stop formalising one set of rules for them and another for everyone else.","I'm sorry but they have brought crime and misery to our local area. They should not be pandered to at all.","I support the Cyber campus to the west of Cheltenham centred on GCHQ. It makes sense to build on the amazing centre of excellence that already exists, plus the committed improvements to J10 and the A4019 (plus link road to the A40).","Keep commuting times (and therefore new traffic issues) to an absolute minimum. The traffic in this area is a disaster and no plans exist to improve this other than around the A4019.","By protecting the rural environment. Leave the green fields alone.","By concentrating planning and investment on the centres. Shopping is dead. Leave it to the retail parks. Ban or reduce car journeys, invest in mass transport, massively increase leisure opportunities. Ignore old people's objections (and I'm one of them!)","Stop subsuming the villages and rural areas into urban sprawl.","Mass transit. Local education and healthcare options.","No new settlements, you'll just generate traffic between them and the existing settlements. Concentrate the existing.","Allow the small rural settlements to grow organically. 2, 4, 6 house developments rather than threatening 500 houses in a cancerous growth.","Yes","","","No","It's obvious that the people in charge have a vested interest in developing green field sites. The councils, TBC in particular, have a history of being run by people with a link to the large historical land owners who just want to turn their land holdings into a huge personal profit. This needs to stop - the May 2023 elections went a long way to helping by getting some of those out - but the decisions need to start being taken by people with the best interests of ALL residents rather than narrow personal vested interests. These are not the rantings of a crazy socialist, merely the observations of a disillusioned former Tory voter. It is blatently obvious to me that if we continue on the current trajectory everything we cherish about our local area will be lost within a couple of generations and our grandchildren will rightly curse us for our greed and stupidity.","Scenario 1: Urban concentration; Scenario 6: Sustainable transport scenario","No","","Please get it right for our children, grand children and the many many species of wildlife under threat by our current thinking."]
["Resident",null,15,"","","","","","","Reducing the need for people to travel by concentrating any development at existing major urban centres and not creating residential \"sprawl\" into the greenbelt.","Compulsory inclusion of green initiatives in all new development (solar, heat pumps, recycled grey water etc. )\nDesigned to fit with the traditional look of each town (Gloucester, Tewkesbury and Cheltenham each have their own characteristics and any buildings should \"match\" the traditional existing style to retain separate identities","Re-use/repurpose as much as possible. Major conversion of unused commercial/retail premises in towns for residential use. Lots more people living in the town centres with a drive to regenerate the many dilapidated and underused existing buildings (e.g upper floors above retail units).\nThere shouldn't be any empty or unused buildings anywhere in the region. (use any compulsory powers you have to make owners use their properties to full extent)","Yes","Yes","Keep all the existing Greenbelt land we can. We need it for all those things listed above","employment, schools, health centres","Yes","All buildings (residential and commercial should have solar panels on their roofs sufficient to provide energy needs of that building) Retrofit solar panels to all the many industrial units. supermarkets and retail units built at edge of our towns (e.g. Glos business park, Kingsditch, all the buildings around junction 12) Only give planning consent if solar is included","","","Yes","Economic reasons may reduce demand for houses as people may be unable to afford them","","","No","","Remote from existing settled communities ","","","","We need fewer empty retail sites as this makes town centres unwelcoming and discourages people to visit. May need to reduce the total number of retail outlets but concentrate them together and repurpose unneeded units for housing. No more out of town retail parks to be created. We already have enough","cheaper parking. No more out of town development","schools, health, public transport","","Don't build a dormitory. People need to be next to their job, school and shops so concentrate settlements where those currently exist. If any additional houses are built in rural areas they should be proportionate to the number of existing buildings and not \"swamp\" an existing settlement","No","","","Yes","","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 5: Rural dispersal","","","Please don't destroy our countryside by building large sprawling estates. Make better use of land within current envelopes and only extend into the greenbelt at the margins. Increase the density if necessary.\nYou are in danger of creating a single built up area across the whole of Cheltenham, Gloucester Tewkesbury and Bishops Cleeve and thus ruining the individual character and beauty of our county.\nIn more rural areas look at permitting a few additional houses (perhaps up to 5% of the existing number in each settlement) so they can be incorporated within their settlement without overwhelming it. Also make them smaller 2/3 bed family homes rather than large \"executive\" style homes which are too expensive for the average person."]
["Statutory/Specific Consultee","Canal & River Trust","","More focus on Active Travel.","Gloucester & Sharpness canal & Gloucester Docks, Gloucester City area ","Yes","","Yes","","","","","","No","The Trust will work with Gloucester City Council to identify and deliver opportunities for habitat enhancement on our waterways to meet local and national aspirations for access to green/blue space, habitat quality and connectivity.  We therefore welcome this consultation and would ask that you continue to engage with the Trust on the formation and implementation of future guidance, policies and proposals in relation to both BNG and Local Nature Recovery Strategies (LNRS).","","Yes","Wind, tidal, water","","","","","","","","","Boat dwellers need access to services such as water, electricity, pump out or direct sewage connection, parking and waste disposal. These should be provided as part of the development to prevent pressure on existing services.  \n\nEarly engagement with the Canal & River Trust would help identify issues at any particular suggested location such as navigational safety issues, water supply issues, provision of services in  relation to any location which is on, or requires access from the canal network or is on the river Severn Navigation.","","","","","","Active travel","","","","","","","","","","","The Canal & River Trust is willing to continue to discuss issues relating to Boat dwellers accommodation with the Gloucestershire GTAA group. \n\nThe Trust will work with Gloucester City Council to identify and deliver opportunities for habitat enhancement on our waterways to meet local and national aspirations for access to green/blue space, habitat quality and connectivity.  We therefore welcome this consultation and would ask that you continue to engage with the Trust on the formation and implementation of future guidance, policies and proposals in relation to both BNG and Local Nature Recovery Strategies (LNRS)."]
["Local Councillor","Tewkesbury Councillor",15,"","","No","I'd want to see greater ambition on our decarbonisation aspirations.  ","","","It can give clear targets about the level of decarbonisation we need to achieve both regionally and locally and across all sectors that are key to delivering the Plan .  It can also give clear targets in terms of ecology renewal.","I would like to see net-zero as the minimum with aspirations to better that wherever feasible","We must understand and make decisions on the carbon cost of retention and reuse versus building new.  We must also have a 'sense of place' cost attributed to existing buildings so that we make good decisions about retaining those that give us that strong sense of place.","Yes","No","","recreation, social space, education, health","Yes","solar, battery, wind.  These should be placed in areas close to appropriate energy distribution and on land with low arable/horticulture value","","","","","Yes","bungalows/low-rise for elderly and higher-density housing for younger people.  We need to see much more social housing as a priority but well integrated in the community.","Yes","","","","Encouraging early investment in zero-carbon energy provision.  Encouraging active travel. Encouraging strong provision of relevant digital infrastructure.","Yes although it should do so conscious of the carbon impact.","","","zero-carbon energy infrastructure,  a digital infrastructure that can quickly and cheaply scales in capability and capacity","","","Yes","No","","No","None of them talk about their carbon costs.  This ought to be a key discriminator","Scenario 3: Urban extensions, avoiding the Green Belt","","",""]
["","",25,"","","No","More detail associated with each scenario and more detail on proposed infrastructure for each scenario needed. Infrastructure improvements need to come before housing developments.","Yes","","Housing needs to include low water use policies to address increased demand during droughts. Also consider potential for storage of high flows to mitigate impact of flooding, and for re-use during times of drought when resources are scarce.  eg water butts in each new home, 'slow the flow' measures during high flows to recharge groundwater and alleviate flooding, new nature reserves to slow the flow, new reservoirs for storage of water to be used during drought.","The highest possible!","The highest possible!","Yes","","","cycle paths/walkways/nature reserves","Yes","","No","use evidence based housing calculations to reflect local need","Yes","as above","","","No","define what is meant as a traveller site, they are used as an escape goat to avoid planning permission and develop otherwise green spaces","urban","","","","identify what people want and need, regulate allocation of units, encourage/subsidise if necessary to encourage a diverse selection of untis","","infrastructure needs to be planned and developed across the whole region and in collaboration with neighbouring regions","New access points to the motorway and train stations to avoid piling more traffic onto roads like the A46 at Ashchurch.","Local road network - especially safety. Consideration of existing stresses on the road eg flooding, school buses, existing cycle routes etc.","Yes","Yes","","No","The conclusions do not conclude the assessment of each scenario!","Scenario 1: Urban concentration","No","",""]
["","",10,"","","","","Yes","","","","","No","No","","A General Hospital in Cheltenham with a fully staffed and operational 24/7 A and E department is a must. Relying on Gloucester Royal Hospital to provide these facilities when adding thousands of new houses in and around Cheltenham  when Gloucester Royal struggles to cope now just doesn't bear thinking about.","","","","","","","","","No","","","","Make more of the airport at Staverton. Perhaps making it more attractive to fly routes to large cities in the UK. ","","","","","","","","","","","","Scenario 1: Urban concentration","","",""]
["","",10,"Expanding access to the railway network","","No","Much  more emphasis is required on use of the rail network in Gloucestershire rather than depending on the M5. In particular the transfer of road freight to the railway network of the armoured vehicles from Ministry of Defence Ashchurch.","","","Better public transport less dependence on cars.","","","Yes","No","","Public transport facilities.","Yes","Hydro electric along the Severn","No","Accurate local population forecasts not imposed from central government which are far too high.","Yes","Areas of Outstanding Natural Beauty.","Yes","Second or holiday homes should be banned.","Yes","Use of unused car parks","","Focusing on Gloucester rejuvenation first","The proposed science park by GCHQ will be a disaster for the area. It will only bring in commuters from London and the Midlands rather than local employment. These will be specialised skills and not  employment for the local community. Does Gloucestershire really need inward investment with other main cities (Birmingham) nearby.","Protect our farmland and farmers and allow them to expand naturally.","Better public transport and restricting out of town shopping centres ","No out of town shopping centres","Better rail access and facilities.","Better access to rail facilities for both passenger and railfreight (eg Ashchurch)","Public transport","No","Yes","Move to better public transport to meet Net Zero carbon targets.","Yes","","Scenario 1: Urban concentration","Yes","Areas of Natural beauty","This whole document is far too complicated for the average person to understand and comment on. I am concerned  that the Government's housing figures are too high and should be challenged as Gloucestershire will become like London and the South East and overdeveloped. Above all, brown land should be used first and there is plenty of unused brown land which must be developed first. This does not seem to be considered. Green Belt must be protected at all costs.  The Plan needs to take into account the travel options available in other areas to ensure public transport is given the priority over motor vehicles. For example, reopening Stonehouse Bristol Road railway station (although in a different council area) will encourage more environmentally sound travel into Gloucester rather than the motorway. Other railway stations (eg Churchdown) also need reopening."]
["","",30,"","","Yes","","Yes","","Dictate long term thinking across the board to make our area more resilient to warming events and unusually strong storms/flooding - more insulation, slowing the flow of water in catchments and reducing traffic by encouraging public transport","Reduce the thresholds for affordable homes - too many developers dodge this requirement in order to make better profits- we do not need more houses worth more than £500k in our area","Retention and reuse should be incentivised- repair and reuse should be a more sustainable option for the environment compared to building on green belt or agricultural land.","Yes","Yes","Land around Chargrove lane contains remnant orchards as well as providing important green space for Hatherley and Warden Hill that was vital during the pandemic lockdowns. More should be done in these areas to reconnect the floodplain and increase field margins, and the local farming community should be encouraged to make better use of CS or ELMS","Local shops, GP surgery, recreational facilities (gym/pub etc)","No","","","","","","Yes","More affordable housing","Yes","","Areas should be protected and enhanced for the traveller communities to encourage these groups to adopt these areas as their responsibility and something to conserve, not an area of waste group to briefly exploit","","Look to the stock of dilapidated industrial buildings in our towns and seek to enhance these as work spaces/offices - too many people commute, but offering work areas closer to housing would be ideal","Encourage involvement from the farming communities and promote opportunities for supporting small farmers and urban people interested in farming -  land ownership is the biggest blocker to innovators entering the industry, so grants to assist would be greatly appreciated as would incentives for smaller scale operations","","Consider local shops and services separately from larger commercial businesses - if a supermarket chain wants a new superstore within that area, the impact to local businesses should assessed and evaluated","Cycle lanes and adequate provision for public transport","Dedicated cycle lanes and ideal some form of mass transport such as new bus links","Access to NHS services and to community areas including pubs and community areas","Yes","No","","","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","","",""]
[null,null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt","","",""]
["Resident",null,5,"","","","","","","","","","Yes","","","","","","","","","","","","","","","","","Take into account existing uses or supply alternative property","","","","highways","","","Yes","Building houses less than 10 meters from muck heaps and stables is not acceptable","","","","Yes","My property as I am being forced out of it Ascot house farm","A development within 10 meters of my property has ruined my life, my family has been destroyed"]
["Resident",null,20,"","","","","","","Retain large areas of open space for the natural environment to develop","Safe materials, energy efficiency,","Upgrading to the highest standards","Yes","Yes","Plock court Longford, Staverton airport","Schools, Doctors surgeries Community centres","Yes","Solar systems, wind turbines where possible without ruining any outstanding areas of natural beauty ","Yes","","Yes","Consider employment availability and ease of access","Yes","Starter homes  and bungalows","","","","","","Provide cheaper housing for employees ","Support community transport","Ensure there is easy parking","","Schools, medical  facilities, community centres with social and sport facilities","Transport, local shops, easy access to a larger centre, retention of surrounding green belt","Yes","Yes","Access to social and community centres for all ages.\nProvision local green spaces","Yes","","Scenario 4: New strategic settlement; Scenario 6: Sustainable transport scenario","","","Consider the need for accommodation for the disabled and elderly to be included in the development"]
[null,null,"","","infrastructure shortages are currently chronic in the urban extension areas from JCS1 along with flood protection issues- these need to be addressed prior to allocating further urban extension sites","Yes","","Yes","","","","","Yes","Yes","","","","","No","there are no official government targets as they were abolished in 2022 and use of the standard method will just generate numbers for Cheltenham and Gloucester that would require considerable work to find within their areas most of which would be below strategic level sites and not deliverable within the timescales, this in turn would almost inevitably lead to the easy option being taken and a large part of the calculated need for Cheltenham and Gloucester being dumped in Tewkesbury. This in turn exasperates the chronic infrastructure shortages created by JCS1 where even if funding were found immediately would take years to deliver","Yes","flood risk in Tewkesbury along with AONB and physical boundary restraints in Cheltenham and Gloucester","","","","","","","","","","","Schools, doctors, dentists, roads, flood protection, community centres, shops, buses, cycle and other transport options and green spaces","Schools, doctors, dentists, roads, flood protection, community centres, shops, buses, cycle and other transport options and green spaces","","Yes","","","No","the urban extension options have proved to be very problematic in JCS1 due to flooding and lack of basic services and infrastructure this will take years to deliver up to the standards required now let alone future needs even before more sites are added","Scenario 1: Urban concentration; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","The outstanding services and infrastructure from the original plan need to be delivered for communities prior to considering future urban extension options being considered as the new suburban areas are severely short of basic services provision and infrastructure"]
["Resident",null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Improved public transport links and cycle routes","Parking, transport links, schools and community spaces","Schools, shops, parking","No","","","","","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt","No","","Of the 6 scenarios presented, those focusing on existing urban areas would appear to be the most suitable "]
["Other","Tewkesbury Town Council",25,"The policy topics lack a consideration of farming and the use of farmland.","The following local policy topics are unique to our parish:\n•\tWater management\n•\tTourism\n•\tThe preservation of historic fabric\n•\tSocial hubs\n•\tNature reserves/SSSIs\n•\tRights of way","Yes","","Yes","","While not discouraging development, the local plan should set a high bar for water management on sites that might be developed for housing; not just on allocated sites, but on sites that come forward during the plan period.  This should include finance to ensure that organisations appointed to manage SUDs cannot fail, measures to effect a reduction in the threat of flooding in vulnerable downstream neighbourhoods, improvements to infrastructure so that sewers cannot become overwhelmed and roads so choked with traffic that cars stand idling for longer periods, and proper provision for sustainable modes of transport.\nThere should be an encouragement for owners of listed buildings to embrace low carbon sources of energy, with perhaps a scheme similar to the HAZ, to enable the installation of heat pumps, double-or-secondary glazing, photovoltaic roof slates and solar panels.\nThe design of roads and parking strategies should aim to create a more cycle-friendly environment and also a more pedestrian-friendly environment.\nThere should be a requirement for new and converted homes to have access to an EV charging point.  There should be a requirement for new industrial and commercial properties to contain a proportion of EV charging points.\nCommunity spaces could include drop-off hubs for the delivery of internet and mail-order purchases, from which people can choose to collect goods.\nThere should be greater access to E-bikes throughout our communities.\nThe cycling network between communities needs to be strengthened and made safer.\nThe plan must not inhibit the ability of natural water courses to deal with increased rainfall.\nThe plan should allow for and encourage safe movement of wildlife, via wildlife corridors, toad passes, etc","Encourage developers to aim for zero carbon, in both the development stage and in the running of new buildings.\nEncourage the use of reclaimed materials where practicable.\nEncourage groups of self-builders to work together to source supplies of materials and renewable energy.","Redevelopment of brownfield sites must be encouraged above the use of, say, greenbelt land.  Perhaps such sites could be used for modern farming methods, such as hydroponics.  Perhaps the development of key brownfield sites could be linked to the development of greenfield sites, so that the relative expense of developing the former can be partially offset by the opportunity to develop the latter.  Planning authorities could carry out a ‘de-risking’ strategy for stubbornly undeveloped brownfield sites (as with Healings Mill).","Yes","Yes","The fields off Walton Cardiff lane, on the opposite side of the Derek Graham Playing Field.","Medical and dental services, schools, general stores, banking facilities, sporting facilities, community halls, play spaces, high speed broadband, places of worship, places for burials and interment of ashes etc","Yes","Ground source heat pumps at central locations in new housing developments and also in rural areas.  Solar panels, pv slates and air source heat pumps in already developed areas. Hydro-electric turbines watercourses.","No","The number derived from the local annual housing need calculation needs to be reduced, to take account of the following factors:\n•\tThe proportion of the total plan area that cannot be developed because it is in a flood plain\n•\tThe proportion of the total plan area where development is restricted because it is in an AONB\n•\tThe proportion of the total plan area that has special characteristics, eg a particular historical environment, that would be harmed by the close proximity of modern development.\n•\tThe proportion of the total plan area that is protected by SSSI or listed Ancient Monument status\n•\tThe proportion of the total plan area that needs to be allocated to major infrastructure, eg roads","Yes","Due to the densely developed nature of Cheltenham and Gloucester, there is a pressure to bring forward sites in areas that are also very much subject to the pressures described in 12a.","Yes","Given the relatively elderly demographic of the northern part of the plan area , there needs to be housing that is suitable for retired people, and is also designed to be easily adaptable for their changing needs, so that they can live independently for longer.  There needs to be accommodation for growing families, that again can adapt to their needs as they grow older.  There needs to be suitable and affordable accommodation for young people, close to the facilities that enable them to socialise and lead healthy lives, without having to leave the area.","","","","Where possible, economic development should be focused on existing centres in order to help them to remain, or become more, vibrant.  Empty sites in town and city centres need to be given new economic uses.  Local planning authorities should encourage ‘in-the-meantime’ uses for some town centre sites, perhaps for the erection of temporary start-up business premises and/or entertainment/leisure venues, so that there is still footfall in those areas, until more permanent premises can be found.","The Strategic and Local Plan could identify the types of businesses that work well in close proximity to each other and encourage them to locate in premises near to each other.  A fast broadband connection throughout all urban and rural areas is vital to ensure good connectivity and thus allow businesses to flourish.  Some businesses don’t need huge physical movements of goods, and these should be encouraged in areas where the road network is less robust, and areas which can be cut off due to floods.","There are modern types of farming and market gardening methods that don’t require huge tracts of land and these may be more manageable for young people who haven’t actually inherited a farm.  Strong internet connections will enable businesses that don’t rely on extensive sewerage networks to flourish in rural areas. Access to renewable energy will also be beneficial. ","The Strategic and Local Plan could incentivise modifications to existing buildings in order to make them more accessible and also more energy efficient.  It can also incentivise the repurposing of existing structures and sites for new businesses and accommodation.","It can help to encourage banks/post offices to maintain a presence.  It can encourage the provision of sustainable transport options and provide well-lit, well-overlooked, safe pedestrian routes, that will make it more possible for residents to use those facilities without having to get into a car.","A sewerage system that is fit for the 21st Century, strongly managed SUDs, roads, strong internet and mobile phone connectivity, schools, health facilities.","Good links to existing settlements, additional infrastructure provision, so as not to disadvantage users of existing provisions.","Would it be possible to live a fulfilling life here and not have ready access to a car?  There needs to be a community hub, shop, local jobs, open space, play areas, safe and sustainable access to other communities and a fast broadband connection.","Yes","","","Yes","","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","Further information for number 8:\n\n8.\tShould the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development?\n\nYes.  10% can be relatively easy to gain, particularly if the land, watercourses, trees and hedges have not been well cared-for for some years previously.  The level needs to be set at a point which requires a real effort on the part of the developer, to attain a level that is at least 10% above what can be evidenced to have been on the site, during the history of the site.  Local people can be encouraged to keep records of biodiversity in their areas.\n\nGeneral comments:\n\nAccommodation needs to be made in the plan for residents who will pass away.  As our population increases, so will our need for cemeteries and memorial spaces.  There needs to be a range of different options, from the reuse of existing plots of a certain age, to the establishment of woodland cemeteries.  We must be mindful that, within the Severn Valley, opportunities to accommodate such sites within easy access of communities is limited by the height of the water table and we should take care not to allow housing for the living to take all the high ground.  \n\nWe could learn from Dutch experiments with amphibious homes and offices – ones that can rise above the water in times of flood and those that don’t rise but can cope in flood conditions.  The Dutch are even now creating such homes in heavily developed areas and areas with a high-quality historical environment.  The Dutch also have a ‘Make Room for the River’ programme from which we could learn.\n\nWe should challenge the assumption that we have to keep growing.  What about keeping a balance that sets a comfortable maximum level of growth that retains a good quality of life and allows it to still be nice to live here.  Unless we cap our economic growth, we are in danger of losing the characteristics of our area that make it attractive to come and live here."]
["Planning agent or developer","Morgan Elliot Planning","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Scenario 1: Urban concentration; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","",""]
[null,null,20,"","","Yes","","Yes","","","","","","Yes","Boddington ","","","","","","","","","","No","","","","","","","Stop building on all the farmland ","","","","","No","","","","Scenario 6: Sustainable transport scenario","No","",""]
["Resident, Local Councillor","Self employed",15,"Preserving existing communities","Local NDP's should be referenced","Yes","","Yes","","Climate change is of prime importance, however affordable housing is also at crisis point...if houses are designed and build with energy saving features it is imperative that the affordability of the house is not lost.","Use of Low carbon energy sources. Energy efficient insulation","Re-development of existing building should be supported financially to make it viable, particularly large building such as Healings mill for both employment and residential.","Yes","Yes","Community Woodland in Claydon Ashchurch....plus any flood plain...in it very important that there is good connectivity for wildlife","Shops, employment and recreation facilities to create 15 minute communities.","Yes","250 acres for solar farm already permitted in Ashchurch. Investigate the possibility of Hydro and Wind. Houses to be built with energy generation (Solar or Heat pump)...each development to be able to demonstrate when it will become Carbon neutral","Yes","","Yes","Consideration for flooding and available transport links","Yes","Bungalows, and warden controlled communities for the aging population, perhaps consider multiple occupation housing for people moving into the area or for temporary contracts.\nWhen considering affordable housing it would be good if the Council  controlled rents and purchase prices, some previous schemes sometimes are not quite what they seem..\nConsideration should be given to young people wishing to remain in the area.","Yes","Consideration should be given to how Traveller sites can be integrated, so a to allow for use of community facilities such as schools and shops","on edge of larger communities, with facilities to be self sufficient, e.g. washing and toilet facilities, waste collection....easy access for transient travellers. ","Support for existing business to expand and encourage new business to invest...creation of attractive places to work that people can be proud of using similar principles to new housing","Encourage and support for training facilities, finance/subsidise training programmes and apprenticeships in skills such as engineering, health and beauty, construction, vehicle mechanics, electronics, hospitality.","Ease planning rules for farms wanting to diversify for employment units, Discourage development of farm buildings for housing.\nMake available low cost easy in easy out terms for start up and small businesses.\n\n","City and Town centres to transform from retail to residential, with great transport systems (Buses, Scooters etc.) but also heath facilities such as Doctors/Dentists and Gyms","Low/No rates for small shops....consortium of shops from different area's to increase buying power...this could be coordinated by a council... encourage volunteer staff... within community Hubs, could even include an occasional  medical representative as a district nurse, or a roaming Doctor ","Sustainable transport, but also to include road improvements to ease congestion where private vehicles are unavoidable.","Road and Rail improvements, Health facilities, Supermarkets, Shopping and leisure facilities to create 15 minute communities...Green open spaces commuting and relaxing.","A community that will get behind change...generally the majority of objection to development is based around transport","Yes","Yes","Consideration for in-between scenario's so instead of one large strategic development consider 2 or 3 smaller developments, big enough t obring the required infrastructure.","Yes","","Scenario 1: Urban concentration; Scenario 4: New strategic settlement; Scenario 6: Sustainable transport scenario","","","It is vitally important that existing communities are considered, no matter which scenario's are selected, growth of this scale is  both exciting and frightening, it will mean considerable change for many people...\nDevelopment should only come when the infrastructure is in place or at least planned all too often new developments are just housing which is no longer acceptable, particularly were there are no easy answers to transport constrains so it is more important than ever that developments are sustainable....\nIt is generally understand that Tewkesbury borough a likely to take some of the Housing requirements from Cheltenham and Gloucester it is important that each of the boroughs benefit with BNG, as is being demonstrated by developments coming through there are oppurtunities for some lage BNG (70% has been suggested in Pamington)\nCurrently the boroughs (Tewkesbury in particular) are under attack form piecemeal development this must be stopped (or paused) until the SLP can take control. Developers appear to be pacing development completion to suit their own ends.\nWe may be in  a housing crisis but it is imperative that housing design, size and construction is suitable for growing families with an expectation of longevity of housing, it is likely we will  see the 40 - 50 year mortgages in the no too distant future it would good if the houses can make that timeframe with out major costs.\nEmployment type is critical, Advanced Engineering has been considered, the area has a history in this discipline and it is an industry which brings with it great employment opportunities... \n\nConsidering the area is dominated by its rivers (and flooding) WATER QUALITY must be a high priority.\n\nHopefully there will be an option for me to save my answers if not hen it is something to consider for the future"]
["","",10,"","","Yes","","No","","","","","","Yes","Parton Farm, Land to the West of Gloucestershire Airport (CHU015). \n\nConserving and enhancing farm land/ green belt land enhances biodiversity and supports wildlife populations. \n\nCertain agricultural practices, such as maintaining floodplains and implementing natural water retention measures, can help mitigate flood risks by absorbing excess water and reducing runoff. Preserving farm land in strategic locations can contribute to effective flood management strategies.\n\nFarm land can act as a carbon sink, sequestering carbon dioxide from the atmosphere through photosynthesis and storing it in soil and vegetation. Protecting agricultural land helps maintain this important carbon storage capacity, contributing to climate change mitigation efforts.","","Yes","","","","","","","","","","","","","","","","","","","","","","","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal","No","","The land around Glouceatershire airport should be preserved on the basis of aviation safety for emergency landings and noise mitigation."]
[null,null,15,"Place-making and quality of life","Council Area: growth strategy, distribution transport network","No","A much more sensitive settlement by settlement analysis of capacity and opportunities for coherent place-making","Yes","","Maintaining a local mix of land use and employment to minimise commuting","Go for the leading edge constructional standards eg Passivhaus etc plus mandatory sustainable energy generation","Standing structures represent value. Judgment and creativity must be applied to decision making. Therefore experiences staff must be appointed.","Yes","Yes","There needs to be a comprehensive land use survey and plan , Large amounts of land are underused and misused.eg mandatory application of woodland management. Consent needed for horseyculture . stop the wrong uses being applied to high grade agricultural land.","primary/junior education, health, appropriate retail for  units of approx. 3,000 people. Elderly persons provision for downsizing and care provision","Yes","A Borough Plan is long overdue to identify land that would be suitable for solar generation based on the landscape impact and agricultural land quality","No","Housing need and housing capacity of a particular area should be based on a more complex analysis that would produce built communities that have quality and sense of place. They actually need planning as distinct entities rather than a number crunching exercise.","Yes","The Borough must be prepared to make firm judgements on the environmental capacity for growth at the local community level up to the shape of the future Borough.","Yes","Much more thought needs to be given to providing a range of dwelling types eg the \"parker Morris\" standards. Many rural areas are in dire need for family units to downsize and that must lead on to sheltered housing and care hubs. Private sector volume house builders will not provide the answers. More creativity is needed including the LA's providing serviced site for self build.","Yes","Proper planning enforcement and the application of legislation is required to bring sites under proper control eg the land raising the continues on the outskirts of Gloucester in the flood plain.","Develop and intensify the sites that already exist, and positively select new area in the garden town type large scale releases.","Actively intensify the use of brown field sites used for business and industry. Provide site release for business and light industrial opportunities at a local level eg redundant farm groups. Promote home/work units and shared office spaces. All will require proper servicing.","Seek to create quality environments that are well service by the internet and transport links.","Insist that working locally would be the medium to long term goal ","Encourage the city and town centres to promote the special services and retail opportunities that are worth using eg \"concentrate \"rather than spreading big sheds all over the landscape. Again make an effort to create a special quality of place.","Ensure that the key villages have an optimum population to support appropriate levels of  growth and services. Think about the quality of place that the Borough is planning to create rather than lax Development Control providing the answer.. ","Revise and renew the service infrastructure that is often worn out or under capacity. Provide appropriate community facilities, including education, health care, support for the elderly and recreational provision.","Everything! there are no short cuts and there are particular dangers just relying on private sector volume house builders stepping up to the plate.","Can you provide a comprehensive service infrastructure. Does the development have adverse impacts on the surrounding community patterns and lock up the existing transport network. On top of this what sort of impact such development have on the landscape setting  and natural environment.","Yes","Yes","Detailed analysis of how the transport system could be made more sustainable by properly integrating new development to reduce unnecessary movements.","Yes","","Scenario 1: Urban concentration; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","Yes"," A complete settlement re-evaluation is needed to identify possibly up to 6 new \"key villages\" to provide for additional growth to achieve a more sustainable community.","The plan will not achieve its goal unless more detailed analysis is undertaken at the local level to identify the real opportunities that exit across the Borough. It needs an understanding of your \"patch\", care, judgement and creativity; qualities that are often sadly lacking in an era of forward planning by Development Control"]
["Statutory/Specific Consultee","Theatres Trust","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Further to rural shops and services specifically, we recommend inclusion of a strategic policy which guards against the loss of all community/cultural/social facilities in line with paragraph 97 of the NPPF (2023)","","","","","","","","","","","",""]
["Resident","Ridge Technical",30,"","Excessive use of A40 & B4215 and flooding on both routes plus A417 isolating communities and pressure on local roads ","Yes","","Yes","","By addressing flooding caused by rivers and land runoff.  Improve local transport.","Utility, road and transport infrastructures.","Use of existing buildings as a priority to new development .","Yes","No","","Access to green spaces, social support networks.","Yes","Solar farms and battery power storage. Inclusion of renewable system in all new build individually or networked.","","","","","","","","","","Planning committees need to be more flexible and open minded.","Transportation, road networks, use of rivers and canals","As above","Being more flexible and open minded in the use of brown field sites and existing buildings .","","Reliable and sustainable utility services. Suitable transport and road provisions.","As above plus education and health provision.","All as above two questions.","Yes","Yes","An additional River Seven crossing from Forest of Dean (A48) to Gloucester (A38)","Yes","","Scenario 6: Sustainable transport scenario; Scenario 3: Urban extensions, avoiding the Green Belt","No","","This has not been an easy survey to complete. Despite vigorous efforts by our local parish councillors it has been an uphill struggle to complete and does not encourage participation. This results in an unfair and disproportionate result especially if one does not have access to the internet."]
[null,null,"","","","","","","","","","","","Yes","The Chargrove Triangle, near Up Hatherley.","","","","","","","","","","","","","","","","","","","","","","","","","","Scenario 3: Urban extensions, avoiding the Green Belt","","","Please prevent beautiful countryside, such as land off Chargrove Lane, near Up Hatherley, Cheltenham, (often called the ‘Chargrove Triangle’) from being built on.\nIt provides vital green space for people to enjoy walking and cycling in a largely car-free and therefore unpolluted environment.\nThe area is a haven for wildlife too and retaining natural landscapes for animals is vital for biodiversity.\nPrevious plans to build houses on the land were rightly refused and it should be saved for current and future generations to enjoy."]
[null,null,25,"","","","","","","","","Any empty buildings where domestic or commercial should first be upgraded to make useable before demolishing or new builds erected.","","","","GP surgery, hospitals, schools, open areas for walking,","Yes","","","","","","Yes","bungalows - this allows older residents to downsize whilst still living independently","","","","","","","","Lower rents and landlords made to upkeep empty units","","","","","","","","","","","","Churchdown railway station reopened.  With the growing ageing population not everyone will be able to walk, take a bus or drive easily so facilities need to be accessible.  Young and old residents with any form of disabilities need their future needs taken into consideration."]
["I work for a charity or volunteer in the area","Gloucestershire Playing Fields Association","","","","No","The Gloucestershire Playing Fields Association would like to see the words 'sport and recreation' (or similar) introduced to the 'new provision' element of the vision, as we consider that this element is otherwise diminished if not specifically highlighted within the following sentence: 'Growth will have been supported by the provision of a range of essential digital, transport, community and other infrastructure.'\n\nWe would prefer the sentence to read: ''Growth will have been supported by the provision of a range of essential digital, transport, sport and recreation, community and other infrastructure.'\n\nAlthough sport is mentioned later in the para: 'Together with necessary retention and management of existing sports and leisure facilities, this will have unlocked opportunities for healthy lifestyles, inclusive access to sport and recreation, active flood risk management and improvements to biodiversity.' - this relates to management of existing facilities and not provision of new facilities to meet the needs of the growing population.\n\nThere should be a proactive approach to identifying and safeguarding sport and activity hubs/centres within all new strategic development, including both indoor and outdoor facilities for community sport and activity.","Yes","","","","","","","","It is essential that facilities providing communities with access to high quality sport and recreation activities are provided within major developments. This should include strategic sports hubs, that provide indoor sports facilities, as well as outdoor sports pitches, including 3G all weather pitches. Piecemeal (small and medium) housing development does not currently provide an adequate level of formal sports and other recreation provision, and without strategic hubs being planned into the SLP area from the outset, many communities will have poor sport and recreation provision, leading to further health inequalities in some areas.","","","","","","","","","","","","","","","","","It is essential that new facilities providing communities with access to high quality sport and recreation activities are provided within major developments. Smaller developments should contribute to strategic sports hubs that will serve the areas they are built in.\n\nThere should be a number of sites safeguarded to build new, strategic sports hubs, which will provide indoor sports (and community) facilities, as well as outdoor sports pitches, including 3G all weather pitches. \n\nToo many small and medium sized developments currently do not provide any on-site formal sports provision, and there is no consistent strategic overview or policy requirement, created from the starting point of the Fields in Trust standards/guidance and Sport England guidance, to ensure that there is sufficient new provision to adequately cater for the projected population growth.\n\nPlanning, securing and safeguarding the provision of new, strategic sports facilities within the SLP document should also counter the 'viability' argument frequently used by so many developers as a reason to not provide such facilities.","As per previous answer. It will be critical for strategic scale new settlements to make adequate provision of new, strategic sports facilities (both indoor and outdoor), to meet the needs and demands of the growing population. It should not be something left to individual developers, there should be an holistic planned approach across the whole SLP area. \n\nOften the new sports provision offered as part of med/large developments is restricted in size (e.g. one football pitch with small changing room) or inadequate for the current and future level of demand (and indoor sports facilities are rarely provided). Community centre facilities should be required to include at least one sports hall sized space, to enable indoor sport and activity to take place.","","Yes","","","","","","","","The adopted Playing Pitch Strategies for the three local authorities are either out of date, or at end of life, requiring a comprehensive review (as part of the SLP process) of the current qualitative and quantitative position, future provision of facilities, plus current and future demand for sports pitches and other associated community sport and recreation facilities. Built facilities strategies and open space strategies should also be reviewed as part of the SLP process, to ensure that an accurate, comprehensive overview of all current and future needs in respect of sport and activity is created, to support the relevant SLP polices. \n\nThe SLP process is the one opportunity that the three councils have to think more strategically and holistically across the Cheltenham, Tewkesbury and Gloucester area, in respect of providing high-quality, accessible, sport, activity and recreation opportunities to all residents residing in the three administrations within the Plan area. \n\nThe Gloucestershire Playing Fields Association, would welcome the opportunity to work with the three local authorities, Sport England and Active Gloucestershire as part of the SLP process, to ensure that everyone is working towards the same objectives and that the new Plan makes robust, tested policies, to secure the best level of provision for sport and activity that it can, in relation to its existing communities and within all new development."]
["Statutory/Specific Consultee","Longford Parish Council",20,"","Infrastructure shortages are currently chronic in the urban extension areas from JCS1 along with flood protection issues- these need to be addressed prior to allocating further urban extension sites.","","","","","","","","","","","","","","No","There are no official government targets as they were abolished in 2022 and use of the standard method will just generate numbers for Cheltenham and Gloucester that would require considerable work to find within their areas, most of which would be below strategic level sites and not deliverable within the timescales, this in turn would almost inevitably lead to the easy option being taken and a large part of the calculated need for Cheltenham and Gloucester being dumped in Tewkesbury. This in turn exasperates the chronic infrastructure shortages created by JCS1 where even if funding were found immediately would take years to deliver.","","","","","","","","","","","","","Schools, doctors, dentists, roads, flood protection, community centres, shops, buses, cycle and other transport options and green spaces","Schools, doctors, dentists, roads, flood protection, community centres, shops, buses, cycle and other transport options and green spaces","","","","","No","The urban extension options have proved to be very problematic in JCS1 due to flooding and lack of basic services and infrastructure this will take years to deliver up to the standards required now let alone future needs even before more sites are added","","","","The outstanding services and infrastructure from the original plan need to be delivered for communities prior to considering future urban extension options being considered as the new suburban areas are severely short of basic services provision and infrastructure"]
[null,null,"","","","","","","","Keeping and maintaining the Green Belt and wildlife areas should be a priority for dealing with the impact of climate change. Having areas where people can walk rather than drive would not only help with Mental Health issue but reducing the use of vehicles.","Improving and regenerating homes rather than building new should be priority. This should be on brown field sites.  Where new are being build they should be highly insulated and triple glazed. Also consideration of solar panels. These should be part of Building Regulations.","","","","","Local medical services such as medical centres, schools and community centres  ","","","","","","","Yes","Bungalows and/or properties that can be adapted for people with disabilities.","","","","","","","","","Adequate bus services are essential to reduce vehicle use and help with the impact of Climate changes. Also local train stations could be provided to enable people to travel between Gloucester and Cheltenham.    ","","","","","","","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt","","","Wildlife areas must be preserved and maintained. Since the pandemic more people are taking advantage of the countryside. The access roads and parking areas should be provided and maintained so where people have to drive the vehicles can be parked adequately. On the county lanes which lead to wildlife areas (such as Chosen Hill in Churchdown) these should be permanently maintained with passing places where the roads are so narrow.   "]
["Resident",null,"","The mental health and well being of residents should be considered also…space and good air quality with access to green, natural spaces for walking etc.","Brown field sites and empty properties in the town centres should be considered to regenerate the towns and boosting the local economy before any more building takes place in more rural and semi-rural areas. We need to restrict urban sprawl. In Churchdown and Innsworth, for example, there have been large areas of development already which has a knock on effect on traffic, and services such as schools, doctors’ surgery etc.","","I agree with most of the draft vision but the part concerning housing development is more relevant to the established  urban areas and not so much for the semi-rural areas such as Churchdown. Valuable green spaces and farmland must be preserved.","Yes","","Preserving the green belt should be given priority and also do not build on flood plains. Perhaps plant more trees in open spaces to help offset carbon emissions and also mitigate flooding. \n\nEncourage residents to use water butts to save water..perhaps the councils could provide them. This would mean less reliance on hoses in the summer.\n\nTo prevent flooding, encourage householders to have grass or gravel in their front drives, rather than hard surfaces. Also, ensure that the drainage systems in roads are inspected regularly and any blockages are cleared. At the same time, check that brooks are running freely.\n\nClimate protective measures should be used in the design of new houses. All new houses should have charging stations for electric cars.\n\nCycle paths and a good, reliable public transport system to encourage people to use it rather than private cars. Perhaps free public transport for under 18’s ( as in Scotland) would also avoid the use of cars. At the moment it is too expensive for parents to use public transport for their families. This would reduce pollution and the use of fossil fuels.","Any new buildings should be designed with climate change measures in place using eco-friendly materials, insulation etc\nThe Greenbelt must be preserved and not used for housing development.","Brownfield sites and existing buildings should be used before building on farmland and green spaces","","Yes","The land between Brookfield Road, Oldbury Orchard and Brockworth Lane has a rich biodiversity and is a haven for wild life and flora. Larger mammals such as foxes, deer and badgers are there and also birds, amphibians and reptiles. The area is beautiful in the spring/summer with wild flowers. The area is well used by walkers on the public footpaths.","Bus services and shops","","","","","","","","","","","","Lower rates for business owners in Cheltenham and Gloucester","","Sponsor apprenticeships in local businesses. Encourage farmers to use their land for agriculture so we are not so reliant on imported produce. Allow them to diversify and use existing buildings for holiday lets etc.","","","Green spaces, good transport links, shops, schools, doctors’ and dentists’ surgeries.","","Flood risk and loss of green fields and countryside.","No","No","","","","","","",""]
["Resident",null,100,"Population ageing and eventual decline in the long term.","","No","You want to justify unsustainable suburbanisation in Gloucestershire when studies show this is not how urban planning should be.","No","","I don't think encouraging Barratt Homes etc to build more box homes will help the environment.  Greenwashing at its finest, the whole plan.","Stop building on greenfield land. Preserve the compact nature of towns and cities for the benefit of connectivity and aesthetics. Aesthetics is always ignored.","Make it almost impossible for developers to use greenfield sites when there are alternative brownfield sites within a five mile radius.","Yes","Yes","All floodplain land in Gloucester. All greenfield sites in Gloucestershire.  Preserve it.","Pubs and small shops. It is unbelievable that Coopers Edge is in effect a housing estate with almost zero real fully accessible community facilities.\nBuild a good local pub and a small local shop. Require community facilities in these soulless developments at the very least. \nAnd goodness me the state of the facades. Black mould within 5 years.\nDisgusting.","Yes","","","","Yes","Natural population growth is low within Gloucestershire. \nAlmost all of the current and future growth is from migration internal and international. \nYou have not factored in the fact that the UK is not going to grow forever. You have not considered issues with segregation in urban areas.","","","","","","Encourage centralisation of business. Encourage more businesses to locate themselves within city and town centres.","","","By evolve you mean turn shops into houses, which is NOT what should happen.\nLower rents. Encourage startups. Incentives for risk.","","A tram system would be a dream.","","","","","","","","","","","I am disgusted that you merely want to encourage even more intense population growth through house building when it's not needed and will not bring down house prices in the county and make toungnpeople like me afford a house.\nThis is all about big business getting quick profits.\nA patchwork of unsustainable housing estates blotting even more greenfield sites."]
["","","","","","No","","","","","","","","","","","","","No","","","","","","No","","","","","","","","","","","","No","","","","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","","","The fields behind Ratcliff Lawns are special landscape interest designation and we must protect the iconic openness of the views from Cleeve Hill – tourist attraction, known world wide etc."]
["Local Councillor, Resident","Local Councillor","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt","","",""]
["Resident",null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","You mention developing an Infrastructure Delivery Plan (IDP) and here you are asking what types of infrastructure are most critical. I would like to refer you to the IDP developed 10 years ago by Calderdale - some 80 pages. All of the types of infrastructure mentioned are also critical to North Gloucestershire and need to be assessed before you start delivering new homes. \n\nhttps://www.calderdale.gov.uk/environment/planning/planning-policy/evidence-base/infrastructure-delivery.pdf","As above. I would like to refer you to the IDP developed 10 years ago by Calderdale - some 80 pages. All of the types of infrastructure mentioned are also critical to North Gloucestershire and need to be assessed before you start delivering new homes. \n\nhttps://www.calderdale.gov.uk/environment/planning/planning-policy/evidence-base/infrastructure-delivery.pdf","","Yes","","","","","","","",""]
["Resident",null,10,"The setting of service levels against monthly performance. The performance measures may, but not limited to, air quality, noise, exercise and well-being quiet routes for lo local people.","Chargrove Lane. Plus surrounding urban exercise and environment routes to amenities,  such as, shops, school and wellbeing spaces.","No","No measures linked to triggers of service and well-being impacts on residents.","Yes","","To enhance and provide new and existing zero carbon forms of mobility. By that zI mean walking, cycling. Dog walking and jogging routes with suffient space, quality of segregated  path.","Consider mode of transport to the building in a way that people can identify with. By that I mean to walk and cycle on a good quality, well maintained, route. So it not just 'Buildings with zero carbon impact, solar etc but the users means of access that's missing for me.","Where possible maintai existing history balanced with zero carbon reuse.","Yes","Yes","Chargrove Lane","Quick Zero carbon urban routes for walkers an cyclist.","Yes","Solar and wind. Gloucester Airport. M5 motorway corridor.","No","Calculations are a quanative measure.  This must be balanced against the qualitive measure. By this I mean the wellbeing of all residents.","Yes","Where the sevice capacity does not meet the proposed plan. I.e sewers, cars, car perking and limits on number of cars per dwelling as examples.","No","","No","","","Airport an Cyber Park.","Airport,aviation new environment business. I.e zero or reduced carbon.","Improved transport links that operate within business hours and weekends\n Including hospitality so running buses until late hours.","Build on existing festivals that bring in revenue by compensating local residents. By that I mean reduced tariffs if you live in Gloucestershire.","Better transport links that are published and easily accessible. ","Urban zero carbon transport routes","Limit the number of cars per dwelling. Therefore limiting demand to a planned capacity. Go and see recent new builds in Up Hatherley to demonstrate this point. Too many cars, pollution, per dwelling. Overspillong onto paths and contesting roads. There are no incentives to use alternative modes!","See above comment.","Yes","","","No","You have to be accountable passed the planning stage into Operational use to measure how successful you have been.  Good start though.","Scenario 1: Urban concentration; Scenario 6: Sustainable transport scenario","","","Read Scarlett McNally: Enabling active travel can improve the UK’s health | The BMJ. \nhttps://www.bmj.com/content/384/bmj.q522"]
["Resident",null,15,"Yes. All policies should consider the end state and the point at which the area reaches saturation. I.e. the point when no more houses should be built.","","No","More weight needs to be give to Neighbourhood Development Plans (NDP). 5 year land supply should not trump the NDP.\n\nLand between villages should be 'locked out' out from development. Minimum separations between villages should exist, preventing gaps being reduced below 1/2 mile.","Yes","","By limiting the amount of development and having strong environmental standards. These standards should prioritize quality over cost. Developers should bear a greater and longer term responsibility for flood damage and impact on the environment","All new building (residential, offices and public) should have Solar panels as a mandatory requirement. Where possible other measures including ground source heating should be considered.","Reuse of existing buildings and use of 'brownfield' sites for development should be prioritized before any building on green field sites is permitted.","Yes","Yes","The fields between villages like Bishops Cleeve, Stoke Orchard, Gotherington and Woolstone.","Consideration should be given to expanding health services. NHS dentists and Cottage Hospitals should be part of the plans.","Yes","Wind turbines should be considered.","No","No, the local residents should determine the appropriate amount and type of housing. This should be within the rules preventing coalescence and should have a final number beyond which 'ALL' development stops.","Yes","In summary, the roads are too busy and no more should be added. Access to basic health care is too poor (Cheltenham A&E closures) lack of Cottage Hospitals, poor care in the community...","Yes","Small local resident lead, warden assisted bungalows are required. 4 & 5 bedroom houses should not be built in preference for smaller houses.","No","Travellers should be catered for in existing locations.","","Priority should be given to small businesses. There is a need for open office flexible hot desking where small companies can book a desk for a day or two  for a modest fee.","Yes, so long as this does not lead to increased housing need.","Yes. We are a rural community, and this must be prioritized over development and housing in the area.","Town centres like Cheltenham should encourage people back in. Free parking before say 09:30, free parking for the first 15 minutes (as seen in other parts of the UK). Better car parks run for residents not companies.","By regulating and driving down taxi fares. This would allow more people to enjoy a night out at a pub, without having to worry about driving or the cost of a taxi","hospitals, NHS dentists","hospitals, NHS dentists","Roads to and from any new site need to be capable of supporting the additional traffic. Local parishes should be able to veto development based upon traffic impact","Yes","No","","No","No, more emphasis needs to be given to controlling and where appropriate stopping development","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt","","","Only to say that the overarching prioritises must be protecting the rural nature of our area. Any commercial programme of work has clear objectives and a defined end state the programme is seeking to deliver. This means there should be a clear end state view for housing in our area. A plan which shows the final state of development beyond which no attentional houses or roads will be built. Failure to include an end state view means we could end up with a valley filled with housing. This would be to loose all fields and natural green spaces. As an exercise, walk the Cotswold escarpment and look into the valley. Cheltenham is growing and villages are sprawling into towns. If we don't control 'and limit' housing this cancer will continue to wreak villages and communities."]
["Planning agent or developer","The Planning Bureau on behalf of McCarthy Stone","","","","","","","","","Whilst Council’s commitment to meeting both its and the UK Government’s target of net zero carbon emissions is commendable together with its desire to include policies that address climate change, it is our view that any requirement should be ‘stepped’ in line with Government targets and the proposed changes to the building regulations.  \n\nThis approach is confirmed within the Ministerial Statement (statement no : Statement UIN HCWS123 available from Written statements - Written questions, answers and statements - UK Parliament)  released on 13th December 2023.  The ministerial statement confirms that with respect to the net zero goal….\n\n‘The improvement in standards already in force, alongside the ones which are due in 2025, demonstrates the Government’s commitment to ensuring new properties have a much lower impact on the environment in the future. In this context, the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale’ and ‘To be sound, local plans must be consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework and other statements of national planning policy, including this one’. \n\nTherefore aligning the Council’s requirement for carbon neutral development with those of Government would therefore be pragmatic, more achievable and consistent with national policy.","See above response.","No","","With respect to BNG percentage:\n\nNo, the Council should not seek more than the mandatory minimum 10% Biodiversity Net Gain than that set out in the Environment Act 2021.  Requiring BNG above 10% does not meet the tests set out in paragraph 57 of the NPPF.  The Council should also note that the recently finalised Planning Policy Guidance on Biodiversity Net Gain at paragraph: 006 Reference ID: 74-006-20240214 confirms that ‘Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented’.  Therefore a minimum of 10% BNG requirement should be maintained in order to ensure that the requirement is ‘fairly and reasonably related in scale and kind to the development’ (para 57, NPPF) and consistent with national policy guidance. \n\nThe Council should also ensure that any policy is consistent with recently published legislation and planning guidance.\n\n","","","","","","","","Yes","Thank you for the opportunity to comment on the Cheltenham, Gloucester and Tewkesbury Strategic Local Plan consultation.  McCarthy Stone is the leading provider of specialist housing for older people. The following comments provides details as to the approach the Council should take towards meeting the specialist housing needs of older people and sets out recommendations for the Council to consider when setting policies to ensure the needs of older people are fully considered within the emerging Local Plan.  \n\nNational Policy Context \n\nGovernment’s policy, as set out in the revised NPPF, is to boost significantly, the supply of housing. Paragraph 60 reads:\n\n“To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed, that the needs of groups with specific housing requirements are addressed and that land with permission is developed without unnecessary delay.”\n\nThe revised NPPF looks at delivering a sufficient supply of homes, Paragraph 63 identifies within this context, the size, and type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies including older people.  This now specifically includes those who require retirement housing, housing-with-care and care homes.\n\nIn June 2019 the PPG was updated to include a section on Housing for Older and Disabled People, recognising the need to provide housing for older people. Paragraph 001 Reference ID: 63-001-20190626 states:\n\n“The need to provide housing for older people is critical. People are living longer lives and the proportion of older people in the population is increasing. In mid-2016 there were 1.6 million people aged 85 and over; by mid-2041 this is projected to double to 3.2 million. Offering older people a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking” (emphasis added).\n\nParagraph 003 Reference ID: 63-003-20190626 recognises that:\n\n“the health and lifestyles of older people will differ greatly, as will their housing needs, which can range from accessible and adaptable general needs housing to specialist housing with high levels of care and support.” \n\nThus, a range of provision needs to be planned for. Paragraph 006 Reference ID: 63-006-20190626 sets out:\n\n“plan-making authorities should set clear policies to address the housing needs of groups with particular needs such as older and disabled people. These policies can set out how the plan-making authority will consider proposals for the different types of housing that these groups are likely to require.”\n\nTherefore, the Local Plan should recognise that housing for older people has its own requirements and cannot be successfully considered against criteria for adaptable and accessible general family housing. \n\nNeed for Housing for Older People\nIt is well documented that the UK has an ageing population. Life expectancy is greater than it used to be and as set out above by 2032 the number of people in the UK aged over 80 is set to increase from 3.2 million to 5 million (ONS mid 2018 population estimates).\n\nIt is generally recognised (for example, within the Homes for Later Living Report September 2019). That there is a need to deliver 30,000 retirement and extra care houses a year in the UK to keep pace with demand. \n\nThe age profile of Cheltenham, Gloucester and Tewkesbury can be drawn from the 2018 population projections from the Office for National Statistics. This advises that there were 64,561 persons aged 65 and over in 2018, accounting for 19% of the total population of the Council area.  This age range is projected to increase by 33,758 individuals, or 52.3%, to 98,319 between 2018 and 2043. The population aged 65 and over is expected to increase to account for 25.4% of the total population of Cheltenham, Gloucester and Tewkesbury by 2043.\n\nIn 2018 there were 18,143 persons aged 80 and over, individuals who are more likely to be frail and in need of long-term assistance. The number of people in this age range is forecasted to increase by 17,422 individuals, or 96.1%, to 35,565 between 2018 and 2043.  The population aged 80 and over is anticipated to represent a higher proportion of Cheltenham, Gloucester and Tewkesbury’s residents, accounting for 5.4 % of the total population in 2018 and increasing to 9.2% by 2043.  \n\nIt is therefore clear there will be a significant increase in older people and the provision of suitable housing and care to meet the needs of this demographic rather than purely just adaptable homes should be a priority of the emerging Local Plan.  \n\nBenefits of Housing for Older People \nOlder Persons’ Housing produces a large number of significant benefits which can help to reduce the demands exerted on Health and Social Services and other care facilities – not only in terms of the fact that many of the residents remain in better health, both physically and mentally, but also doctors, physiotherapists, community nurses, hairdressers and other essential practitioners can all attend to visit several occupiers at once.  This leads to a far more efficient and effective use of public resources.\n\nEconomic\nA report “‘Healthier and Happier’ An analysis of the fiscal and wellbeing benefits of building more homes for later living” by WPI Strategy for Homes for Later Living explored the significant savings that Government and individuals could expect to make if more older people in the UK could access this type of housing. The analysis showed that:\n•\t‘Each person living in a home for later living enjoys a reduced risk of health challenges, contributing to fiscal savings to the NHS and social care services of approximately £3,500 per year.\n•\tBuilding 30,000 more retirement housing dwellings every year for the next 10 years would generate fiscal savings across the NHS and social services of £2.1bn per year.\n•\tOn a selection of national well-being criteria such as happiness and life satisfaction, an average person aged 80 feels as good as someone 10 years younger after moving from mainstream housing to housing specially designed for later living.’\n\nA further report entitled Silver Saviours for the High Street: How new retirement properties create more local economic value and more local jobs than any other type of residential housing (February 2021) found that retirement properties create more local economic value and more local jobs than any other type of residential development. For an average 45 unit retirement scheme, the residents generate £550,000 of spending a year, £347,000 of which is spent on the high street, directly contributing to keeping local shops open. \n\nAs recognised by the PPG, Retirement housing releases under-occupied family housing and plays a very important role in recycling of housing stock in general.  There is a ‘knock-on’ effect in terms of the whole housing chain enabling more effective use of existing housing. In the absence of choice, older people will stay put in properties that are often unsuitable for them until such a time as they need expensive residential care. A further Report “Chain Reaction” The positive impact of specialist retirement housing on the generational divide and first-time buyers (Aug 2020)” reveals that about two in every three retirement properties built, releases a home suitable for a first-time buyer.  A typical Homes for Later Living development which consists of 40 apartments therefore results in at least 27 first time buyer properties being released onto the market. \n\nSocial \nRetirement housing gives rise to many social benefits:\n•\tSpecifically designed housing for older people offers significant opportunities to enable residents to be as independent as possible in a safe and warm environment. Older homes are typically in a poorer state of repair, are often colder, damper, have more risk of fire and fall hazards. They lack in adaptions such as handrails, wider internal doors, stair lifts and walk in showers. Without these simple features everyday tasks can become harder and harder\n•\tRetirement housing helps to reduce anxieties and worries experienced by many older people living in housing which does not best suit their needs by providing safety, security and reducing management and maintenance concerns. \n•\tThe Housing for Later Living Report (2019) shows that on a selection of wellbeing criteria such as happiness and life satisfaction, an average person aged 80 feels as good as someone 10 years younger after moving from mainstream housing into housing specifically designed for later living. \n\nEnvironmental\nThe proposal provides a number of key environmental benefits by:\n•\tMaking more efficient use of land thereby reducing the need to use limited land resources for housing.\n•\tProviding housing in close proximity to services and shops which can be easily accessed on foot thereby reducing the need for travel by means which consume energy and create emissions. \n•\tProviding shared facilities for a large number of residents in a single building which makes more efficient use of material and energy resources.\n\nRecommendations\nThe 2018 population projections from the Office for National Statistics shows a large increase in the population over the age of 65.  For this reason and the requirements of the NPPF and PPG, the Council should ensure specialist housing to meet the needs of older people is addressed and that older person’s housing is not confused with wheelchair accessible housing, Lifetime Homes or other specialised housing.  \n\nIt is common for Local Authorities to conflate the needs of ‘wheelchair users’ with the needs of older people in the community.  The Council are respectfully reminded that ensuring that residents have the ability to stay in their homes for longer is not, in itself, an appropriate manner of meeting the substantial housing needs of older people.  Adaptable houses do not provide the on-site support, care and companionship of specialist older persons’ housing developments nor do they provide the wider community benefits such as releasing under occupied family housing as well as savings to the public purse by reducing the stress of health and social care budgets.  Housing particularly built to M4(3) standard may serve to institutionalise an older persons’ housing scheme reducing independence contrary to the ethos of older persons.  Older people’s housing should be incorporated into the emerging Local Plan as a priority.  \n\nThe best approach towards meeting the diverse housing needs of older people is for the plan to:\n•\tIdentify the older person’s housing need.\n•\tAllocate specific sites to meet the needs of older people that are in the most sustainable locations close to key services.  \n•\tInclude a standalone policy actively supporting the delivery of specialist older people’s housing with good access to services and facilities for older people. \n\nDevelopers of older person’s housing schemes should not be required to demonstrate need given the increasingly elderly population and the many benefits that older persons housing bring and if a quantum is specified this should be regarded as a target and not a ceiling. Given also that such developments “help reduce costs to the social care and health systems” (PPG refers), requirements to assess impact on healthcare services and/or make contributions should be avoided. \n\nWhile we appreciate that no one planning approach will be appropriate for all areas, an example policy is provided that, we hope, will provide a useful reference for the Council: \n\n“The Council will encourage the provision of specialist housing for older people across all tenures in sustainable locations.  \n\nThe Council aims to ensure that older people are able to secure and sustain independence in a home appropriate to their circumstances by providing appropriate housing choice, particularly retirement housing and Extra Care Housing/Housing with Care.  The Council will, through the identification of sites, allowing for windfall developments, and / or granting of planning consents in sustainable locations, provide for the development of retirement accommodation, residential care homes, close care, Extra Care and assisted care housing and Continuing Care Retirement Communities.”  \n\nWe would remind the Council of the increased emphasis on Local Plan viability testing in Paragraph 58 of the NPPF and that the PPG states that “The role for viability assessment is primarily at the plan making stage. Viability assessment should not compromise sustainable development but should be used to ensure that policies are realistic, and that the total cumulative cost of all relevant policies will not undermine deliverability of the plan” (Paragraph: 002 Reference ID: 10-002-20190509).  The evidence underpinning the Council’s planning obligations and building requirements should therefore be robust.  \n\nWe would also like to remind the Council that the viability of specialist housing for older people is more finely balanced than ‘general needs’ housing and we are strongly of the view that these housing typologies should be robustly assessed in any forthcoming Local Plan Viability Assessment.  This would accord with the typology approach detailed in Paragraph: 004 (Reference ID: 10-004-20190509) of the PPG which states that.  A typology approach is a process plan makers can follow to ensure that they are creating realistic, deliverable policies based on the type of sites that are likely to come forward for development over the plan period.  If this is not done, the delivery of much needed specialised housing for older people may be significantly delayed with protracted discussion about other policy areas such as affordable housing policy requirements which are wholly inappropriate when considering such housing need. \n\nThe Council must therefore ensure that an up-to-date viability assessment is undertaken to inform the future plan.  The new viability assessment must include a number of typologies that includes older person’s housing and if older person’s housing is found to be not viable an exemption must be provided within the plan in order to prevent protracted conversations at the application stage over affordable housing provision and delaying the provision of much needed older persons housing.  \n\nWe would direct the Council towards the Retirement Housing Consortium paper entitled ‘A briefing note on viability prepared for Retirement Housing Group by Three Dragons, May 2013 (updated February 2013 (‘RHG Briefing Note’) available from https://retirementhousinggroup.com/rhg/wp-content/uploads/2017/01/CIL-viabiilty-appraisal-issues-RHG-February-2016.pdf.  The RHG Briefing Note establishes how sheltered housing and extra care development differs from mainstream housing and looks at the key variables and assumptions that can affect the viability of specialist housing for older people.  These key variables include unit size, unit numbers and GIA, non-saleable communal space, empty property costs, external build cost, sales values, build costs, marketing costs and sales periods.  \n","","","","","","","","","","","","","","","","","","","",""]
["Resident",null,"","","","","","","","","","","","Yes","Chargrove is all Green Belt land on the southern side Up Hatherley Way, the very road designated to provide the limiting boundary for any urban development.  This SLP should protect and not permit building on Green Belt land.  \nChargrove Lane is unique around Cheltenham, unspoilt by development & traffic on the edge of the already numerous Up Hatherley housing developments. This application, if permitted, would irrevocably destroy a priceless piece of rural countryside together with numerous trees & hedgerows, all home to many species of wildlife.  A large number of these trees are currently protected by a tree preservation order & include a rare surviving traditional Perry orchard that has protected ‘Priority Habitat’ status and is also included on Gloucestershire’s Historic Environment Record.","","","","","","","","","","No","","","","","","","","","","","","","","","","","","",""]
["","Octavia Group Limited","","","","No","New settlements are a high-risk delivery strategy and present many hurdles to the achievement of the local plan.  Existing settlements should be prioritised for growth, utilising existing infrastructure and minimising delays to housing delivery.\n\nAcross the SLP area there is a significant opportunity to sustainably grow a number of Service Villages in order for these to efficiently develop into Rural Service Centres, which in turn increase the sustainability and functionality of their immediate surroundings.  This could avoid the need for multiple new settlements with significant infrastructure burdens and high environmental costs.\n\nAccording to Joint Core Strategy Rural Area Settlement Audit (Sept 2014), Highnam ranks 7th overall, demonstrating it’s clear sustainability and suitability for a focus of growth in the emerging SLP.\n\nWe draw to your attention Land north and south of Newent Road (B4215) (HELAA Ref: HIG010), which Octavia Group Limited promoting for a sustainably located mixed development comprising approximately 1,045 dwellings.  This land is within a single ownership, without constraint to development and is available immediately.  ","","","","","","No","","","","","","Yes","Departure would require clear evidence of exceptional circumstances, which cannot be evidenced for the SLP area. ","","","","","","","","","","","","","","","","","Yes","The Consultation Draft acknowledges a need for a review of the growth of the region and offers a range of scenarios, which in combination aim to achieve sustainable future for the joint area.  It also clearly confirms that concentrating new homes within the urban areas of Gloucester and Cheltenham will not deliver sufficient new homes and jobs.\n\nScenario 3 critiques the merits of Urban Extensions which avoid the Green Belt, however it fails to consider a new pattern of growth derived from widespread remote working arrangements.  This places far less pressure on residents needing to live within a close proximity to traditional economic centres, and provides the opportunity for sustainable growth across a wider area, not just on the fringes of Gloucester, Cheltenham and Tewkesbury.\n\nAcross the SLP area there is a significant opportunity to sustainably grow a number of Service Villages in order for these to efficiently develop into Rural Service Centres, which in turn increase the sustainability and functionality of their immediate surroundings.  This could avoid the need for multiple new settlements with significant infrastructure burdens and high environmental costs.\n\nUnder the existing JSC (ref: Table SP2c: Settlement hierarchy) the area has 2 Rural Service Centres; Bishops Cleeve and Winchcombe, both located in the Northern hemisphere of the JSC area.  There are 12 scattered Service Villages, delivering varying degrees of amenity to the surrounding area.\n\nAccording to Joint Core Strategy Rural Area Settlement Audit (Sept 2014), Highnam ranks 7th overall, demonstrating it’s clear sustainability and suitability for a focus of growth in the emerging SLP.\n\nWe draw to your attention Land north and south of Newent Road (B4215) (HELAA Ref: HIG010), which Octavia Group Limited promoting for a sustainably located mixed development comprising approximately 1,045 dwellings.  This land is within a single ownership, without constraint to development and is available immediately.\n\nPhase 1a and 1b: 95 dwellings and an expansion of Highnam Business Park (ref:21/01392/OUT)\nPhase 2: 100 dwellings to be submitted in Autumn 2024.  \nPhase 3: 250 dwellings, a local centre and playing pitches.   \nPhase 4: Relocation of Rodway Golf Course on to land owned by the landowner a short distance away, freeing up vital development land for a further 600 dwellings, a GP surgery, elderly care facility and ecological enhancements.\n\nWe are currently preparing our phase 2 planning application and would welcome early discussions with the policy team to discuss our wider ambitions. ","","","Scenario 3: Urban extensions, avoiding the Green Belt","","",""]
["Planning agent or developer","Vistry","","","","","","","","","","","","","","","","","","","","","","","Yes","Vistry Group supports the provision of sites for traveller communities in sustainable locations where a local need is identified and the site meets the requirements of the target community. Vistry Group believe that an effective strategy for providing for the Gypsy and Traveller community would be to create purpose built, dedicated sites in sustainable locations close to the key settlements in the SLP area which would allow for easy access to schools, healthcare, shops, and other important services as well as to enable cultural integration in the respective areas. \n\nVistry Group are currently promoting the land north east of Kidnappers Lane in Leckhampton, Cheltenham, for a purpose built provision of permanent pitches, transit pitches, and plots for Travelling Showpeople. \n\nThe site is 8ha of grassland within Cheltenham’s settlement boundary and is sustainably located immediately adjacent to such facilities as a primary school (Leckhampton C of E Primary), 300m away from a new secondary school (The High School, Leckhampton) and is an 11 minute walk (2 minute drive) to a Coop in Leckhampton. For a larger offering, Morrisons Supermarket in Hatherley is a 3 minute drive (25 minute walk). The site is also located close to the proposed ‘Cycle Cheltways’ route along the A46 (Shurdington Road) leading straight into the centre of town. \n\nParagraph 4.25 in the ‘Gloucestershire Gypsy, Traveller and Travelling Show people Accommodation Assessment’ (GTAA, November 2022) identifies that it is best to locate transit pitches close to the M5 motorway. Vistry’s proposal to the north east of Kidnappers Lane is located a short and straightforward 8 minute drive from junction 11A on the M5 (approximately 4.6 miles), a route that would be suitable for associated Gypsy, Traveller and Showperson movements. \n\nAs the GTAA (2022) identifies, land prices are very high in the SLP area and as such, many sites which would be appropriate for Gypsy and Traveller sites are instead promoted for conventional housing (para 4.8). Furthermore, feedback from stakeholders reveals that often landowners are reluctant to sell land to the Travelling community (para 4.6). Vistry Group’s proposed site in Leckhampton would provide land for Gypsy/Traveller/Travelling Showpeople in an area of growth within Cheltenham’s settlement boundary, and which would otherwise remain unused. \n\nThe land lies outside of the greenbelt and within Cheltenham’s settlement boundary, with strong pedestrian, cycle, and vehicular links to the facilities and services in the surrounding area and the town centre, as well as benefiting from excellent links to the M5 motorway (8 minute drive).\n\nThe land north east of Kidnappers Lane is solely owned by Vistry Group and is readily available to assist in the identified shortfall in Gypsy and Traveller sites in the SLP area.","The GTAA provides guidance regarding preferred characteristics and locations for traveller sites. \n\nParagraph 8.5 indicates that smaller sites are preferred as they allow for better ongoing management and security. New provision should be in a ‘safe environment’ (8.6). \n\nThe assessment criteria in paragraph 8.7 gives a good general understanding of the key elements to a good site. Vistry Group have provided a response to each of these criteria below for the land north east of Kidnappers Lane, Cheltenham, which Vistry are promoting for Gypsy and Traveller pitches (both permanent and transit) as well as plots for Travelling Showpeople. \n\nCosts\n\n• How do land costs impact on feasibility i.e. is it affordable? Land costs are high, however Vistry Group are open to working closely with the Travelling Community to bring forward the site for provision and negotiating occupation arrangements, be it through land sale or rent. \n\n• Implementation of services – is it possible for the new site to connect to nearby mains services e.g. electricity, gas, water or sewerage? Yes. Services are readily available in the area and can be installed where required. As one of the largest house builders in the country, Vistry Group are experienced in coordinating the servicing of land. \n\n• Can good drainage be ensured on the new provision? Yes. A suitable Flood Risk, Drainage and Foul Water Strategy will be implemented on site.  \n\nSocial\n\n• Does the proposed location of the new provision lie within a reasonable distance of school catchment areas? Yes. Leckhampton C of E Primary School is located immediately adjacent to the site, and the High School Leckhampton is 300m away as the crow flies (approx. a 9 minute walk or 1 minute drive). \n\n• Sustainability – is the proposed location close to existing bus routes? Yes. There are regular bus services running along the A46 between Gloucester and Cheltenham (number 10 bus), the nearest stop is 12 minutes walk away from the site. Alternatively there are existing bus stops along the Leckhampton Road (13 minute walk from the proposed site) and bus services also run straight into Cheltenham town centre. \n\n• Proximity of social and leisure services – is the proposed location close to leisure facilities such as sports centres, cinemas etc. or welfare services such as health and social services etc? The site is approximately 1 mile from the nearest doctors surgery (Leckhampton Surgery). There are existing playgrounds in the nearby Redrow Development along Farm Lane/Leckhampton Lane, as well as a BMX ‘pump track’ adjacent to the site. The majority of other social and leisure services are located in the town centre which is a short bus service away, or around a 39 minute walk (1.8 miles). \n\nAvailability\n\n• Who owns the land and are they willing to sell / rent? The land is solely owned by Vistry Group who are promoting the land for Gypsy, Traveller and Showperson pitches and plots.  \n\n• Is access easy or will easements across other land be needed both for residents and services/utilities? Easy access from Kidnappers Lane for residents, services and utilities. \n\n• Are utilities close enough to service the provision at realistic prices? Yes. \n\nDeliverability\n\n• Does the proposed location meet existing general planning policy in terms of residential use, (for example in relation to Green Belt, flooding and the historic environment)? The site is currently identified as Local Green Space in the Cheltenham Borough Local Plan (July 2020). \n\n• Can the owner sell the land easily and quickly? The land is owned by Vistry Group and is readily available\n\n• Can utilities connect to the proposed provision? Yes\n\n• Can highways connect to the proposed provision? Yes","","","","","","","","","","","","","","","","","Vistry Group propose their land located north east of Kidnappers Lane, Leckhampton, Cheltenham, to be considered for Gypsy, Traveller and Travelling Showperson site allocations. This can be in the form of permanent pitches, transit pitches, plots, and yards."]
["Local Councillor","Local Councillor",15,"no","Protection of green belt","","","","","","cat 6 housing mandatory solar panels and air source heat pumps","As close to above subject to any limitations ie Listed buildings","Yes","","","Dr and dentists local primary schools","Yes","battery storage of renewable energy for night use","No","","","","Yes","lower density estates with larger plot sizes Small scale social housing estates. larger minimum space standards","","","semi rural due to likely employments and livestock but  close to amenities and services","","located close to main highways and populations","subsidized or fixed shared ownership and some social housing","scale down the centres and invest in coverred and good accessed shops and entertainment centres","shared community ownerships ","Schools Doctors local shops [subject to limits as above] transport  by foot and pubic services","as abouve","","Yes","","","Yes","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","","",""]
["Resident",null,3,"","Planning","No","","No","","Lead by example and provide incentives for residents/businesses","Meet minimum carbon reduction standards","Use more brownfield sites","Yes","Yes","Golden Hay Field, Dumbleton","Recreational facilities","Yes","Solar and wind ","Yes","","No","","No","","No","","","Local jobs in local businesses for local residents ","","","Better range of shops","Multi purpose shops, cafes etc in one place","","","","Yes","No","","Yes","","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 2: Urban extensions; Scenario 1: Urban concentration","No","",""]
["Resident",null,"","No","","Yes","","Yes","","Electric vehicles in town centre only, autonomous electric transport for people and goods to operate in town centres, connecting towns to each other and a transport hub located outside the towns where good may be delivered to and from.","Carbon emissions to build and operate - carbon cost","Carbon emissions to maintain and operate - carbon cost\nCultural value","Yes","Yes","Combe hill nature reserve","Autonomous electric transport for people and goods.  Operating out of a main transport hub where goods and people  arrive from outside the local area and are then distributed by electric or hydrogen powered transport autonomously to their destinations.  Transport can be requested from anywhere by smartphone and an autonomous vehicle will arrive to transport goods and/ or people safely securely, efficiently and environmentally friendly to their destination, or to the transport hub for destinations outside the local area.\n\nSmaller local hubs within urban centres.","Yes","Wind power, solar power, tidal power - Severn esturary","Yes","","","","Yes","Communal housing for low wage and homeless","Yes","","","Reduce business rates for town centres","Attract tech companies by incentivising them to set up in the local area","Good  electric or hydrogen powered transport for goods and people to connect rural areas to urban centres and transport hubs.","Reduce business rates for town centre businesses so they can compete more fairly with out of town businesses","Autonomous  electric or hydrogen powered transport available to all to transport goods or people at any time, connecting rural areas together and with urban centres and transport hubs","Transport hubs, autonomous electric and hydrogen powered vehicles, energy sources for the same.","Transport hubs, autonomous electric and hydrogen powered vehicles, energy sources for the same.","Flood risk, risk of increasing flood risk, current services and infrastructure, environment","Yes","Yes","Transport hubs, autonomous electric and hydrogen powered vehicles, energy sources for the same.","Yes","","Scenario 6: Sustainable transport scenario","","","The strategic plan could be  a blue print for other areas - if we do something radical and progressive like: \nTransport hubs, autonomous electric and hydrogen powered vehicles, energy sources for the same for transport of people and goods"]
["","","","","","","","","","To look at possible flooding. To stop soil erroison, need trees/woods/hedges.","","There are lots of places in town, factories, office blocks no longer used that could be converted to housing. This would bring regeneration in the towns. However Gloucester needs a good food shop where Sainsbury's used to be in town, not everyone drives so struggle to access the out of town Supermarkets. Towns are cluttered with cars, need a railway station in Churchdown.","","","","GP's, schools, dentist, trains, busses,","Yes","Solar, wind, Hydro (water). ","","","Yes","Not all these new houses are being sold.","Yes","Housing for single people, bungalows which are appropriate for people who are in wheelchairs, affordable housing.","","","","Reduce business rates so shops can continue to afford to stay in the towns. ","","","Reduce business rates, since Debenhams closed Glos has lack of decent clothing shops in the City, not everyone wants to go to the keys to look at clothes.  Worcester and Hereford both have excellent shops in the City.","Important to keep the little corner shops, not to be drowned out by Tescos and Aldi etc.","Schools, parks, GP/dentist good bus/train links.","Senior schools, school busses that are affordable for parents to help reduce the congestion of areas. Churchdown has two comprehensive and three infant/junior (inclusive of the Catholic school) around school time it's chaos with school traffic and they park over the pavements making it unsafe for pedestrians and the school children. \n","","","","","Yes","","Scenario 3: Urban extensions, avoiding the Green Belt","","","We need more parks.  More allotments required. Burial grounds are getting full to capacity - need more with easy accessibility.  "]
[null,null,"","","","","","","","Measures should be taken to mitigate the impact on the local flora and fauna e.g. reintroduction of plants to help insects and tree/hedge planting to help birds and small mammals","Houses and infrastructure should be constructed in line with the Government advice on 'Heat and Buildings Strategy' 'Net Zero Strategy Build Back Greener', etc.","Where possible, any regeneration of buildings should be sympathetic to the historical use of that building so that local character is retained","Yes","No","","Schools, Doctors Surgeries, community recreation buildings and outside areas; car share","Yes","More use of solar panels on housing; wind turbines","","","","","","","","","","","","","","","The Mass Rapid Transport Plan should be considered","In Options 4 and 5 the increase in settlements in the Highnam area would require a new bridge between Highnam Roundabout and Cole Avenue, say.  \nWhen A417 closed due to flooding at Maisemore, Corsend Road, B4215 and A40 already over capacity with existing housing.\nBy adding a new bridge this would remove southbound traffic towards Bristol away from Castlemeads Way. As the next available river crossing is the Severn Bridge.\n\nAs for increases in scattered villages the infrastructure is already over capacity.","All utility infrastructure would need to be greatly enhanced.  Community services such as Doctors surgery and community recreational facilities added.","Yes","","","","","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario; Scenario 3: Urban extensions, avoiding the Green Belt","","",""]
[null,null,"","","","","","","","Not building on areas prone to flooding.  And conduct thorough surveys, maybe through using advanced technology such as AI, to identify areas that may flood in the future, in order to avoid building in those areas.","","Make it easier to develop listed buildings","","","","","Yes","I'm no expert, but investigating whether tidal power from the River Severn could be harnessed somewhere might be helpful","","","Yes","The infrastructure has not been developed to support the housing that has been built to date.  Schools are oversubscribed, doctors' surgeries are full, with long waits for routine appointments, the roads are continuously being damaged due to volume of traffic, and traffic is appalling.  The infrastructure needs to catch up with the number of homes we have in 2024, before we start to build more homes. ","","","No","","Small, legitimate sites which have appropriate planning permissions in place, and where Council Tax is levied and enforced","","","","Reduce business rates and rents for local businesses, offer 'green' incentives.","","Transport, health, education, power, telecommunications","Transport, health, education, power, telecommunications","","","Yes","Tewkesbury has already seen an increase in population of 15.8% (Census 2021 compared with 2011), the highest increase in the south west, and way above the overall increase for England (6.6%).  This is also an area prone to serious flooding.  Serious consideration should be given to ANY further development in this area, where the infrastructure (schools, roads, health) is being stretched.","No","Across all options, the fact that infrastructure is already under pressure due to it not having kept up with housing development,  has been woefully underplayed.","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 5: Rural dispersal","","","Bishops Cleeve has seen a completely unsustainable growth in housing development over the last ten years.  The infrastructure simply has not been delivered - to date - to keep up with the rise in demand.  Additionally, housing and retail developments near M5 J9 have created traffic and travel misery in that area.  Infrastructure needs to catch up with existing development, before ANY further development is planned and approved.  Additionally, the rise in second home ownership is pricing locals out of the housing market in some areas: second home owners should be charged a premium: maybe through a local stamp duty or extra council tax, which in turn could be invested in local housing supply.  "]
["Resident",null,"","","","","","","","Good environmental design such as tree planting to provide shade or SUDS to capture runoff, which complements an urban/residential development. Consider incorporating local renewable energy generation.","More energy efficient buildings and consider a municipal hot water systems or heat transfer systems with river/canals or ground.","Special grants to improve the appearance of facades for improved amenity value and or energy efficient improvements.","Yes","","","","","","","","","","","","","","","Continue to enable infrastructure improvements to Staverton airport and regeneration of Gloucester Docks as this provides a good catalyst for wider growth.","","","Limit new out of town retail space and ensure town centres are economically more desirable with good transport links.","Developers to contribute financially with promotion and enhancement of existing amenities or services which encourage people to stay local.","Wide mixed use footpaths with linear green open spaces which can provide amenity value and cycle routes.  Local mixed use developments to minimise travel time to work.","Simple and efficient central road layout with wide interconnect green open spaces and footpaths. Upgraded regular public transport network with a continuation of the flat or reduced fee ticketing to encourage greater use.","","Yes","","","","","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 5: Rural dispersal","","","The greenbelt between Gloucester and around Cheltenham was created to prevent urban sprawl and maintain the natural environment, which therefore should be protected from all development with the highest priority. The land near to the Cotswold AONB should be promoted with environmental enhancements to offset the recent loss of greenbelt and climate change, so future generations can enjoy the green open environment that separates the two distinctive urban areas."]
["","Swifts Local Network: Swifts & Planning Group","","","","","","","","","In summary, please add to the policy, clearly separate from the BNG requirement:\nSwift bricks to be installed in new developments including extensions, in accordance with best practice guidance such as BS 42021 or CIEEM which require at least one swift brick per home on average for each development. Artificial nest cups for house martins may be proposed instead of swift bricks where an ecologist specifically recommends it.\n\nIn more detail, the reason for this is that bird boxes/ bricks and other species features are excluded from the national DEFRA Biodiversity Net Gain (BNG) metric, so require their own clear policy. The Government's response in March 2023 to the 2022 BNG consultation stated that: \"We plan to keep species features, like bat and bird boxes, outside the scope of the biodiversity metric... [and] allow local planning authorities to consider what conditions in relation to those features may be appropriate\" (page 27, https://consult.defra.gov.uk/defra-net-gain-consultation-team/technicalconsultation_biodiversitymetric/). \n\nSwift bricks are the only type of bird box specifically mentioned as valuable to wildlife in national planning guidance, along with bat boxes and hedgehog highways (NPPG Natural Environment 2019 paragraph 023). \n\nThe National Model Design Code Part 2 Guidance Notes (2021) also recommends bird bricks (Integrating Habitats section on page 25, and Creating Habitats section on page 26).\n\nSwift bricks are considered a universal nest brick suitable for a wide range of small bird species including swifts, house sparrows and starlings (e.g. see NHBC Foundation: Biodiversity in New Housing Developments (April 2021) Section 8.1 Nest sites for birds, page 42: https://www.nhbcfoundation.org/wp-content/uploads/2021/05/S067-NF89-Biodiversity-in-new-housing-developments_FINAL.pdf ).\n\nSwift bricks are significantly more beneficial than external bird boxes as they are a permanent feature of the building, have zero maintenance requirements, are aesthetically integrated with the design of the building, and have improved thermal regulation with future climate change in mind. Therefore, swift bricks should be included in all developments following best-practice guidance (which is available in BS 42021:2022 and from CIEEM (https://cieem.net/resource/the-swift-a-bird-you-need-to-help/)).\n\nThe UK Green Building Council (UKGBC) is a membership-led industry network and they have produced a document entitled: \"The Nature Recovery & Climate Resilience Playbook\" (Version 1.0, November 2022) https://ukgbc.org/resources/the-nature-recovery-and-climate-resilience-playbook/ This document is designed to empower local authorities and planning officers to enhance climate resilience and better protect nature across their local area, and includes a recommendation (page 77) which reflects guidance throughout this document: \"Recommendation: Local planning Authorities should introduce standard planning conditions and policies to deliver low cost/no regret biodiversity enhancement measures in new development as appropriate, such as bee bricks, swift boxes [and bricks] and hedgehog highways.\" \n\nMany other Local Authorities are including detailed swift brick requirements in their Local Plan, such as Cotswold District Council which is proposing three swift bricks per dwelling in their current Local Plan consultation (Policy EN8 item 6, and paragraph 0.8.4, https://www.cotswold.gov.uk/planning-and-building/planning-policy/local-plan-update-and-supporting-information/ ), Tower Hamlets Local Plan Regulation 18 stage (paragraph 19.70, page 311 - https://talk.towerhamlets.gov.uk/17424/widgets/82097/documents/50138 ), which follows the exemplary swift brick guidance implemented by Brighton & Hove since 2020,\n\nand Wiltshire Local Plan Regulation 19 stage, which requires an enhanced number of two swift bricks per dwelling (policy 88: Biodiversity in the built environment, page 246 - \"As a minimum, the following are required within new proposals: 1. integrate integral bird nest bricks (e.g., swift bricks) at a minimum of two per dwelling;\" https://www.wiltshire.gov.uk/article/8048/Current-consultation-Reg-19 ), and  so such an enhanced level should also be considered.\n\nAlso, please add: Existing nest sites for building-dependent species such as swifts and house martins should be protected, as these endangered red-listed species which are present but declining in Gloucestershire return annually to traditional nest sites. Mitigation should be provided if these nest sites cannot be protected.","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","",""]
["Local Councillor","Toddington Parish Council",20,"","","Yes","","Yes","","","","","Yes","","","Doctors and schools","No","","Yes","","No","","No","","No","","Travellers by definition do not wish to join in with a community and be part of an existing village so they do not require to be near residential communities","","","","","","Medical facilities and schools","Better roads, more medcial facilities","The saftey of the road, speed limits and footpaths","Yes","No","","Yes","","Scenario 2: Urban extensions","No","","Healthy, accessible and walkable neighbourhoods promoting active travel and sustainable travel with transport systems that work for local people” identifies Toddington as unsuitable for development. “Climate change - growth takes place in sustainable locations minimising travel needs and promoting active travel.”  Every new house built would increase the number of vehicles on the road by at least two for each house.  Almost everyone would have to use a vehicle to get to work.  Only residents employed at the pub, shop or nursery could walk or cycle to work in the daylight and doing so at night time would be unsafe in our “dark “ village with narrow or no footpaths.  \nThe already overloaded ancient wastewater system could not accommodate any more users. \n"]
[null,null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","With reference to TBC HELAA MAP, specifically to SOU006, 007 and 008, I do not agree that these sites should be categorized as ‘potentially developable’.\n\nThe land is visible from far and wide and forms part of the spectacular and stunning views from both Cleeve Hill and the racecourse.  It is impossible to ignore the breathtaking backdrop to the races on the TV and this would be spoilt immeasurably if houses were built on it.\n\nOur villages are what makes our countryside quintessentially English and these are defined by their separation.  To build on these areas of land would blur the boundaries and merge villages thereby destroying their individual identities.\n\nThe sites are either situated in Green Belt or designated Special Landscape Area (SLA) and adjoin AONB. \n\nThe drainage from the fields prevents flooding which has started to increase in recent years in Southam.\n\nSoutham has neither the infrastructure nor road network to support the increased traffic from a housing development.  The housing would detrimentally impact the noise and air pollution in the area.\n"]
["Resident",null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","The area known as Chargrove between Chargrove Lane and Greatfield Way is green belt and should be protected as such to prevent the merging of Gloucester and Cheltenham.  It is valuable agricultural land permanently farmed with cattle, sheep and arable crops.  It is crisscrossed with public footpaths which are regularly used by the public to enhance their welfare and enjoy exercise.  Indeed, one path leads directly from Shurdington to Up Hatherley where Morrisons Supermarket is thereby avoiding walking along the main A46 Shurdington Road.  This path is part of the Cheltenham Circular Path used annually by athletes and was also used by church goers from Warden Hill to\nShurdington Church.   The other paths attract walkers from near and far,\nsome parking their cars in the lane, whilst walking their dogs or just enjoying the natural environment.  The lane acts as a circular route for walkers, runners and cyclists on the \"\"Chargrove Triangle\"\" enjoying nature which includes deer, buzzards, swallows, bats, woodpeckers, yellow hammers, redwings and fieldfares. The cricket field and a grade listed farm house add to this area needing to be protected as do the orchards and dew ponds.\nChargrove Lane could not withstand any development of any sort and the main A46 Shurdington Road is at a standstill during morning and evening (rush ?) hours so can't take any more traffic and has caused several accidents including deaths in recent years.\nProtecting this valuable area will go towards addressing the serious climate change challenges that we all have."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","",""]
["I work for a charity or volunteer in the area","Sustrans",15,"I agree with the policy topics mentioned by the National Planning Policy Framework, but Infrastructure specifically on sustainable transport should be a central policy topic. The issues and options SLP consultation document makes up for this later on .","Policy topics unique to council areas, neighbourhoods and communities include the planning permission or allocation of new housing, infrastructure and facilities","Yes","I agree with the draft vision, but the paragraph ‘Growth in sustainable locations will have enabled…’ could also mention that active travel in turn helps to help to identify and create suitable locations of local growth. This could help to centre sustainable transport from a conceptual perspective within the SLP.","Yes","","The SLP can most effectively address the impacts of climate change through highlighting to any developer or construction project what needs to be built to ensure sustainable growth in the SLP area. For example the construction of new housing should always be accompanied by the provision of LTN 1/20 cycling infrastructure, helping to address the issues of car dependency and therefore emissions and climate change from the area.","","","Yes","Yes","Former British Car Auctions site in Tewkesbury, as this is an unoccupied brownfield site near to Carrant brook that is prone to flooding.","Shops, healthcare, public transport, walking and cycling provisions, community centres.","Yes","More sites like this: https://www.gloucestershirelive.co.uk/news/regional-news/maisemore-solar-farm-gets-green-8228593 as they can also facilitate active travel corridors.","","","","","","","","","","This is a planning area outside of our Sustrans remit, but the SLP should consider any economic regeneration that can be tied to growing sustainability industries and sustainable transport.","This is a planning area outside of our Sustrans remit, but the SLP should consider any employment needs that can be tied to growing sustainability industries and sustainable transport.","This is a planning area outside of our Sustrans remit, but the SLP should consider how sustainable transport can connect rural communities to ensure connectivity to employment areas.","This is a planning area outside of our Sustrans remit, but the SLP should consider how sustainable transport encourages investment within city and town centres.","This is a planning area outside of our Sustrans remit, but the SLP should consider how sustainable transport better connects villages to amenities.","Walking and cycling infrastructure which promotes active travel. The trend of constructing new housing development, which can only be reached by motor vehicles, is exacerbating car dependency, especially when unconnected shared use paths or painted cycle lanes (when the on road conditions are far too busy) are the only provision construction provided.","LTN 1/20 compliant cycling infrastructure, and walking infrastructure that is compliant with Manual for Streets, or even better Healthy Streets guidance.","Whether that settlement could be connected by public transport, along with walking and cycling infrastructure, plus new shops and community facilities can be built as sensitively as possible to that area’s rural location.","Yes","Yes","Although this is a conceptual point, consider that sustainable transport should not be a separate development scenario and should be an inherent part of all the scenarios.","Yes","","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","","","Mention the National Cycle Network as an important local asset for walking and cycling infrastructure. The NCN contributes towards the UK Government aims to enable active travel, to reduce air pollution, to level up health inequalities, and to ensure people live within 15 minutes’ walk of nature."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Really hard to have faith in any planning strategy. Here in Twigworth, Gloucs both the JCS and local planning groups were overridden by the Sec of state in order to build 750 homes (on clay fields). On the back of this has come a proliferation of smaller developments along the A38. Changing completely the nature of Twigworth Parish. \n\nOnce again Tewkesbury Council recently denied planning for 80+ houses on a field that floods on the river side (flood zone) off the A38. Overridden once again by the Secretary of State! Is there really any point in consultation?\n\nThe money and influence of big builders is part of the picture. Moving the goalposts when needed by politicians also has an effect. The field that has just been given up for the 80+ house was agriculturally useful but under the 20 hectares required to preserve it. Great loophole for builders to find smaller fields and fill them with crammed housing.\n\nUnfortunately I like many others are voiceless. Without the money to engage barristers to challenge decisions we will remain voiceless. Money, not local considerations, run planning and if you deny this then you are lying to yourself."]
["Planning agent or developer","Morgan Elliot Planning","","","","Yes","","Yes","","\"A key component of this is delivering development in sustainable locations that are not solely reliant on the private vehicle, referenced as objective 1 within the Sustainable Transport Strategy: Broad Site Assessment Report (published December 2023). This has been carried through to the Council’s proposed development strategy, looking at six different development scenarios. In particular, the Sustainability Appraisal (SA) identifies Scenario 6 (Sustainable Transport) as the most sustainable development scenario based on accessibility and its purpose to deliver growth along sustainable transport routes. It also performs relatively well in terms of accessibility to social infrastructure such as schools and employment opportunities. Further below this representation details the support for development Scenario 6 which looks to deliver growth along sustainable transport routes. Referring back to question 6, when looking at development opportunities, the Strategic and Local Plan should look at existing development sites and support their ability to expand to help deliver future growth needs. Not only does this relate to the expansion of existing, similar uses on site but also the services and facilities that could be delivered on site that further sustains those uses. This aligns with the NPPF’s reference to making the most efficient use of land and having regard to the criteria set out at Paragraph 128 of the NPPF. It also supports Paragraph 124 a) which requires planning policies and decisions to encourage multiple benefits from both urban and rural land, including through mixed use schemes. Finally, we support the principles of Paragraph 160 of the NPPF which should be reflected in the emerging Strategic and Local Plan as it progresses: “To help increase the use and supply of renewable and low carbon energy and heat, plans should: a) Provide a positive strategy for energy from these sources, that maximises the potential for suitable development, and their future re-powering and life extension, while ensuring that adverse impacts are addressed appropriately (including cumulative landscape and visual impacts); b) consider identifying suitable areas for renewable and low carbon energy sources, and supporting infrastructure, where this would help secure their development; and c) identify opportunities for development to draw its energy supply from decentralised, renewable or low \ncarbon energy supply systems and for co-locating potential heat customers and suppliers.”\"","","","","","","","","","","","","","","","","","","A review of the consultation document, the SA and the Gloucestershire Economic Needs Assessment (GENA) (prepared in August 2020) has been undertaken, albeit it is recognised the GENA is out of date given that it was undertaken at a time when the pandemic was ongoing along with concerns over Brexit. It is noted that as the emerging Strategic and Local Plan continues, the economic needs assessment will be reviewed and updated. Notwithstanding this, the consultation highlights that Tewkesbury Borough over the period between 2021 and 2041 will require 23 ha of land to deliver Class B1a/b (now Class E use) and 75.5 ha of land to deliver Class B1c/B2 and B8 uses (Class B1c now falls within Class E use). These should be seen as minimum figures and updated accordingly in line with the review of the GENA. The economic and regenerations needs in which the emerging Strategic and Local Plan should look to address should be focused where existing employment sites exist, looking to expand their offering within what will already be sustainable locations for development with supporting infrastructure. Consideration should be given to the existing employment allocations as identified in Policy EMP1 of the Tewkesbury Local Plan, which includes my client’s site ‘Ashville Business Park’. As per paragraph 4.6 of the Local Plan “The major employment sites present some of the largest and most important employment areas in the borough.” It goes onto state that “The primary purpose of identifying these sites is to encourage traditional forms of employment development for which there is a great demand for land, and in order to help deliver a minimum of 192ha of B-class employment land across the JCS area in accordance with policies SP1 and SP2 of the JCS.” As part of extending these existing employment sites, Councils should also look to support an offering of different uses on site to ensure that the employment generating uses are being served adequately by everyday services and facilities, such as cafes, day nurseries and shops. This will enable employment sites to flourish and encourage employees to work from their workplace whilst retaining flexibility around a ‘work/life balance’. Indeed, the trend since the pandemic has been that there is preference by many organisations to enable hybrid working. COVID-19 has forced us into a different way of living and working according to an Office of National Statistics1 expressing that, after government guidance to work from home was lifted, the proportion of workers hybrid working had risen from 13% in early February 2022 to 24% in May 2022. Allowing existing business parks to expand to meet the identified employment land needs whilst delivering a mix of uses that would support the ‘work/life balance’ will enable the emerging Strategic and Local Plan to provide an attraxtive environment for workplaces.","Allowing existing business parks to expand to meet the identified employment land needs whilst delivering a mix of uses that would support the ‘work/life balance’ will enable the emerging Strategic and Local Plan to provide an attractive environment for workplaces. In addition, the emerging Strategic and Local Plan should look to direct additional employment land in areas that are well served by public transport, sustainable modes of transport and existing transport infrastructure. As mentioned above, my client supports proposed development Scenario 6 which looks to direct development along sustainable transport routes. It is considered that employment land that is well connected to public transport routes and other sustainable modes of transport, as well as local road networks, adds to the social benefits for delivering employment uses, ensuring such locations are easily accessible and inclusive for all employees within the workplace. Indeed, the SA considers Scenario 6 as one of the top performers for delivering economic growth, which we agree with. Ultimately, as per Paragraph 85 of the NPPF, the emerging Strategic and Local plan “should help create the \nconditions in which businesses can invest, expand and adapt.”","","","","","","","","Yes","Consideration should also be given to developing existing development sites that sit outside the defined boundaries of the three main settlements (Gloucester, Tewkesbury and Cheltenham). Whilst it is understood that the Rural Disperal strategy (Scenario 5) goes some way to accommodate growth outside these key settlements, none of the proposed development scenarios specifically reference the redevelopment of previously developed land that sits outside the three main settlements and which may in planning policy terms sit within the open countryside. Moving forward, the emerging Strategic and Local Plan should favour brownfield sites that can be expanded within the open countryside to meet the future development needs. Particularly in light of the Government’s recent announcement on 13th February 2024 which looks to concentrate development on brownfield sites and maximise density on existing development sites.","No","We support the pros listed in support of Scenario 6 and take note of the cons. The only addition we would like to add to the pros is to emphasis the ability to be in close proximity to schools. As identified in the SA this development scenario scored highly under SA Objective 13 (education).","Scenario 6: Sustainable transport scenario","","","This representation supports Scenario 6 ‘Sustainable Transport’. However, this representation does not consider that this solely should be the preferred development strategy, rather the preferred development strategy should include Scenario 6 as well as other scenarios. It is requested that Scenario 6 is carried forward as part of the preferred development strategy as the emerging Strategic and Local Plan progresses. Clearly, by the pros identified within the consultation document and its rating within the SA, it is a development strategy that would ensure developments are sited within sustainable locations in accessibility terms and would also help address the climate change agenda, reducing the rate of carbon emissions. Indeed, it is known nationally that the use of the private vehicle is the primary influencer of the rate of carbon emissions in the UK, equating to 26% of all carbon emissions. Not carrying forward Scenario 6 in its entirety would undermine the Council’s climate change agenda and conflict with Paragraphs 109, 157, 162 and 163 of the NPPF."]
["Resident","",10,"","Cheltenham has no more building land available without extending into Tewkesbury BC and therefore should not be extending outwards.  Cheltenham is not doing enough about using or reusing land (eg former coach station)/empty shops/offices within its own boundaries.","No","","No","","Sustainable affordable public transport.","","","Yes","Yes","Badgeworth village, Chargrove \"triangle\", Shurdington - one of the only large village areas still bounded by the greenbelt, retaining and protecting the remaining 2 greenbelt fields of Brizen Farm, being the last 2 fields before you get to the new Leckhampton housing estate, Whites Farm at Churchdown.","Schools, libraries, GP, affordable public transport, parks, public footpaths, green space.","Yes","","","","","","","","","","","","","By not building on the farm land surrounding villages?","","Council facilities such as libraries, NHS facilities, eg GP Surgeries, and village schools must be funded, not just in the short term, but for years to come, by the developers who are making so much money from these developments.  Providing a building for such facilities is just the beginning – they need to be staffed, maintained and supplied in the long term.  Large supermarkets should no longer be the usual retail model, but smaller units for use by local businesses should be provided at low rent.  Existing businesses should be provided funds to renovate and update their services.","The massive developments in Leckhampton have included no GP Surgeries, no extra libraries, no community halls or places of worship, no community shops or parks, no pubs or cafés, mirroring the huge developments in Bishops Cleeve on TBC land but attached to the north of Cheltenham.  This creates dormitory suburbs, which are empty during the day and leading to a lack of community – people drive to places of entertainment, because there is no facility within their artificially created housing development.","See above","","","Yes","Use of cleaned up industrial sites, utilising unused or underused offices, shops and other existing buildings must be considered before any further rural developments.  We are destroying our own county and its environment.","No","There should be no rural village spread, no building in the greenbelt and definitely no changes to the greenbelt boundary, with the greenbelt in this area already being one of the smallest in England.","","","","\"Poor advertising of, and thus poor attendance at, consultation events has ensured that many people are unaware of what is in the pipeline. The confusing website and documents makes it difficult to link proposals to questions. The questions are worded in a manner which assumes that we agree with these things happening at all, especially so soon after the previous JCS. I object most strongly to the amalgamation of Gloucester/Cheltenham into one large conurbation, piecemeal housing developments with no infrastructure and the destruction of the rural nature of our county.  Additionally I would like to make the following points:  \n•\tThe Chargrove ‘valued landscape’ (and Green Belt) should be exempted from development and protected for rural recreation and its long views to the Escarpment.\n•\tThe JCS has resulted in major erosion to our small green belt, which was designed to prevent a merger of the Gloucester/Churchdown/Brockworth conurbation with Cheltenham.  No further greenbelt losses can be sustained, particularly in this small countryside gap towards Shurdington. \n•\tThis consultation’s Evidence documents are incomplete and out-of-date.\n•\tThere are no housing ‘target’ figures for the additional plan period (2031 to 2041), that is to say. beyond the JCS provision. \n•\tThe Transport evidence pertains only to buses, cycling and walking, but lacks any contribution from County Council Highways towards specifying the road infrastructure needed for tens of thousands of houses.  \n•\tCheltenham can no longer expand outwards, into its surrounding AONB and Green Belt. Therefore, the only sustainable expansion options are:\n\tRestraint on numbers - Cheltenham has survived the enforced Restraint of its permitted NorthWest and West urban extensions not having delivered to date, due to County Council Highways’ failure to specify road infrastructure at the JCS Examination.  \nOR \n\tNew satellite settlements, either north-west of Stoke Road (Bishops Cleeve), or in non-coalescing Green Belt at Boddington, which would be a quasi-extension of the JCS-permitted ‘Cheltenham West’ urban extension.\""]
["Resident",null,"","Although given a mention in passing , I believe that the areas of Health and Security/Policing should be given a little more prominence. I think they are both items which figure highly in terms of services upon which people depend on a day to day basis. Arguably they are infrastructure items but I feel that by relegating them to that area leads to the possibility of giving them too little emphasis. Possibly there should be reference to specific strategic partnerships with the relevant NHS bodies , medical centres and the Police And Crime Commissioner.","I believe that the development of specific local policies is best dealt with by the relevant County Council and Borough Councils. I do not feel that such items need to be included in a strategic plan. The local items should flow from the overarching strategic plans. On a specific issue , I believe that local items should rarely be left entirely in the hands of Parish Councils. Increasingly Parish councils rarely have elections to their councils. People are simply appointed by the existing members. This leads to basically unaccountable bodies. Vested interests  and prejudices can seriously influence decisions and most residents have no idea what is happening.","Yes","","Yes","","I believe that the most effective and acceptable way in which the SLP can address climate change is to focus on issues which tangibly improve the majority of people’s lives rather than degrade them. Therefore , almost all initiatives linked to nature , such as the preservation of green belt land and the increase in biodiversity are excellent. Similarly guidelines for new housing which include requirements for good insulation, solar panels and heat pumps / community heating systems are positive since they help people moving into new homes to be as carbon neutral as possible. Similarly , it will be beneficial to try to improve the overall system of public transport , in order to try to reduce some element of private car usage. Conversely , I do not believe that it will be efficient to try to force people into actions which seriously degrade their lifestyles. For example , it is not helpful to try to force people to switch to heat pumps when the costs and difficulties of installation are far beyond the capabilities of the vast majority of people. Similarly it is not helpful to try to force people away from private car usage to an extreme degree. People will not be at all happy to see their private mobility severely restricted – particularly if there is not a suitable public transport alternative. It is worth bearing in mind the high level issues involved in climate change. It now seems that climate change is definitely a phenomenon. I believe that independently of climate change it makes sense to try to move away from using fossil fuels – partly due to emissions problems and partly due to the finite amount of such fossil fuels which are available. On a political level , it also makes sense to move away from dependence upon the majority of countries which produce fossil fuels. Unfortunately , the majority of fossil fuel producing countries have despicable , despotic regimes where human rights are almost non-existent. However , it has to be admitted that there is absolutely no certainty around the degree of impact of such measures upon climate change. It is simply not possible to know precisely if and when such measures will have a significant impact on climate change. Therefore , I believe it is not sensible to set very challenging , strict target dates for climate change measures. There needs to be flexibility. Otherwise people will see their lifestyles being seriously degraded for no real apparent benefit. This could lead to social unrest and a severe backlash against climate change initiatives. Ultimately climate change measures which are too severe will simply be seen as worthless virtue signalling by politicians with no real benefits becoming apparent. ","I am not aware of the current requirements for the construction of new buildings. However, there should certainly be minimum standards for insulation including double / triple glazing of windows. This will be essential if heat pumps are likely to be the main source of heating for new buildings, otherwise levels of heating could simply be insufficient. In addition , it may be useful to consider community heating systems where this is viable.","It is particularly important for there to be increased flexibility in the use of buildings in city , town and village centres. There are increasing changes in the nature of centres , as the demands for offices , retail space and residential property all fluctuate. Without flexibility of use there is a danger that centres could decay and have numerous vacant buildings. Flexibility is also needed when considering the retention of existing buildings. Clearly if existing buildings have historic value or contribute to the overall character of a town centre , then at least the facades of the buildings should be retained , even if the internal arrangements of the buildings are remodelled. It is important not to have vacant buildings if at all possible – this simply leads to decay. Any repurposing of existing buildings should , as with new buildings , take into account minimum standards for insulation , glazing , solar panels and heating systems.","No","Yes","I cannot identify specific plots of land for environmental purposes. However , as a general point it may be worth considering some form of development of wildlife and biodiversity projects in green belt areas. I am keen to retain green belt land and would not wish to see it overdeveloped by such projects but it should be possible to employ some environmental projects in green belt areas without destroying the character of the land. For example there are green belt areas around Cheltenham Racecourse which are well used by ramblers and dog walkers and I am sure that sensibly arranged environmental projects would be appreciated by all users of the land.","I would think that ideally all the basic services for daily life should be within easy reach – i.e. medical (doctors, dentists, pharmacy), schools , policing , fire & emergency services , local convenience stores, green space / leisure space & facilities.","Yes","Given the fact that one of the major attractions of the area is the natural scenery within it , it would seem very difficult to find any significant space to accommodate wind turbines without seriously degrading the quality of that scenery. However , there may be ways of employing solar panels which do not create environmental issues. For example , perhaps panels could be installed on suitable south facing roofs of larger commercial buildings such as factories , warehouses etc.","Yes","","Yes","I can envisage two extreme cases where the number of houses might differ from the Standard Method approach. Firstly , there could be a scenario in which it is decided to grow the population way beyond the figures indicated by the Standard Method. This could occur if an influential group believed that the area should simply become one big conurbation – linking Gloucester , Cheltenham and Tewkesbury. Obviously government would not oppose such an approach since it helps to accommodate housing needs. However , I believe it would completely destroy the character of the area and degrade the lifestyle of the majority of people. Unfortunately , such a scenario is not totally impossible. We saw a slight move in that direction with the economic growth models which were included in the original Joint Core Strategy for the area. The models were ridiculously over optimistic and included such notorious items as an annual growth figure of 4.7% for year after year and an assumption that retail space would increase six fold !  Unfortunately I cannot help that feel that some of these optimistic views are driven by the prospect of some of the businesses and  consultancies benefiting from grants and subsidies. Personally I am very much against this approach and I hope that great care will be taken to avoid a move in this direction. Secondly , there could be a scenario in which the local authorities take a view that the housing needs figures emerging from the Standard Method are simply not sustainable in the area. Clearly, a big piece of work would be required to demonstrate that the figures emerging from the Standard Method would lead to such a degradation of lifestyle for local people that the approach would simply be unacceptable. It would be necessary to demonstrate that the Standard Method figures would lead to a virtual breakdown of infrastructure , local services , climate change/ environmental initiatives. This would be extremely difficult to prove and would receive enormous pushback from government. However , in any sane world such a bottom up planning approach ought to be given at least  as much weight as a top down approach where government simply obliges everyone to deal with its policy of unlimited immigration.","Yes","I believe that the optimum way of providing affordable housing is via the social housing that is being pursued by Cheltenham Borough Council. I feel that this approach avoids most of the pitfalls of other forms of affordable housing approaches. It would appear that the student populations in Gloucester and Cheltenham are likely to continue to grow in the near future. I believe it is better to try to provide purpose built accommodation for as many students as possible. The alternative seems to be that multi-occupancy areas develop in an uncontrolled way and this can create issues for other residents in those areas. To date the provision of accommodation for older people has largely been left to the commercial sector. I feel that this has not always led to satisfactory solutions. In particular , the private accommodation aimed at older people has been expensive and well out of the range of most lower income people. There are also serious problems connected to management fees and exit fees. There is a need for an affordable form of accommodation in this area. It will be a growing sector in the future due to the aging population. It may be difficult for councils to tackle this area but it probably requires a targeted solution akin to social housing.\n","No","","","I believe that it is crucial for the SLP to support realistic economic and regeneration projects in order to optimise the rewards which will be generated. As I have mentioned previously in this consultation document , I believe that it is essential to avoid the sort of over optimistic and unrealistic projections that formed part of the original Joint Core Strategy work. Inflated projections simply lead to a waste of time , energy and money and even to a falsely inflated figure for housing needs. They also create an impression that overblown projections are produced in some instances in order to satisfy local interests for subsidies and grants for pet projects that will actually go nowhere. It is often said that economic projections within plans need to be aspirational and include stretching targets. I understand these views but the results still need to be attainable with a reasonable probability of success otherwise an idiot like me could knock out a projection in an hour and half and it would have as much validity as one that has taken months of work by highly paid consultants. It is essential that projections are compared in detail with historic figures in order to highlight potential anomalies and discontinuities with past development. Any such discontinuities and anomalies should require rigorous analysis and explanation. To say that a specific figure is a “stretch” target is not by itself a proper explanation. Specific projects are mentioned in paragraphs 5.36 to 5.39 of the notes with the consultation document. It is excellent to see such specific items. In relation to 5.36 and the possible need to make greater us of the Birmingham to Bristol rail line ,   I would simply say that great care needs to be taken in this area since the operation of rail lines throughout the UK seems to be in great flux , with a creeping renationalisation taking place. I would also say that one would require rose tinted glasses to believe that the rail line from Gloucestershire to London parallels the A40. The east west rail link is disjointed and the service is far from perfect. I believe that the Innovation projects and cyber security developments in Cheltenham , covered in paragraph 5.37 , are a good example of building something upon a specific  local advantage – i.e. the presence of GCHQ. I do believe this work should be given all reasonable support. Similarly , the Gloucester regeneration projects mentioned in paragraph 5.38 are a good example of specific work with a clear objective (however I have to say that Gloucester regeneration seems to have a never ending life span – I think some cities blitzed during World War II were regenerated more quickly).  Tewkesbury is mentioned in paragraph 5.39 and reference is made to tourism which I am sure could benefit from increased attention and support. However , I feel that the references to other economic sectors in Tewkesbury seems a little vague and there may be a need to attempt to define an area or areas where Tewkesbury has specific advantages that could be built upon.\n","I believe that the points covered in paragraph 5.35 of the consultation notes provide a good framework for attempting to ensure that the area is attractive to inward investment. I believe that these principles should be applied to those areas such as the ones noted in paragraphs 5.36 to 5.39 ,  in order to try to focus resources on those projects with the highest probability of delivering good returns. As noted earlier , I believe that this focused effort should be concentrated on projects which are linked to local advantages rather than attempting to attract businesses which have no relevance, connection or links to the area.","One fairly straightforward way to encourage a degree of rural employment would be to ensure that high speed broadband connections are readily available in all or most rural areas. There are many freelance professionals who are able to work from home with a suitable broadband connection. Similarly , there are a growing number of employees who work for at least a portion of their time from home. Poor broadband connections have historically been a deterrent to many of these people being based in rural locations. I would just make a point related to the method of provision of broadband services. Unfortunately, in an effort to speed up the provision of broadband services, the government has relaxed certain planning restrictions and this has led to some bad practices by some providers. In particular , some providers have chosen to use telegraph poles rather than underground cables – even in some places where underground cabling is already present. Not only are the poles unsightly but their use is clearly not environmentally friendly. At present, there is a clear movement to plant more trees as part of the fight against climate change. In this case we have companies chopping down trees for their own profit motives. I can believe that there may be some locations where the use of telegraph poles is necessary but I think this should always be a last option and not the first. If possible the local authorities should attempt to control these practices.","Firstly , I would say that this area may look awfully difficult at first glance but I believe that it actually provides an enormous opportunity to transition and repurpose our town / city centres. I feel that the drivers behind much of the need for change – such as the growth of online shopping and the emergence of working from home – are actually still in their infancy and will actually accelerate and drive further change. Inevitably much of the push for change will come before we have solid solutions but this should not unduly worry us but simply energise us to think and work harder. I think the decline in retail space in town and city centres is likely to continue. I do not see out of town retail parks as the enemy, they simply provide people with incredibly convenient places to shop , where parking is free and in abundance. Such retail parks simply complement shopping sites elsewhere. I was pleased to note that a Retail Study had been commissioned by the authorities. As mentioned , it will need an update since it was completed in 2019 , before the pandemic which drove enormous changes in working practices. At least that study did acknowledge that there was unlikely to be a need for much more , if any , retail space in the area. This corrects the fantasy of the original projections in the Joint Core Strategy which claimed that there would be a six fold increase in retail space. I think the vacant units action plan in Cheltenham is a good initiative, since a plethora of vacant units in any centre can look very depressing. However , ideally any action plan to minimise the number of vacant units should be linked to an overall strategy for a town or city centre , otherwise there is a danger of simply lurching from one vacant unit solution to another in a never ending cycle. I feel that retail requirements in centres are likely to continue to reduce and there is a need to completely rethink centre usage. I believe that there is likely to be some blend of residential , leisure , tourism and some retail. I feel that there could be a case for considering some form of public green spaces and town squares in some centres. These could form a focus for social gatherings and could be used for festivals and markets. For example in Cheltenham Imperial Gardens and Montpellier Gardens are used as sites for festival activities and seasonal events. In fact now that the Boots corner route through Cheltenham has been opened up again , there could be a case for considering the closure of the lower Promenade to traffic and converting it into a park / town square. If such a project were successful , it could become a tourist attraction for the town. I believe it would be valuable to think about the potential mix of residential properties in city / town centres. I think there could be a case for having an element of accommodation focused upon the elderly population. Currently such accommodation provided by the commercial sector is way too expensive for the majority of people and has many issues relating to management fees and exit fees. Properly planned developments could provide good centres of community and support for older people. Similarly , it may be useful to consider accommodation for students in city / town centres. This appears to be likely to happen in Gloucester. Such developments could avoid the haphazard development of multi occupancy properties  for students which happens at present. An idea that I have seen promoted recently for under used offices in town centres is some form of multi occupancy rentals for people / companies involved in hybrid working.  Companies often require staff who work from home to spend some minimum amount of time in an office environment. This can mean that people who live in or near places like Gloucester , Cheltenham or Tewkesbury are required to commute to company headquarters or regional headquarters in cities such as Bristol , Birmingham or London. Perhaps if office space were available locally , then such people could work in the area rather than make long commutes for just one or two days a week. I have no idea if this idea is really practicable or whether there is a real demand but it may be worth considering. Whatever form of transitioning is chosen for town centres this will inevitably involve a high degree of flexibility in the use and reuse of existing properties. No doubt some landlords and property owners will be resistant to change. They will need to be convinced that changes to the nature of city and town centres are inevitable and are in fact already upon us. There will be no point in landlords of retail space hanging on in the belief that retail will experience a miraculous resurrection. When existing buildings are repurposed it will be necessary to consider the character and heritage value of such properties.  In many cases it should be possible to reconstruct the interiors of buildings without damaging the facades which are probably the features which give the buildings their special character. In addition , great care should be taken to ensure that any new buildings fit in with the existing environment. If there is to be a significant change to the look and feel of town centres , then we should avoid at all costs the mistakes made in the 1960’s and 1970’s , when many soulless concrete monstrosities were created. I feel that the whole area of safety and security in centres also needs to be given serious thought. There is a danger that if more bars and clubs appear in centres , then there could be a growth in anti social behaviour unless correct policing is involved.","I feel that this is an extremely difficult area. There was a time when local stores , pubs, post offices and banks would have been considered essential items in any thriving rural community. Across the country such facilities are simply disappearing and this is due to a combination of factors but one of the major factors is simple lack of sufficient demand. I think it will be difficult to support and encourage such facilities if people are not prepared to make use of them.","In practice the types of infrastructure required for a new development are not much different to those of an existing development – i.e. roads , schools , drainage , public transport , health services , recreation facilities , access to emergency services etc. Depending upon the exact location of a new development , it may be possible for some of the infrastructure items to be provided by nearby existing developments. Ideally  it would be optimum for as many services as possible to be within walking distance , in order to avoid the need for unnecessary private or public transport journeys.","The list of required infrastructure would actually be pretty much the same as for other new developments , as noted in question 23 above. However, with a strategic new development , it is likely that virtually all of the services will need to be provided locally within the strategic scale development , since there will not be many or any services already available close by. One additional service that will probably required is basic retail provision including supermarkets. One big potential advantage of large scale strategic developments is the fact that all the infrastructure can be designed and built from scratch. It can therefore be designed to specifically link in with the overall design and location of the development. However, this advantage holds within it a some huge disadvantages , namely those of costs and time frame for development. It is quite possible that these disadvantages will be considered big enough to rule out quite a number of potential strategic developments.","Currently I would guess that the majority of rural developments are quite small in terms of numbers of homes and that these homes are probably targeted at relatively well to do people. In these cases there is probably no particular need for even what would be considered basic services elsewhere. However , if rural developments are much larger in scale (say several hundred homes or more) then most of the services mentioned in the earlier questions are then required. Difficulties obviously arise when a particular location attracts a number of small scale developments independently. The position can be reached where services are required but no specific small scale development has been required to provide them.","Yes","No","","Yes","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement","No","","Firstly, just to say that I attended all the specific subject workshops within the consultation and I found them to be very well organised and very informative. At this early stage of the SLP process everything is very professional and civilised , partly because it is mainly conducted by the planning professionals and also because it is nowhere near detailed discussions about specific proposed development sites. I would just like to make one procedural point to consider for much later in the process when specific sites are being discussed , either within meetings of the local authorities or in examination meetings with the inspectorate. I think that strict time limits should be imposed on all lobby groups and local interests when making comments or statements in those meetings. I believe that a number of such meetings toward the end of the original Joint Core Strategy process were marred by weak meeting management. In particular, the lobby group for Leckhampton (LEGLAG) were well organised , forceful and demanding. That group actually took up as much as 80% of the time in at least two meetings which I recall. The importance of that area did not warrant squeezing out other subjects. The sad end to this was that LEGLAG actually did not really succeed in their objectives anyway , since over one thousand houses have been built in the Leckhampton area. I just think that better meeting controls should prevent one action group from hijacking proceedings. Finally , one point which is not strictly part of the SLP but which I think has an impact on the way in which developments are completed and received by existing residents. A sizeable development of around 350 dwellings was completed a few years ago near where I live in Prestbury. A local resident who lived right next to the proposed new development fought hard to prevent the development actually happening. However , when cause was lost he did not go off in a sulk and ignore everything. He actually monitored the construction process literally on a day to day basis and did his best to ensure that developers kept to their plans and promises. I have to say that all his hard work has really paid off. He made sure that all the flood alleviation work was completed properly and that all the promised green spaces were provided. He even ensured that certain corridors were maintained for wild life in the area. I walk my dog through parts of the estate every day and see the results of his efforts. There has been no flooding or even gathering of surface water, there are several pleasant green spaces and almost every early morning I see foxes and badgers. My point in explaining all this is that I think many developments would benefit significantly by someone actually having the job of monitoring the construction processes on an ongoing basis in great detail. It is no use monitoring developments only near the end of work , since by that time a number of issues will probably be irredeemable."]
["","MP","","","","","","","","As noted in the consultation document (para 4.2) the SLP should meet the challenges of climate change, whilst ensuring green growth, nature recovery and making use of brownfield sites.\n\nThis last point is very important: brownfield building must be the first, second and third priority. And yet all too often the approach has been ‘greenfield first’; just take Oakley Pastures, where the planning Inspector highlighted that the decision to approve was based in significant part on the Council’s failure to identify sufficient housing supply. As a result, the protections afforded by AONB status have been significantly eroded. \n\nI have said for many years that there are many alternative opportunities here in Cheltenham to bring new homes on-stream – which in turn would take pressure of green spaces. First, I continue to encourage CBC to review housing delivery and take the opportunity to repurpose empty retail sites to residential. Second, it is also important that local brownfield sites are sympathetically developed to remove additional pressure on sensitive sites.\n\nIt is noted in the consultation document that active travel is one of the policy actions which may be considered through the Strategic Local Plan. In Cheltenham, we are lucky to have a town which is largely flat, and therefore more cycle-friendly than many others. However, it is the case that people in Cheltenham are not cycling in the numbers that residents are in places like Cambridge and London. \n\nMore can be done to promote cycling and other forms of active travel to help reduce emissions. Crucially, the Council should steer away from expensive and controversial (to say the least) schemes like closing Boot’s Corner, and focus again on affordable and practical measures.\n\nThe natural environment plays a large part in tackling climate change and nature recovery. In a similar way to ensuring councils have a five year housing supply, a five-year tree supply should also be secured with the identification of suitable sites for planting. What steps, for example, have been taken to liaise with the Environment Agency for permission to plant trees in Cox’s Meadow?","","","","","","","","","","","Yes","It is my view that if not already taken into account, the upcoming large-scale employment and transport improvements around the West of Cheltenham, J10, and the A417 should be given due consideration when assessing housing requirements. ","","","","","","","I appreciate the consultation document was produced prior to the announcement regarding the closure of Cavendish House. I believe this can be used as an inflection-point to deliver an ambitious vision which secures the future of the town centre. That means a mixed-use development with a blend of retail, recreation and affordable accommodation.\nThat accommodation element is particularly critical, and this can and must be used to deliver more homes for young people. As well as meeting that need, it will also help relieve pressure on precious green spaces as referenced above. \nI strongly urge the Council to seize this opportunity to catalyse a wider plan for Cheltenham, with major strategic rebalancing of retail and residential space across the length of the High Street. Far more must be done to shape where empty shops, particularly beyond the bowling green out towards Gloucester Road, can better be reconfigured as homes. ","","It is noted in the consultation document the town centre is being used more and more for leisure than for shopping requirements, which are increasing met online or at retail parks. Therefore, measures need to be taken to secure the future of the High Street. Along with those already mentioned, I reiterate my long-standing call for cheaper parking. A large proportion of society have no choice but to drive. Specifically, I favour free parking after 6pm and on Sundays to encourage people to the town centre. ","","As has been referenced in paragraph 5.53, new homes and employment will require new infrastructure. I agree with the general view that this should include, but not be limited to, health provision, education provision, transport, and recreation. These elements will be exceptionally important should the SLP follow the model of new strategic scale settlements, which may not necessarily have the same access level to existing provisions. \n\nIn addition, I believe it is important that the SLP also looks at how existing infrastructure can be improved. Given the considerable projected growth in housing numbers, coupled with the welcomed expansion of our local employment base, improvements to the town’s strategic infrastructure must be given greater emphasis.\n\nWhile I am aware that the purpose of this consultation is to explore what the SLP should cover, I am aware of a specific proposal as regards supporting the safeguarding of the route of a Southern rail connection between the GWSR and the Midland Main Line. This would include creating a park-and-ride station at the eastern end of such a connection, with parking available on the Racecourse's adjacent car park. Whilst such a park-and-ride and its connection to the main line may be of little economic benefit to the GWSR, it would be of significant benefit to Network Rail, the Jockey Club (the owners of Cheltenham Racecourse) and Cheltenham Town.","","","","","","","","","","","[New homes] - I note in para 5.5 of the consultation document, it is acknowledged that the council’s existing Local Housing Needs Assessment (2020) will need updating as part of the SLP process. Evidently the snapshot provided currently is out of date, and a more current view is needed to provide the adequate analysis and planning as part of the final SLP. However, I am pleased to see that a range of demographics have been given initial consideration as part of the consultation, and that all will be taken into account when determining housing supply. I re-iterate my comments on use of empty retail space and brownfield sites as a priority for development of new homes. \n[Jobs and the economy] - I understand the Gloucestershire Economic Needs Assessment currently mentioned in the consultation was produced at a time where implications of the pandemic were not fully known, and so evidence will be reviewed later in the SLP process. I look forward to seeing the updated assessment. Alongside acknowledging that working patterns have changed since the pandemic, I would also request that the growth of Cheltenham as a cyber centre of excellence is taken into account when setting out the way in which employment land and premises are managed. I am pleased that Cheltenham’s status as an innovation hotspot has been mentioned in the consultation. I agree that the SLP will need to consider how best to promote the local business environment in a way that embraces growth and change.\n[Retail and town centres] - Paragraph 5.47 notes that in 2019, a “health check” was completed for the main town centre areas, including Cheltenham, and that is what is summarised in the consultation document. A great deal has changed since the “health check” was performed, including a global pandemic which has changed how people work and shop. For the SLP to plan accurately and suitably for the future, a new assessment must be carried out. \n[Infrastructure] - I note that an Infrastructure Delivery Plan will be produced alongside the SLP, and I look forward to seeing this in due course.\n[Planning for sustainable development] - It is reassuring to see that thought is being given into the long-term options for sustainable development. Noting that there is limited land for development, I would like to emphasise again my view that brownfield sites should be considered first so as to avoid where possible, mass development on AONBs and Greenbelt land. I am pleased to see that this is highlighted in paragraph 6.11."]
["Resident","University of Gloucestershire","","","","","","","","We support initiatives aimed at addressing climate change and promoting nature recovery. Approximately 64% of our students commute via active or sustainable travel options and we will continue to work with local bus companies and the county and city councils to encourage greater uptake of these options. ","","","","","","","","","","","","","","","","","","","","","We support the reinvention of retail and town centres by promoting multi-use destinations and empowering our student communities to play a role in this. The development of our new city centre campus in Gloucester is a clear example of this in practice and will have long lasting, positive impacts on the health of the city centre.  ","","","","","","","","","","","","","I am delighted to submit our response from University of Gloucestershire in relation to the SLP and the open consultation period. Our response covers a number of themes, so we have included them all as set out below:\nAs an anchor institution in the region, we take our civic responsibility seriously and we are keen to contribute our experience, ambition, and expertise to the development of the Strategic and Local Plan (SLP) for future sustainable success. \nRegarding specific themes outlined in the SLP we are pleased to provide initial feedback as below which can be further developed as the plan is progressed, with the intention of highlighting areas of shared vision and commitment. We have a wide range of specialist academic and professional colleagues with specific interest in the themes and scenarios raised in the plan and look forward to the opportunity to collaborate with you as key stakeholders as the programme develops. \n[Planning for climate change and nature recovery] - The University estate consists of a variety of landscapes, including rare species of flora and fauna, which are managed to maintain biodiversity and improve it where possible. We work with local nature partnerships and other wildlife organisations to improve nature in the local area. \nWe have a strategy to become Net Zero by 2030 and have undertaken considerable work to decarbonise our campuses. We have replaced 6 gas boilers with air source heat pumps and will undertake a £900K project this year to replace another set of large gas boilers with ASHPs. Our new campus in Gloucester City centre will be completely electrically heated and the refurbishment has included significant improvements to the thermal envelope of the building. \nAll of our campuses are accessible by public transport and active travel options. We have installed electric vehicle charging at all campuses and have encouraged cycling and walking as low carbon travel options.\n[New homes] - Considering the forecast need for new affordable housing in the region there are several university initiatives underway that align with this and where we can demonstrate we have a shared vision for maximising use of spaces.  \nThe University has now approved the proposal to dispose of Hardwick, with the intention being to sell the site, including the student residencies, with vacant possession by September 2026. This is a clear opportunity for an existing site to be redeployed for alternative use and to support the vision for new homes to be created through a blend of new build and repurpose of existing facilities.\nThe proposed development at the Folly site also reflects our commitment to community enhancement. We anticipate that this project will not only address the need for affordable housing but also provide improved sporting facilities and public realm for both the local community and our university.\n[Jobs and the economy] - We strongly advocate for a culture of collaboration and innovation across urban and rural communities to drive innovation, enterprise, ambition, and productivity. This is evidenced by our lasting commitment to the Gloucestershire Growth Hub Network, our Hub in Gloucester, and our ongoing business support activities. Working with employers from across the region, business support networks and national support providers, we focus in on the reskilling and upskilling needs of our workforce, the economic growth of local businesses and the creation of jobs and new enterprise that should follow. Our business engagement teams have access to first-hand knowledge and insight from regional businesses regarding the key barriers to growth and we look forward to continuing our collaboration with county council colleagues to shape solutions to meet these challenges. \nOur work with the Cyber community contributes to the need to home-grow the future workforce, and we are partnering with CyNam to work more closely with SMEs in this across the region.  As a Cyber First partner, we continue to build relationships with the county’s schools to raise aspirations for further and higher study.  Our portfolio of courses is mindful of the region’s economic priorities (cyber, education, healthcare, creative industries); we see our capacity to support growth in this area as a key element of our partnership working. \n[Retail and town centres] - Enhancing connectivity between urban and rural areas and improving transport links are crucial steps toward creating vibrant, inclusive destinations. We have a commitment underway to improve our students feeling of connectedness to the same end – moving away from students routinely using only one site and encouraging students to use multiple campuses across Cheltenham and Gloucester, to get the full UOG experience and better build ‘place’ as a differentiator for the institution. To support this, logistics and transport availability will be key, as will the approach to sustainability that can be evidenced through any new provision. We are therefore keen to work with partners to develop enhanced public transport links between all of our campuses within and between Cheltenham and Gloucester, including our student village at Pittville, to the advantage of our students and staff as well as the wider community."]
["Statutory/Specific Consultee","Tewkesbury Garden Communities ",30,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Yes","Yes","Please see response in question 31","","See response to question 31","","","","The Garden Communities team at Tewkesbury Borough Council, with support and funding from Homes England, are tasked with promoting and facilitating the development of a garden town (now called Tewkesbury Garden Communities or TGC) on land to the east of Tewkesbury Town. (Rough location can be seen in the Charter document) \nThis representation relates to the promotion of that land to the Strategic Local Plan spatial optionsand represents the officers view. The purpose of this representation is to set out why the TGC is the best option for delivering strategic housing numbers, employment as well as infrastructure and services, in a sustainable way while demonstrating exemplar standards of design. \nThe Garden Communities programme, run by central government, seeks to tackle the national housing crisis by helping to deliver much needed homes in a way which does not compromise on quality. Well planned and well-designed garden communities have an important part to play in meeting our housing needs. \nWithin this programme, Tewkesbury was awarded garden town status in 2019 which means the development proposal is seeking to deliver around 10,000 new homes as well as substantial employment land, supporting services and infrastructure. The benefits of planning for communities at this strategic scale is that they can be designed comprehensively, meaning that they also deliver strategic infrastructure and avoid piecemeal development. \nTewkesbury Borough Council has recently adopted a TGC Charter, this sets out the 9 principles which could guide the development going forward (see Garden Communities website). These principles are highly ambitious and will help to ensure that the TGC is achieving sustainable development, as defined by the NPPF. These principles align with the 3 overarchingobjectives of the planning system, explained below. \nEconomic Objective – The TGC will plan for a self-sufficient community that provides for the right mix of uses to help build a strong economy. Planning comprehensively will ensure that infrastructure is delivered in a considered and coordinated manner to support growth. The location of TGC, on the edge of Tewkesbury Town, means that it will connect and integrate with the existing settlement locating homes and jobs close to those areas. This creates growth where it is most needed and sosupports the vitality and viability of the town centre. \nSocial Objective – The scale of TGC will ensure that Tewkesbury Borough Council can deliver a sufficient number and suitable mix of homes to meet the needs of present and future generations. The aspiration of the Garden Town is for exemplar design, ensuring that growth not only meets the required numbers, but it is also well-designed, beautiful and supports communities health, social and cultural well-being. \nEnvironmental Objective - The location of TGC is highly sustainable. It is located around Ashchurch for Tewkesbury railway station, which provides for the opportunity of supporting sustainable travel options. The principles of TGC embed the highest standards of sustainability and seek to ensure that development contributes to a carbon neutral community and builds resilience to climate change. \nThe garden communities team support the inclusion of TGC in the scenarios for development, and while we accept that the scale of the proposal may warrant consideration under new strategic settlements, we do not feel this accurately describes the approach. The location of TGC next to Tewkesbury Town and nature of the development proposal ‘Transformational for Tewkesbury’ couldalso fall under the consideration of an urban extension and the benefits that this brings. This location also avoids some of the stated ‘cons’ of new settlements such as “not providing homes and jobs where they may be needed close to urban and rural settlements.” TGC offers a unique development approach for the boroughand this may warrant its own development scenario so as to more accurately consider the pros and cons. \nThe rough area of the development proposal can be seen in the Charter document. The majority of the land within this area has developer interest which gives assurance of the availability and deliverability of grow in this area. However, the multiple landownerships highlight the importance that this area is planned for comprehensively and a coordinated approach is needed to avoid a piecemeal development which will weaken the overall sustainability. \nThis scale of development will obviously be delivered over a number of decades and maybe a number of plan periods along with supporting infrastructure development. We would therefore encourage the Local Plan to consider development over at least 30 years into the future. The Garden Communities Charter and our 9 development principles have been brought forward though engagement with the community. The Garden Communities programme is set up with a governance structure which allows for ongoing engagement so that our plans are considerate of the views of the community. \nConclusion - In conclusion, the Tewkesbury Garden Communities can offer a strategic scale of development in a comprehensively planned and sustainable way. Which supports the aims and objectives of the Strategic Local Plan. It would help meet the housing and employment needs of the borough, while promoting the highest standards of design and also delivering services and infrastructure. The location of the garden communities is relatively unconstrained in planning terms and is inherentlysustainable with excellent transport links, therefore offering a unique opportunity to plan positively for growth in the borough."]
["Resident",null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt","","","[Q29.] \n1. Urban Concentration would involve developing within Gloucester and Cheltenham. This would rejuvenate city centres and use some unused previously developed sites. Transport links are already there and road networks too so this is a good option in my view.\n2. Urban Extensions options may involve green belt areas which I do not agree with. \n3. Urban Extensions - this option is as no.2 but not involving the green belt, so a bit better.\n4. . New strategic developments and settlements - the Highnam / Churcham triangle suggestion is absolutely NOT a suitable area for this size of development. \na. The traffic this development will generate will be disabling for the parish and area as a whole, causing major problems on our road network. Any local commuters experience major traffic problems already in and around the Highnam and Over areas (B4215 & A40) and this development will dramatically increase these issues. \nThis development would add at least 8,000 extra vehicles to the 10,000plus currently travelling daily along to and from Gloucester, the M5, Cheltenham and Ledbury. The highways infrastructure is not fit for purpose and is frequently hit by flooding from run-off and the River Severn bursting its banks. The A417 Maisemore road has been closed due to flooding at least 4-5 times already this year and that has a massive detrimental knock on effect pushing even more traffic onto the B4215 and A40 going from Highnam towards Gloucester. It can take at least 30 minutes even on a good day rto get from Highnam to the Over roundabout and that should really only take 3 minutes. Add in 8,000 extra vehicles and flooding and it is a disaster.\nb. Prime arable land would be lost. \nc. This option only identifies land in the TBC area, and doesn’t share the responsibility with Gloucester and Cheltenham. Development West of Gloucester is fraught with so many complications and we only have 1 river crossing so everything bottlenecks as it is - without any further developments.\nd. This Highnam/Churcham development would have a huge detrimental impact on local biodiversity, increasing the possibility of flooding and water run-off risks not to mention the impact on climate with the increase in vehicular transport. I was extremely disappointed and surprised that this option had been put forward for consideration especially given its rejection by (FoDDC) in January 2021.\ne. The scale of this development could not be integrated into the community but would obliterate it due to its sheer size.\n5. The Rural Dispersal would enlarge existing communities where capacity for existing infrastructure and resources, like the schools, Doctors etc is already at over capacity, as in Highnam. They also lack a good transport network, so would not be cost effective. In Highnam, being a service village, development has already occurred and continues to receive development. It is already at the point of the infrastructure not coping with demand. The roads are already too busy, the school is over capacity and local children have to travel fair distances to a school by car. This goes against developing a good carbon footprint, which has been agreed as a common understanding between Councils. The B4215 which is a B road in name only, but much more like an A road; cannot cope as it is - large lorries use it as a 'cut through' to Gloucester from the M50 as a short cut, and have to compete with the many commuters travelling over the Severn at the only point they can (The Over roundabout) whilst also competing with farm tractors and machinery, as this is a rural area with many farms. The road network serving and passing through Highnam village is already beyond saturation point. This also creates road safety concerns, adversely affected also by excessive speeding along this section of road. The narrow Two Mile Lane is increasingly being used as a main access thorough fare between the B4215 and the A40, taking far more traffic than it was ever designed to do. \nThe Highnam community can only expand so much before intrinsic features such as social cohesion, infrastructure fabric and scale which residents cherish and identify with are either compromised or are at risk of being destroyed. Life in Highnam has already been severely compromised following the construction of the 88 house development and the proposed additional 95 house development will exacerbate this further. Major new development “upstream “at Newent exacerbates this. The village should not expand further. \nThe current network of services to the existing community (gas, electricity, domestic water, surface and foul water drainage, telephonies, broadband etc.) are already at full capacity. Service outages, leaks and general breakdowns are a regular occurrence. This creates serious constraints on additional development, the provision of which would take this beyond breaking point. Surface water flowing off the new housing development at Lassington Reach is already creating downstream flooding problems through Highnam Court and beyond through Minsterworth to the River Severn. Clearly, significant additional development would seriously compound this. \nHighnam is an attractive village well provided for with important heritage assets (Church of the Holy Innocents, Highnam Court etc.), a traditional landscape patchwork of field hedgerows and boundaries, woodlands, together with plentiful wildlife. This would be lost if the village was further developed.\nThe majority of people in Highnam of working age travel elsewhere for their employment. This is not sustainable in the long term if we are to reduce our carbon emissions by cutting down on car journeys. More developments is only going to put more cars on an already overstretched road network. Therefore an upgrade and provision of additional buses would help provide more sustainable modes of travelling. \nI am concerned at the potential loss of good quality, productive farmland surrounding Highnam which greatly contributes to our need for food security and helps maintain local bio diversity.\nHIG010: Land to west of Highnam (remainder of the field) and Rodway Golf Club are both totally unsuitable areas for development for each and every reason stated above.\nHIG011: This open farmland has no discrete means of access for development, lies in established open farmland, and has no intrinsic merit for alternative use development. \nHIG006, 007 and 013: These sites straddle Lassington Wood, an important wildlife, leisure and amenity facility much enjoyed by residents. These sites are all totally unsuitable for any form of development, indeed HIG006 lies on the crest of a prominent hill and landscape feature, and HIG013 largely comprises steeply sloping, unstable land. \n6. Sustainable Transport option links areas of good transport networks, promoting more sustainable travel, and reducing carbon emissions from transport. In my option, this is suited more to Urban areas where the transport networks are already there - NOT areas like Highnam which would only put more traffic on the roads.\nSummary - In my view Urban concentration and Urban extensions, (retaining as much green belt as possible), would be the best choice, to achieve nice places to live, better transport networks and links to existing urban facilities. I would strongly be against ANY development in Highnam and any further development 'West' of Gloucester is fraught with many issues as stated in my points above above."]
["Statutory/Specific Consultee","Brookthorpe-with-Whaddon Parish Council","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Brookthorpe-with-Whaddon Parish Council opposes the selection of the Whaddon as a site for either a new settlement or urban extension in the Strategic and Local Plan. The evidence submitted to the Inspectors in the Examination of the Draft Stroud Local Plan and the comments lodged with the planning application 23/2428/OUT show that the site is both unsound in planning terms and received only adverse responses from local residents.\n\n\nA. Local Opposition.\nOpposition to the planning application to Stroud District Council by Taylor Wimpey 23/2428/0UT has been almost universal. The comments made to that planning application come mainly from residents in Tuffley who complain about likely traffic congestion caused by the number of houses to be built on the site and also the lack of local facilities  to support up to 3,000 houses there. No comments in support of the application have been made. The application is regarded as being premature as the site does not have adequate infrastructure. Previously, in the cases of similar proposed urban extensions in Abbeymead/Abbeydale and Quedgeley/Hardwick new infrastructure was provided in the form of Metz Way and the new Hempsted route. The Whaddon site has to be accessed from Gloucester by the Stroud Road or minor roads from it and residents in Tuffley and neighbouring areas complain that the road system cannot cope with all the additional traffic that the site would generate. Until proper road infrastructure is built the Whaddon site is not sustainable. As well as those comments to the planning application opposition was also expressed by local residents at a public meeting at St. Barnabas Church on the 26th November when Richard Graham MP and both Tuffley City and County Councillors expressed their decisions to contest the proposal.\n\nB. Accessibility and Infrastructure.\nEvidence was supplied to the Inspection of the emerging Stroud Local Plan that the Whaddon site has the worst accessibility score of any of the 450 + sites within the Stroud District area.  This is caused by the lack of crossings over the railway line, with the distance between the Naas Lane underbridge and the Grange Road underbridge being 1.3 miles approximately. Without solutions to the accessibility issues the site is not sustainable and the transport plans lodged by Taylor Wimpey in their planning application have not been approved by the County Council. The County Highways Manager gave evidence to the Inspectors at the EiP that the only solution to the accessibility issues was one which was not acceptable to mass house builders, namely a low traffic neighbour. Taylor Wimpey, who have options on the majority of the site, will not agree to a scheme which prevent car ownership and cars will be available to every housing unit they build. Their preferred solution for traffic congestion on Stroud Road and St. Barnabas is not supported by the County, Gloucester City, or Active Travel England.\n\nC. St. Barnabas.\nAlthough solutions to the traffic congestion at St. Barnabas have been suggested, none have the support of the County Council or offer a solution to the long-term traffic congestion which will be caused by a new Whaddon settlement. The emerging Stroud Local Plan suggested in their Traffic Forecasting Report and Addendum that mitigation at St. Barnabas could be provided by adding extra lanes to each of the four major roads to the roundabout but that is not supported by the County. They say that just providing more capacity is not the solution and neither is the traffic light scheme proposed by Taylor Wimpey. Traffic lights might improve current congestion, but will not mitigate the extra traffic generated by the Whaddon G2 site. There is also evidence in a Statement of Common Ground between the County and Travel Planning Associates that additional provision for pedestrian and cycling priorities at St. Barnabas will only cause the lengthening of queues. The proposal to partially close the entrance to Reservoir Road has resulted in opposition from residence. Therefore, there are no workable proposals to resolve the congestion issues at St. Barnabas and until housing developers accept the need to reduce car use then Whaddon will always create unacceptable levels of congestion on the routes into the City.\n\n D. The SRN and J 12.\nThe emerging Stroud Local Plan has had its Examination placed on pause, mainly for the reason that the Inspectors are concerned about the impact on the M5 with J12 and J14 being seen as congested and in need of upgrading. The Inspectors have suggested that the Local Plan may have to be withdrawn if solutions for the upgrades of the motorway junctions are not found before the EiP is completed. There is therefore the possibility that the site allocations including Whaddon in the Stroud plan may have to be removed. There is evidence from National Highways, as well as the County Council, that Whaddon G2 impacts J12 and the pending application by Taylor Wimpey will be made subject to a holding declaration by National Highways as in the case of Hardwicke G1 and Grove Lane, Whitminster. The County have estimated the projected cost of junction upgrades at up to £400 million for J12 with a time estimate of about 15 years based on past projects on the M5. This could mean that the Inspectors may decide that the Draft Stroud Local Plan cannot be sound or that the delay in delivering the upgrades will prevent housing allocations being built by the imposition of Grampian conditions by Highways England. Unless Whaddon can be shown to be sound at the emerging Local Plan Inspection it should not be selected as a preferred site.\n\nE. Naas Lane.\nThe Naas Lane underbridge is inadequate to serve a new community at Whaddon, and is regarded by the County Council, Active Travel England, and the Ramblers Association as being unsafe. The underbridge was built as a farm access at the time of the construction of the railway and is unable to safely take pedestrian and cycle traffic while sharing the same road space with other vehicle uses on the road. The County Council has said that the existing level crossing should be used in preference to the underbridge. The developers have not agreed to any new crossings over the railway line and insist that the underbridge be used with a virtual pavement. This has been suggested by Taylor Wimpey without carrying out traffic modelling on Naas Lane while at the same time Stagecoach have made written submissions suggesting Naas Lane should be closed to through traffic.\n\nF. Active Travel\nActive Travel England have lodged a letter of objection to the planning application by Taylor Wimpey saying that the Masterplan offered by the developers does not contain adequate provision for pedestrian, cycling, and wheeling movements within the site and on the wider road network. The Whaddon G2 site does not lend itself for good active travel access into Gloucester with a lack of safe cycling routes despite current planning policy that it should be a primary consideration in new developments. The existing routes into Gloucester for cycling, wheeling and walking are congested, inadequate, or unsafe.\n\nG. Traffic Impacts.\nEvidence agreed between the County Council and the developers' consultants have confirmed the extra traffic impacts affecting both the main road and minor roads , including Firwood Drive, Epney Road and Upton Lane within increases in traffic flows of up to 44%. The extra traffic on the A4173 generated by the G2 scheme has been described by the County's Highway Manager as \" phenomenal \" and the likely congestion impacts at St. Barnabas and the wider network as \" severe \". Those impacts are to be felt also in Brookthorpe village, Upton Lane, and Haresfield Lane with Brookthorpe being shown in the Traffic Forecasting Report as been one of the three most congested roads in the Stroud Local Plan near Whaddon even after mitigation. Insufficient or no mitigation has been offered by the proposed developers for Brookthorpe and Whaddon villages and the surrounding road network stretching to Upton St. Leonards and Haresfield. Without proper mitigation, the site is not sustainable.\n\nH. Public Transport\n At the moment the Whaddon site is served only by the Stroud 62 and 63 buses with a half hour service in each case. The proposal by the developers is to route those services through the site along with a further new orbital bus service from Kingsway but all three bus services will approach Gloucester along the Stroud Road to St. Barnabas.  It is inevitable that the congestion at St. Barnabas will create delays with those bus services and increase the queueing length stretching back to Whaddon. Although another route has been proposed by Stagecoach in Firwood Drive, the current Masterplan show it will only be used by the existing number 9 service from Tuffley.  There can be no double-decker bus services to the West under the railway line because of the height restrictions in all three under bridges. This will therefore increase the number of orbital buses using Naas Lane and the route through the development. Despite a requirement from Stroud District Council for a bus route to Grange Road through the Tuffley Farm site in G2 no agreement has been reached with the promoters there and at the present time all buses will be using the route through a Modal Hub onto Stroud Road.\n\nI.  The Modal Hub.\nThe Whaddon G2 relies on a Modal Hub being provided in order to provide transport alternatives to the car and to improve sustainability. The location for this has been chosen by the developers as being next to St. Margaret's Church which is a Grade II * listed building. That has received an objection from Historic England who say that unacceptable adverse impacts will be caused, and the location also offends a draft policy from Stroud District Council in that it should not be within 250 ms of the Church. Further, the whole concept of a park and ride is doubtful in view of the experience at Quedgeley where the 450-space car parking scheme is hardly used and is effectively redundant. People prefer to use their cars and Whaddon G2 could produce over 3,500 cars at a ration of 1.22:1 for 3,000 houses. Until a new planning strategy is applied to reduce car numbers, traffic congestion in and around Whaddon and Tuffley would reach unacceptable levels with a site allocation for mass housing. The public responses to the pending planning application show that this is the main concern with residents."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I live in Highnam and want to show my support for the response given by Highnam Parish Council to yourselves regarding the above.\nI appreciate homes need to be built but further building around Highnam will only result in more traffic, flooding and pressure on utilities etc.\nThere must be lots of brownfield areas around the county and with our high streets dying maybe the empty shops should be considered as prime sites for conversion as well as empty office blocks."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I am dismayed that Green Belt land might be considered for housing development.\nShould this plan go ahead three more farms will be lost meaning eventually more food imports will be needed.\nThis is also detrimental to local wildlife which I believe is now endangered already with species of birds and insects to mention a few lost forever.\nWe need to keep green spaces for the future hopefully other more suitable areas for housing can be found."]
[null,null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I am writing on behalf of Bloor Homes, who control land at North West Cheltenham that was removed from the Green Belt and safeguarded for longer term development in the Joint Core Strategy. Accompanying, this letter is a plan of the land concerned. Our representations concern principally the spatial strategy options which are discussed in the consultation document.\nThe JCS was adopted in 2018. Whilst it provides strategic planning policies for its three constituent parts for the period to 2031, there was an obligation on the local authorities to undertake an immediate review in respect of two parts – retail policies and housing provision. That obligation has not been met. Rather the Issues and Options consultation was first undertaken in 2018, with no other material progress in the intervening period. The attempt to bring forward this new Local Plan is in the face of a number of difficulties that have arisen because of the JCS. The significance of these contextual points is unavoidable. At Cheltenham, highway infrastructure needed to accommodate allocations made at the end of the JCS examination process is now substantially larger and strikingly more costly. This has created conditions that have delayed the delivery of longstanding and eminently suitable development. The ambitious aspirations at the Golden Valley beyond the policy position in the JCS has hindered the delivery of North West Cheltenham. Delays through the planning process have also hampered delivery of other sites including Leckhampton. At Tewkesbury, because its Borough Local Plan looked only to the housing requirement in the JCS, rather than the level indicated as necessary by the Government’s Standard Method, it has been unable to demonstrate the required amount of housing land supply. It is in this context that the Strategic  Local Plan (SLP) is being prepared. These are matters that plainly cannot be resolved in the short or medium term. For example, there is a deficit against the JCS’ housing trajectory at North West Cheltenham and West Cheltenham of some 2000 new homes by the present time. In looking forward to the next plan period, that under provision cannot simply be ignored as it has manifestly contributed to the affordability difficulties that are described in the consultation document and widely experienced. \n\n[Q1.] The consultation document refers to a vision for 15 – 20 years. In the context of the evident difficulties that exist a planning strategy covering a longer period of time is going to be necessary. This need arises for two reasons. Firstly, the task of preparing a new plan is no small matter and will take many years still regardless of intentions to move swiftly. The current JCS effectively took between 2008 and 2017 to prepare and it had the benefit of the earlier work undertaken as part of the Regional Spatial Strategy as to Areas of Search for future development; it is inescapable that the 2006 Section 4/4 advice from the County Council is the cornerstone of the JCS’ spatial strategy and most of its strategic allocations. \nSecondly, the ability to achieve the existing and future development needs will require a careful and considered approach to strategic planning and delivery. At Cheltenham the foundation of the SLP will need to be the existing North West Cheltenham strategic allocation given its many important facets. There is no alternative strategy that can conceivably replace that strategic allocation whilst achieving the various land use benefits that are to accrue from it and the sound spatial principles that unquestionably remain.\n\n[Q4. Q5.] The Vision and Objectives set out in the consultation document, are in the main, unobjectionable and reflect a range of material planning considerations and national planning policy. It is evidence that a number of those objectives dictate a particular spatial pattern; for example: \n- Ensuring growth takes place in sustainable locations that minimise the need to travel and provide genuine sustainable transport and active travel options; \n- Making the most effective use of previously developed land, including higher density development in city and town centres and other locations well served by public transport; and \n- Reducing the need to travel by creating real options for healthy, accessible and walkable neighbourhoods where key services are available without the need to use motorised transport. \nThe extent to which the Vision is realised and the objectives are achieved, will depend on the policies and proposals that are in due course set out in the Plan. Plainly, such policies and proposals need to positively prepared, effective, justified and in accordance with national policy. \n\nSpatial Options\nThe underlying principle in the JCS was to meet development needs where they arose. It recognised that Cheltenham and Gloucester’s needs could not be met within the tightly drawn administrative boundaries and that urban expansion was required. Concomitant with this, the Green Belt had to be amended. Those were compelling principles during the gestation of the JCS and remain sound at the present time. It is not the principle of the strategy that has been the undoing of the JCS, rather the ability to properly form a deliverable infrastructure strategy. \nWe are especially mindful of this in commenting in the following paragraphs on the suggested spatial options that are the basis of the consultation document. In our view, none are individually themselves either suitable or appropriate as the spatial strategy for the SLP. \nPausing here however, we note that diagrams used to depict the various spatial options in the consultation document appear to be fundamentally incorrect; they fail to recognise the extent to which land was removed from the Green Belt east of the M5 at junction 10 both for A4 and SD5(7)(ii). Accepting that these are a high-level illustration, as presently drawn, these diagrams imply the Green Belt is a continuous designation east of the M5 north of Junction 10, which is plainly not correct. We are concerned that this might mislead respondents. \n\nDevelopment Scenario 1 Urban Concentration\nWe agree that a priority should be afforded to previously developed land. However, by the present time, the extent to which that represents a genuine unrealised potential of significant development land is limited, especially in Cheltenham. Equally the need to strike the correct balance between housing source and housing types, whilst affording protection to the character of places, dictates that urban concentration simply is not a credible option. \nWhilst national planning policy strongly favours development in close proximity to major developed areas because of the advantages that exist in terms of accessibility and promoting alternative modes of travel, the scope to achieve that is limited. Already, the JCS has removed extensive tracts of land from the Green \nBelt with the intention of meeting longer-term development needs (SD5 refers). \nIn our view strategic allocations and safeguarded land are plainly building blocks for any future development strategy. However, recognising the delivery period associated with those scheme, those are development locations that will extend through the next plan period but are themselves not sufficient to meet development needs. \nThese strategic building blocks will need to be supplemented by development at other suitable locations which inevitably include existing towns and smaller settlements. Development in those locations will need to be commensurate with their role and function. This limits the extent to which a dispersed strategy can successfully accommodate the needs of the plan area without adversely affecting the rural character and appearance. Environmental constraints such as flood risk and the National Landscape similarly constrain the suitability of certain locations.\n\nDevelopment Scenario 2 Urban Extensions\nIt is unclear whether this is the same of the JCS’s Strategic Allocations presently, or how it is different to it. We infer from the diagram that the three development areas around Cheltenham correspond to North West Cheltenham, West Cheltenham and Leckhampton, but we might be wrong and that these represent enlargement of these development areas. If this were the correct interpretation, we would expect to see the safeguarded land at North West Cheltenham identified rather than development spread west and east of the railway line which suggests development between Cheltenham and Bishops Cleeve. \nThe fact that at no point in the consultation document does the safeguarded land appear is particularly notable when the case being made by the County Council in respect of the M5 Junction 10 Improvements is on the basis of the future development of this land in the short term will contribute to the funding shortfall.\n\nDevelopment Scenario 3 Urban Extensions excluding Green Belt\nFor the reasons given above, the depiction of this option is fundamentally wrong. \nAs illustrated, this would imply no development adjacent to Cheltenham when in fact land was removed from the Green Belt and safeguarded for longer term development in the JCS. Paragraph 6.23 suggests this is not the case but again the associated diagram is misleading. \nIt is also of note that, in this scenario particularly, the option of accommodating development at Bishop’s Cleeve, which is beyond the Green Belt is not considered. Paragraph 6.22 suggests that this strategy would consider urban extensions to the main urban areas but to then exclude Bishop’s Cleeve as one of the Rural Service Centres from this option is wrong. This is especially the case when this option has the effect of concentrating development at the historic town of Tewkesbury with its associated flood risk and heritage constraints and at locations at the boundaries of the administrative areas which are already intended to receive new development.\n\nDevelopment Scenario 4 New Strategic Settlements \nA new Strategic Settlement has long been considered as a future development option but hitherto has never been found to perform better than a strategy based on urban concentration and expansion. The infrastructure requirements and delivery profile associated with one, let alone more than one, standalone new settlement mean that this is an option only in the longer term. Whilst this could conceivably be required over a thirty year horizon, this would do nothing to address the short and medium term needs that are a priority in any strategy that is chosen. \nThere are also practical issues of connecting to the main urban areas; no new settlement can reasonably be said to replicate the role or function of the existing principal urban areas. Thus, linkages via sustainable modes of travel will be required as a priority to provide regular and convenient access. \nIn the case of Ashchurch, which is the scheme with greatest status, access to and via the railway station is critically important. At the present time this is for the most part an hourly service to Cheltenham and the scope to improve the frequency of this in unknown but likely to be constrained by available running time on the track. Boddington is subject to extensive flood risk which inevitably constrains its capacity. Highnam, on the west side of Gloucester does not represent a location that would best meet the development needs of Cheltenham and is likely to result in higher commuting patterns between the two settlements. A new settlement is not a substitute to development of the Safeguarded Land. \n\nDevelopment Scenario 5 Rural Dispersal\nParagraph 6.28 of the consultation document illustrates the difficulties with this strategy and why it is not a credible proposition. Whilst Tewkesbury Borough is a rural area, it would be misguided to suggest that the development needs of the JCS area could be catered for almost universally in the Borough. Whilst rural housing is recognised in the NPPF, and there will need to be additional housing opportunities at the various tiers of settlements commensurate with their role and function, this scenario can only be considered alongside another scenario focused on development at the principal urban areas as a blended approach.\n\nDevelopment Scenario 6 Sustainable Transport\nAs a matter of principle and approach, a strategy which focused new development in locations along existing and potential high frequency public transport, walking and cycling routes is wholly appropriate. Logic dictates this will result in development focused in a similar fashion to the JCS; the strategic urban extensions and the safeguarded land were identified as locations suitable in this regard because of their proximity to existing urban areas and key destinations. In this regard the containment that Cheltenham exhibits is documented in the Local Transport Plan (LTP). \nThe LTP includes an ambition to see significant investment in mass public transport, for example in a rapid transit system between Gloucestershire’s main conurbations, and as well as strategic and local walking and cycling routes. Such measures are undoubtedly key to meeting Gloucestershire’s future mobility needs, but they are subject to further study to establish what is genuinely achievable and deliverable. There is plainly an objective to create stronger public transport and cycling routes from Tewkesbury, to Cheltenham (via Bishop’s Cleeve) and to Quedgeley south of Gloucester and there is a synergy between this and future development options. However, the timescales for delivering major linear projects such as this are likely to be challenging absent a plan led strategy to this effect. \n\nConclusions in relation to Spatial Strategy\nThe spatial strategy will need to find a blend between the various options. However, the foundation of this must be the existing Strategic Allocations, accepting that those come with significant infrastructure requirements that may need to be reimagined. \nThe consultation document appears at best to be ambivalent about the safeguarded land being part of the next strategy, whereas in fact what is likely to be required is an unequivocal commitment to that land being brought forward in order to assist with meeting the infrastructure burden that exists to deliver West Cheltenham. \nTo complement that urban focus, the needs of the rural parts of the plan area have development needs that also need to be met and this is best achieved by dispersing development in accordance with the role and function of settlements. \nIt is no coincidence that achieving these two strands, support a strategy based on movement corridors. "]
[null,null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","",{"$cut":{"chars":16421,"head":"I am writing on behalf of Bloor Homes and Persimmon Homes, who are the applicants and prospective developers of Elms Park, the overwhelming majority of the North West Cheltenham Strategic Allocation in the adopted Joint Core Strategy (JCS). Our representations concern principally the spatial strategy options which are discussed in the consultation document. We also comment on the Vision and Objectives and considerations relating to climate change. \n\nBackground \nThe JCS was adopted in 2018. Whilst it provides strategic planning policies for its three constituent parts for the period to 2031, there was an obligation on the local authorities to undertake an immediate review in respect of two parts – retail policies and housing provision. That obligation has not been met. Rather the Issues and Options consultation was first undertaken in 2018, with no other material progress in the intervening period. \nThe attempt to bring forward this new Local Plan is in the face of a number of difficulties that have arisen because of the JCS. The significance of these contextual points is unavoidable. \nAt Cheltenham, highway infrastructure needed to accommodate allocations made at the end of the JCS examination process is now substantially larger and strikingly more costly. This has created conditions that have delayed the delivery of longstanding and eminently suitable development. \nThe ambitious aspirations at the Golden Valley beyond the policy position in the JCS has hindered the delivery of North West Cheltenham. Delays through the planning process have also hampered delivery of other sites including Leckhampton. \nAt Tewkesbury, because its Borough Local Plan looked only to the housing requirement in the JCS, rather than the level indicated as necessary by the Government’s Standard Method, it has been unable to demonstrate the required amount of housing land supply. \nThe Junction 10 Improvements, required only once West of Cheltenham was added to the JCS, have still to materialise and the initial cost estimate of £46million is now some 6 times larger and substantial addition monies are required beyond the Housing Infrastructure Fund funds to deliver this. There is no certainty that will be realised.\nIt is in this context that the Strategic  Local Plan (SLP) is being prepared. These are matters that plainly cannot be resolved in the short or medium term. For example, there is a deficit against the JCS’ housing trajectory at North West Cheltenham and West Cheltenham of some 2000 new homes by the present time. In looking forward to the next plan period, that under provision cannot simply be ignored as it has manifestly contributed to the affordability difficulties that are described in the consultation document and widely experienced. \nThe consultation document refers to a vision for 15 – 20 years. In the context of the evident difficulties that exist a planning strategy covering a longer period of time is going to be necessary. This need arises for two reasons. \nFirstly, the task of preparing a new plan is no small matter and will take many years still regardless of intentions to move swiftly. The current JCS effectively took between 2008 and 2017 to prepare and it had the benefit of the earlier work undertaken as part of the Regional Spatial Strategy as to Areas of Search for future development; it is inescapable that the 2006 Section 4/4 advice from the County Council is the cornerstone of the JCS’ spatial strategy and most of its strategic allocations. \nSecondly, the ability to achieve the existing and future development needs will require a careful and considered approach to strategic planning and delivery. At Cheltenham the foundation of the SLP will need to be the existing North West Cheltenham strategic allocation given its many important facets. There is no alternative strategy that can conceivably replace that strategic allocation whilst achieving the various land use benefits that are to accrue from it and the sound spatial principles that unquestionably remain. \n\nVision and Objectives \nThe Vision and Objectives set out in th"}}]
["","Bloor Homes Western",20,"","","","","","","","","","Yes","","","","","","No","Every plan should seek to meet the full objectively assessed housing need in accordance with the requirements of the NPPF. The standard method provides only the minimum number of homes such that account needs to be taken of other factors such as previous levels of housing delivery, or previous assessments of need, economic and demographic considerations, and the needs of specific groups.\nThe annual housing need figure needs to ensure that it represents positive planning, is justified, and will be effective in meeting housing needs and addressing the local and national housing crisis and is consistent with national policy and guidance.\nIt is strongly recommended that the plan include for a greater number of homes (through increasing the housing requirement figure or allocating additional sites) to address problems in the delivery of new homes. This was recommended by the Inspectors who examined the adopted Joint Core Strategy (JCS). Given the significant problems in delivering the necessary growth identified in the adopted JCS the new Plan should make an even greater allowance this time around.\nThe current overall 20-year target of 35,700 new homes does not satisfy the above aims.\nThe need for urgent delivery of homes is underlined by the 2023 Cheltenham Housing Land Supply Position Statement identifying a supply of 4.84 years, the 2023 Tewkesbury Interim Housing Position 5Statement stating a supply of 3.24 years and the 2023 Gloucester Five Year Housing Land Supply Statement identifying 5.2 years.\nThe overall 20-year target of 35,700 is noted; however, it is considered that identification of adequate amounts of land does not guarantee its timely or eventual delivery.","","","","","","","","","","","","","","","","","","","","Scenario 1 ‘Urban concentration’ is supported in principle. The conversion or rebuilding of retail or other town centre properties into housing or mixed-use schemes is considered to be an appropriate way of enhancing both the quality and placemaking of an area, as well as helping to increase local housing supply. \nDespite the support in principle for Scenario 1, we are very concerned that this scenario alone would ‘not deliver sufficient new homes and jobs’ for three key reasons. First, the number of opportunities that are currently available is very limited. Secondly, the cost and often difficulty in redeveloping brownfield sites makes this option very uncertain. Thirdly, developing town centre building and/or retail premises often restricts the range of housing types, sizes and tenures. This often has consequences for the number of family homes and affordable homes being delivered. As a result, further scenarios are considered to be required to deliver the necessary housing over the appropriate plan period.\nScenario 2 ‘Urban extensions’ is supported and considered to be a good option for delivering housing in sustainable locations with existing infrastructure. It is fully agreed that this method can deliver a range of available sites that will enable the Council’s to meet their housing and economic needs in full. Further, urban extensions often provide a greater variety of homes to meet the local need, including family and affordable homes. Many of the potential urban extension parcels would include land without long-leases that would \notherwise hamper development timeframes. This means that sites can be delivered quickly and efficiently to create the new homes and jobs that are desperately needed. One of the identified benefits of this scenario is that ‘Development can be delivered close to where the need arises, reducing the likelihood of unnecessary travel into and out of the area.’ The importance of this benefit should not be understated, as it would create the context to support sustainable travel and would allow areas to self-sustain. In other words, they could thrive independent of outside intervention/local authority funding. This is partly dependent on sustainable travel being facilitated by improved public transport infrastructure. This also allows additions to urban areas to be made carefully, with an emphasis on placemaking. As identified as a benefit, this scenario would create the ‘Opportunity to enable sites to be 7comprehensively planned to incorporate social, economic and environmental infrastructure, e.g., everyday shops and services and open spaces.’\nScenario 3 ‘Urban extensions, avoiding the Green Belt’ is strongly supported. The current wording discredits the level of statutory protection that should also be afforded to the AONB. As such, it is considered that Scenario 3 should be ‘Urban extensions, avoiding the Green Belt and AONB’. Regardless of the above wording, the Council are right in their assessment to acknowledge the AONB and confirm that the combined restriction would only provide for a limited range of housing types, sizes and tenures and therefore not meet the required delivery rates. It is considered that whilst Scenario 3 has the ability to avoid Green Belt areas, this could be at the detriment of being located in more suitable and sustainable locations which are on transport corridors or near beneficial services. This overall negative of poor locational availability is considered to outweigh the perception of harm caused by the removal of land from within the Green Belt.\nThis scenario is particularly pertinent to the delivery of the necessary housing at Tewkesbury which is generally unconstrained by the Green Belt and AONB. It is considered to be by far the most sustainable scenario for the delivery of housing at this location.\nScenario 4 ‘New strategic settlement’ should only really be considered when all other opportunities have been exhausted. First and foremost, it is considered to be better to locate development where it will support existing services and facilities.\nSecondly are the concerns associated with new settlements: \n• The costs for the delivery of new infrastructure can have significant impacts on overall viability. This can result in the delivery of sub-standard infrastructure and supporting services, limited affordable housing, or even a scheme that cannot progress.\n• Large schemes take a significant amount of time to develop masterplans and work through the planning and political frameworks. If then approved, time is required for infrastructure delivery before any homes or employment sites can come forward. \n• New settlements have limited benefits for existing residents, with new homes being located away from existing jobs and populations being taken away from existing business that depend on local footfall for their economic success.\nGiven the collective lack of housing land supply for Cheltenham, Tewkesbury and Gloucester, and the time delays associated with new settlements, it is considered that any overreliance on Scenario 4 could result in long-term harm to the SLP being able to adequately direct where development should be located.\nScenario 5 ‘Rural Dispersal’ is supported in principle.\nDevelopment in rural areas is important for the growth and longevity of smaller settlements. However, the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan should focus its housing allocations in larger, more sustainable settlements which have better infrastructure provision and proximity to Tewkesbury, Cheltenham and Gloucester.\nScenario 6 ‘Sustainable transport scenario’ is supported due to the limited infrastructure costs associated but only applies to Cheltenham and Gloucester. This scenario would ensure that development can be promoted that encourages the reduction in use of private vehicles and supports a movement towards walking and cycling. It is noted that this scenario is not considered to be independent of other scenarios and in appropriate locations would work alongside scenarios 1, 2 and 3. In fact, we would argue that the best location for this approach is at sites on the edge of the three main settlements.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","[Q1.] It is not unacceptable for the Plan period to cover a 15-year period albeit the 15 years should start from the point of adoption. Notwithstanding this, given the area’s constraints, previous and current problems in the delivery of the necessary growth and to provide certainty on the release of the Green Belt we would recommend the new Plan looks forward over a longer timeframe of say 20 years.\n[Q8.] We support the proposed 10% Biodiversity Net Gain requirement as it is in line with future legislation and national policy. It’s impact on the viability of new development will need to be factored in when determining all factors affecting the delivery of new development across all parts of the Plan area. \n\nSummary\nIn summary we consider that a hybrid of some of the above scenarios is the most sustainable option available. Of all the scenarios, Scenario 3 is considered to the represent the most sustainable form of development. It represents a particularly sustainable form of development for Tewkesbury. It is however acknowledged that the scenario would not deliver the quantity of growth required and therefore would need to include a number of the other scenarios. Scenario 3, when the AONB is included, would also result in a small number of available sites for significant development contributions. The above comments consider that there are a number of beneficial scenarios being proposed, with a mixture of pros and cons for all. It is however considered whilst Scenarios 1 and 5 would not be capable of delivering sufficient levels of development to meet required targets but should clearly be included in the overall strategy. Scenario 6 is discounted on the basis that this ambition should be supported for all scenarios being proposed."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I am a resident of Up Hatherley, having moved from central Cheltenham six years ago. I wish to register an objection to the current SLP.\nIn taking personal responsibility for my wellbeing and health, I have adopted a routine of walking each day for one hour before work, one hour at lunchtime and one hour after work. My routes usually take in the Chargrove Lane beauty spot.\nThe benefits I gain from this are many:\nPhysical - over 100k per week, providing a countermeasure to obesity, building stamina, and maintaining flexibility in hips, knees, ankles etc. I am a fit 62 year old thanks to this regime.\nMental - I work from home in a mentally demanding, but sedentary in a global corporate company. My interactions with others are on-line, I have never met most of the people in my team face-to-face. Over the years my daily walks give me vital personal interaction with a community of regular users of this accessible green space.\nI am so lucky to have such a wonderful recreational space so close to my home, accessible without the need to use a car to get to the start of my walk. The panoramic views of the Cotswold Escarpment are a delight, regardless of the season. The wildlife, particularly deer and a variety of birds, provides something different to see each day. The calling of the lambs in the fields signals the impending arrival of Spring.\nTo hear that this beauty spot is potentially to be developed for housing is hugely concerning. Chargrove Lane and the surrounding green space is accessible to thousands of local people. Pushing the Green Belt out any further would make this type of healthy recreation impossible for the residents of Hatherley and Shurdington. It is difficult to even identify anywhere else that is safe for walkers in the way Chargrove Lane is.\nI would urge the SLP Team to consider an exception for the Chargrove Lane and surrounding fields, based on the accessibility of this recreational green space with outstanding views, and to protect it for future generations."]
["Planning agent or developer","Brockeridge Business Park",30,"","","No","The Draft Vision on page 13 of the SLP consultation document is noted and we consider an amendment is necessary to change the 2041 plan end-date to at least 2046 (see our response to question 1). \nFurther it must be recognised that the needs of the SLP authorities should be met in full: “People’s housing needs will have been met in full through the provision of sustainable, high-quality market, affordable and other specialist homes set in beautiful, safe places and conforming to sustainable standards of design and construction.” \nSimilar emphasis should be placed on meeting people’s needs for employment. Whatever the level of employment need identified in the SLP, the vision and economic policies should provide a clear development plan strategy to ensure the full employment needs are planned for through allocations. Reflections on the current adopted JCS demonstrated that employment development needs to be proactively planned. The SLP should therefore ensure sufficient allocations are made to deliver the full needs for employment as well as housing.","","","","","","","","","","","","","","","","","","","","","The SLP should reflect on the ineffective JCS and Borough Local Plan in terms of not proactively planning for the full employment requirement for the plan period, rather than repeating a policy framework which does not make allowance for supporting unallocated windfall employment development opportunities on a variety of scales. \nThe recent delivery of employment development lagging far behind the JCS requirement further highlights that to ensure an effective set of SLP policies for employment and economic growth, the SLP should plan for the employment requirement through a comprehensive set of allocations. In addition, a broader variety of employment opportunities should be explored, avoiding overreliance on strategic urban extensions to deliver the bulk of employment needs, whereby the employment delivery is protracted.","The SLP should provide a positive set of policies which clearly support the expansion of existing employment sites and businesses, where economic growth opportunities and synergies can be best realised. The SLP should look for opportunities to unlock employment growth opportunities which are not hindered by strategic infrastructure delivery. This will help address the current shortfall of new employment against identified needs.","The SLP should recognise that employment growth requires greater flexibility that planned residential development. Much employment growth is traditionally planned alongside strategic scale residential developments such as urban extensions. Beyond that however, there is a need to provide a policy framework which enables employment growth to come forward in isolation, including in more rural environments where prospects for employment growth can benefit from a land market which is not competing with residential land values. The suite of employment policies should therefore afford a degree of flexibility to support new opportunities for employment growth on a windfall basis, including in rural locations where it can be demonstrated that the benefits of economic development outweigh any environmental impacts.","","","","","","","","","No","With regard to scenario 4: new settlement, the long lead-in times associated with this strategy are identified. However, the implications and risks of this should not be underestimated. New settlements by their nature will require significantly longer lead-in times than other strategic growth options, such as urban extensions, due to their higher infrastructure burdens. The problems of this approach with the SLP would be exacerbated by its relatively short plan period (see our responses to questions 1 and 4) meaning the vast majority of new housing which could be accommodated from a new settlement is likely to fall beyond the current plan period. \nIn respect of employment development, there is merit in all of the spatial scenarios identified to varying degrees, but it is readily apparent that a blended approach of the scenarios is required to support the necessary levels of economic development and to distribute the promotion of economic development across the SLP area.","Scenario 6: Sustainable transport scenario","","","[Q1.] \nAs is recognised in the SLP (para. 2.8) the Government requires a plan to cover a period of at least 15 years from the point of adoption. Where the plan includes larger sites that will take longer to develop, the vision and policies can look further ahead to at least 30 years. The current timetable for the SLP is for submission to the Secretary of State in April 2026. On this basis, the SLP is proposed to plan up to at least 2041. \nNPPF Paragraph 22 emphasises this 15-year period is a minimum from adoption. The reference to at least 30-year period is encouraged where there are new settlements or significant urban extensions. At this stage, the SLP outlines a wide range of spatial growth options including urban extensions and new strategic settlements. If these elements were to form part of the Regulation 19 strategy, then a component of longer-term planning would be required. This underlines the critical importance of the 15-year period from adoption dictated by the NPPF being an absolute minimum. \nThe current SLP timetable assumes submission to the Secretary of State in April 2026, this in itself is an optimistic timeframe given the Joint Core Strategy (JCS) took a period of over four years from Regulation 18 stage to submission to the Secretary of State and then a subsequent three years to adoption ('JCS Part 1' public consultation in June to August 2010; Submission to the Planning Inspectorate in November 2014 and, adoption December 2017). On the basis of this past performance and the political coordination required, a conservative adoption date would be mid-2031 and thus a plan period to 2046 would ensure the minimum 15-year period is allowed for.\n[Q7.]\nChanges to Building Regulations and their continued refinement to drive forward high standards of design, construction, energy efficiency and carbon reduction effectively enables the industry to respond in a consistent manner across the country. Individual local planning authorities should thus heed caution on creating bespoke standards which would provide a patchwork of differing local standards creating confusion, duplication, misunderstanding, misalignment and policy conflict. \nThe principle of avoiding such a patchwork of differing standards on issues that are effectively the same at a national level is recognised in the ambition behind the Government brining forward national development management policies. The Consultation Outcome on the Levelling-up and Regeneration Bill: reforms to national planning policy (19 December 2023) states: “Small builders in particular struggle to follow multiple different detailed local plan policies on the same issues, making it harder to build within different local authority areas” (Chapter 10: para 10: fourth bullet). \nA recent Written Ministerial Statement set out the following explanation: \n“The improvement in standards already in force, alongside the ones which are due in 2025, demonstrates the Government’s commitment to ensuring new properties have a much lower impact on the environment in the future. In this context, the Government does not expect planmakers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale that ensures:\n- That development remains viable, and the impact on housing supply and affordability is considered in accordance with the National Planning Policy Framework. \n- The additional requirement is expressed as a percentage uplift of a dwelling’s Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP). \nWhere plan policies go beyond current or planned building regulations, those polices should be applied flexibly to decisions on planning applications and appeals where the applicant can demonstrate that meeting the higher standards is not technically feasible, in relation to the availability of appropriate local energy infrastructure (for example adequate existing and planned grid connections) and access to adequate supply chains”.\n[Q8.]\nThe implementation of Biodiversity Net Gain objections through planning policy should have regard to viability implications particularly given the legal requirement for landowners to manage BNG habitats for a minimum 30 year period. Off-site BNG would result in the purchase of off-site units the cost of which also need to reflect this 30-year management requirement. As such, the provision of even 10% BNG on strategic scale sites is likely to have a significant financial implication and raise viability issues. Any alternative to the now mandatory 10% BNG requirement must be subject to \nrobust scrutiny through viability appraisals and where viability constraints arise a considered review must be had of differing strategic objectives e.g. the need to deliver a suitable quantum of affordable housing with market led schemes.\nThe Planning Practice Guidance (PPG) was updated in February 2024 in relation to BNG and is clear that:\n“Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented”. \n[Q29.]\nMarket and economic evidence, including that provided by the LEP demonstrates that the Sustainable Transport Scenario is best aligned for delivery of economic/employment development. However, this scenario should recognise the role of the M50 in Tewkesbury Borough and its consistency with the established strategy for economic growth along the M5 corridor."]
[null,null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Regarding the proposed development for 1793 houses and a further 417 at Oak Farm Chargrove Lane we strongly object.\nThis is a special area currently in the green belt and should be protected for the nature, habitat, trees and hedgerows providing a healthy environment for walking, jogging and cycling whilst enjoying the open countryside in safety which is priceless. This would all be destroyed forever by people only interested in profit.\nWith the increase in traffic it would create serious impact on the area and the Shurdington road would struggle with the extra volume causing chaos and disruption.\nWe have lived in Chargrove Lane for forty three years and would be very sad to see the devastation it would cause to the environment.\nPlease consider the impact it will have if this proposal is approved."]
["Resident",null,"","","","No","The draft vision is far too focussed on the needs and wants of people. People are simply part of a wider ecosystem and the SLP must pay due attention to that. The focus needs to place the environment at the centre of any policy. There is insufficient detail in the vision on aspects such as nature recovery for example. ","","","The councils involved in the SLP must declare both a climate and nature emergency. Declaring a nature emergency demonstrates that councils know that wildlife is in trouble and that they have a responsibility to do something about it. Declaring a nature emergency motivates councils to take action. It can also attract new funding and ensure that everyone in the council area understands why nature is important. \nA declaration like this also leads to nature being considered in all activities that the Council does. It acknowledges the needs of people and nature to be in balance. It’s the first step to making sure Local Authorities are working to bring nature back","All new buildings should be required to have either rooftop solar panels and/or air or ground-source heating as feasible. There should be no large scale solar infrastructure on green-field sites. ","","Yes","","","","Yes","Energy generation and storage is best done at a local level. All new building should be required to install rooftop solar panels, air or ground-source pumps as feasible. There may be some brownfield (previously developed) sites which could be suitable for energy generation/storage. These would need to be carefully assessed on their suitability. Greenfield sites should not be used. ","","There appears to be no explanation as to how this calculation is made. I am alarmed at the number of houses which apparently need to be built. ","Yes","I emphasise again that Gloucestershire is essentially a rural county. It is very important that we retain and safeguard the rural nature of the Gloucestershire countryside as it has been for centuries, alongside making improvements to the way it is managed to increase biodiversity net gain.","Yes","There is definitely a need for more affordable housing. There should be severe restrictions on the ability of people to buy second homes in the county. Many of our small villages and towns like Winchcombe, for example, have high numbers of second/holiday homes which stand empty for large parts of the year. We need to ensure existing housing stock is lived in rather than building new housing.\nCPRE (The Countryside Charity) has long led calls on the government to introduce a second home and short-term lets register, with local authorities having the power to regulate the provision of them. Their analysis of data on properties on Airbnb and similar sites shows that a massive 148,000 homes that could have otherwise been used as homes by local families were instead put up on short-term and holiday lets.\n‘There simply has to be a government response to the fact that our rural housing supply is disappearing into an unregulated short-term rentals market that simply didn’t exist six years ago.’ We’re calling for tighter controls on second home ownership, including higher council tax on second homes and the requirement for short term lets to have planning permission. (Source: CPRE Nov 2023)","","","","","","","More emphasis on urban renewal, including housing in town centres","","","","The rural way of life is deeply important to people and must be preserved. Only very small scale development should be considered in rural settlements. It would be helpful to have a small shop/post office located in some of our larger villages, which could then serve other smaller villages nearby. \nAccess to some form of public transport  could be useful. \nSuper-fast broadband is an essential tool for the majority of rural homes now. ","","","","","","","","","Response to the Strategic and Local Plan\n\nDear Sir/Ms,\nAlthough I have made an online response, the nature of the questions and requirement for yes/no answers actually made it very difficult for me to fully express what I wanted to say. Please find a summary of my concerns and opinions in the response below. \n\n[Draft Vision and Strategic Objectives]\nMy overriding concern in my response to this consultation is the impact of any proposals on the environment. \nGloucestershire is, at its core, a rural county. It is very important to me that we retain and safeguard the rural nature of the Gloucestershire countryside. \n\n[Planning for climate change and nature recovery]\nThe climate and ecological crises are inextricably linked and we must address them both together. Climate change is driving nature’s decline and the loss of wildlife and wild places is leaving us ill-equipped to reduce carbon emissions and respond to climate change. \nThe SLP is essentially about development but it must recognise that the biggest single driver of biodiversity loss is the destruction of natural habitat.\n\n[Q8.] \nEmphatically yes. The UK is one of the most nature-depleted countries in the world. According to the State of Nature report 2023 species have declined by 19%. In Gloucestershire we have already lost 70% of traditional orchards and only 1.5% wildflower-rich meadows remain. It is the duty of the three councils to ensure that the decline in nature is halted and reversed.\n\n[Q29.]\nI note that paragraph 5:20 states that ‘It is important to note that the sites allocated for development in the JCS, district plans, and other sites with planning permission will deliver new homes in the new timeframe for the Plan (the JCS and district plans covering up to 2031). This includes large sites that have planning permission and are delivering new homes at Twigworth, Innsworth, Brockworth and Churchdown. A large number of homes required are therefore already accounted for’ (Italics mine)\nThis being the case, I would favour urban densification. \n•\tMore people living in and using shops, services and facilities in the main city and town centres. \n•\tBringing more life and vitality to the city and town centres, including at night. \n•\tConcentrated development in urban areas, supporting use of bus and rail, walking, cycling and car clubs. \n•\tSupports maximum use of ‘previously developed land’ and urban regeneration. \n•\tProtects the existing Green Belt and minimises the loss of greenfield sites and higher quality agricultural land. \nWe must hand England’s green and pleasant land onto the next generation. The countryside needs to be cared for and cherished, not built over."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","We were dismayed to see that the field behind Ratcliff Lawns in Southam has been identified as a possible site for development. SOU006. We would like to highlight the damage that developing this field would do to the environment and wildlife. It would create a loss of important wildlife habitats. Many insects, including bees are in decline and this development would further add to their demise. It would have a detrimental affect on the food chain that has been built up  in this area for generations. At the moment there is a variety of birds, including birds of prey and many small birds whose numbers are decreasing, ( e.g. hedge and tree sparrows,  green finches) who depend on this land.  They frequent the field and the hedges surrounding.  Bats and the recently returned hedgehogs would also be in danger as well as other small mammals. Using this site for development will be totally in conflict  with the character of the area. It will be visually damaging in the landscape. It will be destroying traditional field patterns and add to a further loss of high quality agricultural land. Where so much of our landscape is being destroyed and developed surely we should be preserving this area of special landscape interest that is bordering on the area of outstanding natural beauty? How long will it be before that area is also eaten into? Where will each village begin and end? They will just end up merging into one huge development! What green spaces are we leaving behind for our grandchildren and future generations. It might be beneficial to look at documents from 2017. Appeal Ref: APP/G1630/W/16/3165534 Land rear of Dormans, Mill Lane, Prestbury, Cheltenham, Gloucestershire. This development was rejected for many of the points I have made above. Surely these points are even more relevant for future plans for Southam? Especially as Bishops Cleeve has grown so much over the last 5 years and residents are going to want green spaces in which to exercise, explore the wildlife and enjoy. May I also point out that there could easily be damage to the water table and drainage. I understand that in 2007 Bishops Cleeve was flooded. Southam didn’t. More recently the lower part of Southam Lane, after heavy rainfall, often floods with water covering the road. We need the land on the slopes of Cleeve Hill so that the water table won’t be further upset in this time of climate change. We hope you will take these issues into consideration when decisions are made."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I am concerned about the possibility of housing developments at White House Farm , Churchdown Ref CHU024 which may consist of 650 to 850 houses. This site is totally unsuitable for a housing estate because….. 1. It is extremely close to the M5 motorway . The level of noise and pollution for housing and schools is unacceptable. The pollution doesn’t just come from exhaust fumes but also dust from break linings and tyre wear which can cause lung irritation. 2. There is a risk of flooding on the lower areas. 3. The access into/out of the site is dangerous. The speed of vehicles travelling along Brookfield Road over the motorway bridge is excessive. The narrow Brockworth road cannot cope with large amounts of traffic, which will then filter through the narrow twisty roads and roundabouts in Brockworth. 4. The proposed number of houses implies that there could be 1,000 cars to enter/exit the estate through two entrances onto narrow and fast roads. There does not appear to be any other access routes into this site. 5. Brookfield Road is a complete bottleneck around Chosen Hill school particularly at pupils entrance and exit times. Extra cars on this road will be a nightmare. Equally, the feeder roads along Albermarle road, Brookfield Road, Oldbury Orchard, Paynes pitch etc are narrow twisty roads which are unsuitable for high volumes of traffic. 6. The railway bridge on Badgeworth road is weak and already restricted to single file traffic. Extra traffic along this road and Badgeworth and Shurdington road is not desirable. 7. The schools in Churchdown are already over subscribed. Where are the children from this estate go to school ?  There was a previous plan to build a new infant or junior school on this site adjacent to the motorway. What a ridiculous suggestion, with all the noise and pollution from the vehicles. There will be legal claims for damaged lungs and impaired hearing from parents of these children in the future. 8. Churchdown and Innsworth have  seen considerable housing developments over the last few years to such an extent that the Doctors and Dentists cannot take any more patients. The schools are overloaded , so where are the services to support more people ? 9. Bus services do not run down Brockworth road. 10. Are the sewage services suitable such a low-lying area of land ?  Of the 200 + sites identified in the TBC ‘call for sites’ , there are many more ideally suitable sites to build houses on than on White House farm. Developing this site will be inappropriate , totally unsuitable and unnecessary. Please take these points into consideration."]
["Statutory/Specific Consultee","Minsterworth Parish Council","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","At our Parish Council meeting on Monday 12th March, Minsterworth PC would like the following issues to be considered  in the longer term planning in relation to  the SLP. 1. Reducing congestion on the A40, for example by building another carriageway from the Over roundabout to the Longford roundabout (making a dual carriageway), and/or by constructing an additional Severn crossing from the Minsterworth area to connect to M5 junction 12 at Hardwicke. 2. Flood reduction, both from the River Severn, and from the run off that flows under the A40 from adjacent parishes into the currently overloaded drainage system of Minsterworth. 3. A mains sewage system for Minsterworth. We have concerns over the big expansion of our village without mains drainage. 4. Improvements to A48 safety through Minsterworth, including speed reduction and additional safe crossing points to allow residents more easy access to public transport.","","","","","","","","","","",""]
["","",20,"River pollution and management. Ensure community sports facilities are included in housing plans. Building on rural land near existing rural communities adversely affects the rural balance in these areas. People who chose to live in rural communities do not want their choice of a rural environment to be taken away.","Highnam and Churcham communities are potentially under threat by the proposed possible areas of development. With the recent approval of a further housing development opposite Highnam golf course, the number of new houses in the existing Highnam neighbourhood plan has been exceeded and would negatively impact on and alter the natural environment and character of the village, in contradiction to the SLP objectives and vision.","","Overall yes. It is mightily ambitious which it needs to be, but I wonder how, in reality it can be delivered to the quality proposed. To succeed, I consider that all elements of the vision must be considered together so that there is a cohesive approach to the execution of the vision and a quality to living and working across the SLP areas. I consider that paragraph 3.3 (h) Putting ‘placemaking’ at the heart of development and securing high quality design and respecting the character of our existing communities and the surrounding landscape’  should be at the heart and an overarching tenet of the strategy. ","Yes","","By not building on flood plains, building sustainable and environmentally friendly housing and offering sustainable public transport (buses) and cycle lanes.","There is a massive tension here; The plan speaks of quality and beauty in new housing, but so much will need to be affordable, which is usually neither beautiful or of quality. If we add in the absolutely necessary requirements for new homes to be environmentally friendly, this will sadly further deplete resources and de-incentivise builders who will be reluctant to reduce profit margins and therefore, potentially put the kybosh on considerations for beauty or quality of build. This tension and very real conflict needs to be addressed candidly and head on for the SLP and whether this is in fact possible?","Incentives and grants to develop brownfield sites and existing buildings and to enhance them to be living spaces eg for increasing thermal efficiency","","","","GP surgeries, transport, schools, community sporting and leisure facilities access to a shop(s)","Yes","Ideally, yes, but I am not sufficiently knowledgeable to know what would be most appropriate. Include solar panels to be fitted to all new houses as standard. ","No","I think this should be calculated by a genuine and thorough appraisal of the anticipated current and future demographics of the SLP areas considered alongside the plans for economic and employment for the SLP area. NOTE: Paragraph 5.16 states that there is a need for 35,700 new homes required over the plan period and yet the opening statement in the consultation document it states: ‘The population of the area is growing; it is forecast that an additional 23,000 families will form and make the area their home over the next 20 years’ I recognise that not all houses will need to be for families, but these numbers differ significantly. How is the figure of 35,700 houses arrived at?","Yes","See above – if the employment opportunities increase or reduce  in the area for the plan period, more or less housing may be required.","","","No","","Small sites seem to work better in terms of being better kept and fitting in","","Reasonable rental for commercial units. Good access (transport /road infrastructure) to employment sources.","Affordable housing in rural communities that meets the SLP draft strategic objectives. Enhanced transport – people living in rural communities are often cut off from public transport and car insurance costs etc are often prohibitive for young people  to be able to afford a car and therefore to be able to take up job opportunities locally (rurally) or in local towns and beyond.","Good transport links and cycle routes. Accessible and free/low cost parking. Tax incentives for new businesses. Clean streets. Sustainable brown field development of unused buildings for housing. This would in turn encourage further brown filed investment for shops, eateries and entertainment in town centres.","Encourage local communities to work together to develop such facilities, if there is a need.","Ensuring capacity of existing roads, decent transport systems and routes, schools, health facilities, sporting/leisure facilities and water sewage systems.  ","Road networks able to support the new capacity. Sustainable development and transport. Environmentally friendly housing. GP Surgeries/health facilities. Schools. Community and sporting facilities. Water and sewage systems  to support the development. I note that one of the new settlements proposed is between Highnam and Churcham straddling the A40. A proportion of this land is in the Forest of Dean District Council area, being in the same location as the site previously proposed by Forest of Dean District Council for a new town in their local plan in 2020 and which was resolutely dismissed by Forest of Dean residents and the Council for a whole raft of evidenced and documented reasons. I understand that this evidence will be included in the response to this consultation from the Forest of Dean Council. A new town in this area (straddling the A40) is not proposed in the new Forest of Dean local plan and, I firmly believe, should not be included as part of the SLP.  Please be aware that by far the vast majority of Forest of Dean residents (a)\twill not be aware that this is a proposal by the Cheltenham, Gloucester and Tewkesbury SLP, (b)\twill not have had the opportunity to respond to this consultation and; (c)\twill not, therefore, have been part of the democratic process for a decision that may potentially affect their district.","Excellent transport routes.","","","","No","I note that one of the new settlements proposed is between Highnam and Churcham straddling the A40. A proportion of this land is in the Forest of Dean District Council area, being in the same location as the site previously proposed by Forest of Dean District Council for a new town in their local plan in 2020 and which was resolutely dismissed by Forest of Dean residents and the Council for a whole raft of evidenced and documented reasons. I understand that this evidence will be included in the response to this consultation from the Forest of Dean Council. A new town in this area (straddling the A40) is not proposed in the new Forest of Dean local plan and, I firmly believe, should not be included as part of the SLP.  Please be aware that by far the vast majority of Forest of Dean residents (d)\twill not be aware that this is a proposal by the Cheltenham, Gloucester and Tewkesbury SLP (e)\twill not have had the opportunity to respond to this consultation and; (f)\twill not, therefore, have been part of the democratic process for a decision that may potentially affect their district. I consider that paragraph 3.3 (h) of the SLP vision:  Putting ‘placemaking’ at the heart of development and securing high quality design and respecting the character of our existing communities and the surrounding landscape’  should be at the heart and an overarching tenet of the strategy. ","","","","The SLP should consider brownfield sites that become available. Anyn development should be sympathetic to the character of the town. Please remember some people living rurally are happy with that existing settlement (that’s why they live there) and positively do not want interference from councils to change the character of the place they are in. ie: people live in rural places because they are rural. Not everyone wants a local shop/bowling alley/shopping centre/supermarket etc. I would be strongly against building on the areas in Hghnam HIG007 and HIG013 (Monkey Back Hill) for the following reasons: •\tThe public footpath across the hill is part of a longer pathway from the village, providing pleasure, exercise and mental wellbeing to many Highnam residents. •\tBuilding on Monkey Back Hill would deprive residents of a beautiful natural asset and would be detrimental to their mental and physical health by curtailing their opportunities to get out into the natural environment. Any building would alter the character of the village. Please refer back to the draft strategic objectives statement in the consultation document as follows as the basis for any development in the SLP area: \n1.Supporting the creation of high quality, beautiful and sustainable buildings and places through good design.\n2. Ensuring that new development is integrated well with existing communities and providing well-located infrastructure which meets the needs of communities; \n3. Creating a strong sense of place through high quality and inclusive design that respects and enhances local distinctiveness. I consider that paragraph 3.3 (h) of the SLP vision:  Putting ‘placemaking’ at the heart of development and securing high quality design and respecting the character of our existing communities and the surrounding landscape’  should be at the heart and an overarching tenet of the strategy."]
["Resident","",20,"","Any proposed housing development west of Gloucester will have a significant adverse effect upon the already congested A40 where it crosses the River Severn at Over Roundabout. This road cannot take any more traffic without causing more traffic congestion, associated air pollution and increased delays for the emergency services to respond to incidents and transport patients to A&E. Any proposed housing developments need to appropriately consider and implement mitigation factors for increased surface water drainage run-off and the resulting flooding to the River Severn flood plain; especially during periods of extended rainfall as has been seen this winter and which is predicted to increase due to climate change.","","","","","By reducing traffic volumes with appropriate planning of sustainable transport, the considered location of infrastructure and local services and stringently ensuring future housing and business development complies with the strictest environmental criteria.","Town or city centre housing development must utilise centralised services such as heating and power distribution networks to","","","","","Transport, schools, nurseries, healthcare, playgrounds, open space, retail outlets, access to major environmentally friendly national transport networks, etc.","","","","","","","Yes","Affordable housing should be the number one priority for the strategic plan to consider, to allow young people and emergency workers the opportunity to get onto the housing ladder and thereby promote communities which want to invest in their locality and local businesses. The development of more 4-bed detached housing estates in rural areas does nothing to help these groups of people.","","","","","","","A high level review needs to be undertaken that provides a vision of how our city and town centres will evolve to enable smaller local developments to prosper from the overall vision, rather than piecemeal planning on a macro level.","A review of business rates and incentives to encourage new businesses and retain existing services should be incorporated in the planning process.","Transport, schools, nurseries, healthcare, playgrounds, open space, retail outlets, access to major environmentally friendly national transport networks, etc.","Transport, schools, nurseries, healthcare, playgrounds, open space, retail outlets, access to major environmentally friendly national transport networks, etc","There needs to be adequate facilities provided BEFORE the construction of new homes is considered, to prevent unnecessary additional car journeys to/from doctors, nurseries, schools and retail establishments. It occurs all too often that these facilities are promised by developers but never materialise after the completion of the development for various spurious reasons. A much more stringent oversight of any future development needs to be undertaken by the local councils.","Yes","","","","The pros and cons are generally a fair assessment, but it is difficult to accept either as being completely correct as numerous items are listed in each category. It would have been more appropriate if a yes/no option was available for each statement so that a more accurate response could be provided from each responder and therefore a more accurate assessment achieved.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","","","[Q1] The Strategic Local Plan should be developed for a 20-year period, with an optional review set at year 15 to enable changes to be implemented if government policy or overriding environmental considerations dictate. \n[Q26] Yes, these sites could be for future sustainable transport such as tram routes, cycleways, long distance footpaths and canal routes. All of which will enhance the environment for local residents and reduce traffic congestion and air/noise pollution. \n[Q29] Emphasis should be placed on utilising brownfield sites rather than green belt or agricultural land for future housing or infrastructure development. A combination of Scenarios 1 and 2, with consideration for Scenario 6 are in my opinion the best combination to provide what is trying to be achieved with the minimal adverse impact to the environment and adjoining countryside. \nThe Housing and Economic Land Availability Assessment (HELAA) and Call For Sites Initiative: It was understood that proper town and country planning looked at future needs, trends and visions rather than taking an opportunistic approach to site allocation for development as appears to be the case now. Whilst the consultation states that: “the HELAA has no planning weight and does not in itself determine which sites should be granted planning consent”, this is exactly what it appears to be doing. By collecting together, a pot pourri of sites put forward sporadically by landowners and developers in recent years, many of which have no intrinsic development potential or merit, creates a strong impression, certainly to the lay person, that this is a foregone conclusion. This is compounded by the detailed assessments which underpin each site where indicative potential housing numbers have been cited; where broad assessments of development potential have been undertaken; and where a rating of development suitability has been accorded to each site. This has inevitably focused attention too prematurely on micro site related issues and flies in the face of effective forward planning which this whole exercise purports to do. It is my opinion that this whole part of the exercise should not have been undertaken at this stage but left until the broad strategic framework for future development had been completed at which point general localities for future development could be properly identified and assessed irrespective as to whether individual sites had been previously put forward or not."]
["Planning agent or developer","Tetlow King",15,"","","Yes","The SWHAPC supports the Draft Vision provided on page 13 of the SLP consultation document and welcomes the best possible use of brownfield sites for new development. We also support the release of Green Belt where appropriate to meet housing needs.","Yes","","The SWHAPC broadly supports the suggestions outlined at paragraph 4.15 of the consultation document which includes a table that sets out some of the policy actions that the SLP might consider implementing to mitigate and adapt to climate change. The SWHAPC agrees that tackling issues such as the climate change mitigation and adaptation should be prioritised, although rigid climate change policies that have the potential to frustrate the delivery of affordable housing should be avoided. This importance was underlined in the December 2023 Written Ministerial Statement on energy efficiency and environmental standards, where it was suggested that local authorities should not be setting their own standards.","","","No","","","The SWHAPC encourages the development of housing within proximity to key services and facilities. It is crucial that new housing is placed within easy reach of transportation links, employment opportunities and health facilities. The SWHAPC would like to emphasise the importance of the creation of place in delivering effective and sustainable communities.","","","","The SWHAPC notes that paragraph 5.15 and 5.16 of the consultation document outlines that the standard method will be used to calculate housing need for the Local Plan’s duration. At first observation, this is an appropriate methodology for establishing the areas’ housing requirement, as set out in the NPPF and NPPG. The local authorities should look to meet the housing need set out by the standard method as a minimum given that it uses a formula to identify the minimum number of homes expected to be planned for, in a way which addresses projected household growth and historic under-supply. However, it would be appropriate to consider whether actual housing need is higher than the standard method indicates; if circumstances warrant an alternative approach then the local authorities must fully justify their methodology.","","If the standard method housing requirement figure of 35,700 over a 20-year period is taken forward, the SWHAPC strongly advises that this figure should be presented as a minimum housing need in the SLP. This will help to maximise opportunities for affordable housing delivery and meet objectively identified needs over the plan period.","Yes","The types, sizes and tenures of housing that the SLP should plan for should be robustly justified using an up-to-date housing needs assessment. Paragraph 63 of the NPPF requires that the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies. Paragraph 63 further states that these groups “should include (but are not limited to) those who require affordable housing; families with children; older people (including those who require retirement housing, housing-with-care and care homes); students; people with disabilities; service families; travellers; people who rent their homes and people wishing to commission or build their own homes.” The NPPF definition for affordable housing was revised in 2018 to include a wider array of affordable housing tenures in order to meet a diverse range of needs. Future affordable housing tenure mix policy should consider this full range of tenures and should be flexible enough to allow applications to respond to changing local needs throughout the plan period.","","","","","","","","The SWHAPC encourages the Council to allow rural development where it is shown there is an identified need, including affordable need. The delivery of new homes in rural areas will help to ensure that people can move to or continue to stay in the area which in turn will help to sustain rural services and facilities. Delivering new affordable homes in rural areas is especially important in retaining young people in the area who would otherwise be forced to move to urban areas to find affordable housing.","","","The SWHAPC consider suitable transport links to be of upmost importance when deciding whether a location is suitable for new homes and other forms of development. If a rural location offers no other alternative suitable means of transport other than a car, then there is a risk of residents becoming isolated if they do not own their own car.","","","","","","Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","[Q1] The current timetable for the Strategic and Local Plan (SLP) is for submission to the Secretary of State in April 2026. The latest Local Development Scheme 2023-2026 (July 2023) does not set out when adoption is anticipated. As recognised at paragraph 2.8 of the consultation document, the SLP would need to plan up for at least a minimum 15-year time horizon from adoption so that it is in accordance with the NPPF. \n[Q8] Paragraph 4.17 of the consultation document alludes to the possibility of the Local Plan requiring more than the 10% BNG requirement stated by the Environment Act. If the Council is looking to introduce a higher threshold than 10%, this must be robustly viability tested to show that it will be viable for applicants to provide such BNG alongside development. Currently, the SHWAPC disagrees that a higher than a 10% requirement for BNG should be sought as there is significant concern that an increased biodiversity net gain requirement may reduce the delivery of affordable housing across the authorities. \n[Q29] The SWHAPC recognises the advantages and disadvantages of each development scenario. We encourage the Council to progress a strategy that will enable the delivery of a sufficient level of affordable housing in the right places and to meet authority wide and locally identified needs. Given this perspective, at this point in time the SWHAPC cannot show support for Scenario 1 (Urban concentration) as it “would not deliver sufficient new homes and jobs” and “would only provide for a limited range of housing types, sizes and tenures”. It is likely that a combination of the development scenarios will provide the most appropriate strategy for the SLP. \n\nWe would like the new Local Plan to recognise the role of Housing Associations in providing affordable housing in Cheltenham, Gloucester and Tewkesbury. It would be beneficial for the Council to recognise the role of Housing Associations and encourage developers to have early active engagement with Housing Associations in the next round of consultation. Early engagement enables Housing Associations to have an active role in the planning and design of developments to ensure that the development addresses local housing needs and meets the management requirements of the SWHAPC."]
["Statutory/Specific Consultee","RSPB","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Thanks for asking the RSPB to comment on the above, we would like to stress the relevance and importance of enhancing/creating features to encourage wildlife occupation of new and existing urban developments to comply with National Government Directives intended to enhance the Health and Wellbeing of new and existing residents. In recent years in addition to quantifiable Biodiversity Net Gain, Best Practice for enhancing the biodiversity of new building developments has included : an average of one Integral Bird box per residential unit, using \"universal boxes\" which are used by the four red listed building dependant species and others see attached, Hedgehog highways to provide access to and from public and private \"green spaces\", Provision for crevice and void roosting bat species on a case by case basis as specified by the Bat Conservation Trust, Provision for Solitary Bee Species as specified by \"Bug Life\", Where appropriate water features to provide for amphibians, dragon flies etc., Creating/maintaining an urban tree canopy, Recreational green spaces such as allotments, community orchards etc.. See NHBC NF89 biodiversity-in-new-housing-developments.pdf  and more specifically British Standard for integral nest boxes BS42021:20 published in 2022. We understand that the latter was designed to facilitate including \"Bird Bricks\" as part of the planning process, the sections that would be particularly relevant are: Section 9.2 of BS42021:2022 stipulates that Integral nest boxes – installation plan Details for the selection, siting, positioning and installation of integral nest boxes shall be prepared and submitted to the local planning authority, to include: a) the total number of integral nest boxes to be installed on site; b) a list of recommended integral nest boxes selected for installation, i.e. manufacturer(s) and model(s) along with illustrations, where available; c) a site plan at an appropriate scale showing the location of specific buildings in the development into which boxes are to be installed; d) building elevations showing the position on each building on site where boxes are to be installed; e) details of materials, methods and workmanship necessary to install each box, taking into account relevant building regulations (such as Approved Document 7 [5]); and f) a drawing showing the relationship between green infrastructure and the locations where integral nest boxes are to be installed, illustrating access to suitable, natural resources for birds including food, water and nesting materials in nearby habitats. g)The entrance holes shall be minimum of 30 X 65mm\" to accommodate all the species expected to use \"Universal Boxes\" (see attached). 0ur monitoring programs have found that house sparrows tend to prefer single boxes at least one metre apart and that other species seldom use terraces. So we recommend using \"Universal Boxes\" instead, see attached which are used by House Sparrows, Starlings, House Martins, Swifts and assorted others, see attached. 8.4.1 Residential buildings to provide new and enhanced opportunities for nesting, the number of integral nest boxes on new residential developments shall at least equal* the number of dwellings, i.e. the ratio of integral nest boxes to dwellings is 1:1. NOTE 1 In practice this means that some dwellings could receive more than one box while others might contain none as some locations on a development are much more suitable than others, i.e. closer to green infrastructure. This might mean for a development of 30 houses, some might have more than one box and others none. NOTE 2 Some schemes could include a combination of internal and external nest boxes. The installation of external nest boxes is out of scope of this British Standard, however, where external nest boxes are included as part of the development plan they should also be included on the installation plan. Examples of species that might breed in external nest boxes in a built environment include the little owl, tawny owl, barn owl, kestrel, peregrine, starling, stock dove, jackdaw, black redstart, pied wagtail, spotted flycatcher, robin, wren, tree sparrow, swallow and house martin. NOTE 3 External nest boxes are additional to the installation of integral nest boxes on new developments and should not be included as part of the 1:1 ratio. Section 8.4.2 Larger buildings occur in many types and sizes and serve a number of purposes and uses. These include: commercial offices, residential apartments, commercial offices, libraries, educational buildings, nursing/ care homes and hotels and student accommodation, etc. The type and purpose of building could determine how many integral nest boxes are either appropriate or can be installed. The number of installed integral nest boxes in larger buildings depends upon the building construction. Glass-clad buildings might have no opportunities because of the material and the danger it presents to the birds. Some modern claddings could restrict opportunities. The number of integral nest boxes to be installed shall be proportionate to the size and design of the building. NOTE 1 There is not necessarily an upper limit to the number of boxes that can be installed. NOTE 2 Although it is unlikely that all boxes on a site will be occupied at the same time it is very likely that all boxes will be used at some point in the lifespan of the development."]
["Statutory/Specific Consultee","Teddington and Alstone Parish Council",20,"","","Yes","","Yes","","Greater consideration should be given to drainage issues. Land should be set aside to allow flooding.","7a. Require all buildings to incorporate solar panels, heat pumps and use best practice for glazing and building materials.","","Yes","","","Bus services and rail links. Community buildings . Community outdoor spaces such as Playing fields and Playgrounds. Adequate covered parking areas for bikes throughout any development.","","","","","","","","","","","","","","","One important measure is to provide more Park and Ride facilities for those in rural areas who have to drive to reach public transport options.","","Schools, Doctors and Dentist surgeries. Transport hubs/links to towns. Small general shops. Playing fields. Community centres. Allotment provision.","","School, Shop,Community meeting space. A regular public transport service suitable for working people and school children.","Yes","","","","","Scenario 6: Sustainable transport scenario","","","[Q26] Yes, for example for the offline route for the A46 in Tewkesbury Borough. \n[Q29] Scenario 6 would deliver housing more quickly and utilise existing transport infrastructure."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I should like to make the following comments regarding possible Southam developments SOU006, SOU007 & SOU008. The Southam area borders an Area of Outstanding Natural Beauty and parts of Southam, particularly the Ratcliff Lawns Fields area, are Areas of Special Landscape Interest and as such should be protected and enhanced, not destroyed. The adjacent Cleeve Hill is a tourist attraction bringing visitors from far and wide. Any development in Southam would have an undesirable impact on the views from Cleeve Hill which should remain open and uncluttered. The refusal of the planning application for a housing development off Mill Lane, Prestbury in 2017 sets a very relevant precedent when considering the Southam sites."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","* I am extremely concerned about the ‘CHARGROVE GREENBELT’. The Chargrove area contributes greatly to the quality of life for the local communities and should be preserved for our future generations to enjoy. It is an area that should be protected for nature and recreation. *The Chargrove area is widely used by families, younger people and also the older generation for walking, cycling, jogging etc. There are several walks over to Shurdington. It is a very safe area whilst giving the impression of being in the countryside away from the constant roar of traffic and noisy housing estates. Deer are often spotted whilst walking together with an array of birds in the hedgerows.*The area is a haven for wildlife and several of the trees have existing tree preservation orders placed on them. *The greenbelt needs to be protected as valued landscape with having lovely long views up to the escarpment. As the greenbelt in Cheltenham and Gloucester is one of the smallest in England it should therefore remain unchanged. Greenbelt prevents urban sprawl and prevents the merger of Cheltenham and Gloucester! *There is no adequate road infrastructure in the area to support the extra traffic housing would bring. The recent addition of new housing in the Leckhampton area has caused serious impact on Up Hatherley Way, Shurdington Road and Arle Court. There are regular traffic jams along these particular roads and the constant noise of cars and lorries thundering along Up Hatherley Way day and night is very disturbing. *There will be increased pressure put on the local schools and health facilities and these are already substantially oversubscribed."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Proposed housing development, White House Farm, Churchdown, Glos. CHU024. I would like to register my strong objections to this proposed development for the following reasons: •\tThis is green belt land which is one of the few areas preventing Cheltenham and Gloucester becoming one huge conurbation with no open spaces. •\tThe footpaths across these fields are used extensively by local people for walking/exercise in a natural open habitat. Walking in a housing estate is no substitute. •\tWith so many housing developments completed or underway in the area, local services such as doctors, dentists and schools are already overwhelmed. •\tLocal village and country roads would not cope with the increased traffic from such a large development. Congestion around school start and end times is already a nightmare."]
["","Propernomics","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","The PPG for Housing and Economic Land Availability Assessment says (para 21): “Where constraints have been identified, the assessment will need to consider what action could be taken to overcome them”. (The methodology flowchart set out in the PPG also includes an action at Stage 2 to examine “Overcoming Constraints”.) In contrast to this the council has said in its HELAA methodology document (page 11) that “in the absence of an up-to-date evidence base relating to the landscape sensitivity of sites within the AONB a precautionary approach has been taken for the purposes of this assessment and sites within the designation will be assessed as unsuitable for development”. This blanket approach is most unsatisfactory given that some sites are plainly less sensitive than others. By following this methodology the council risks rejecting sites that are suitable and achievable for development and could meet pressing housing needs and aspirations for economic development. For example, Site S148 (in the “Reg 18 Dec HELAA Spreadsheet”) is suitable and achievable for development for the reasons (including errors in the HELAA spreadsheet) now explained. \n1.\tTo be accurate, the assessment should consider the features of the “net area” for development rather than the “gross area” (some parts of the site are well suited to development; others are more suited to landscaping and BNG for example). \n2.\tThe council has already assessed the location as an area of lower sensitivity within the Settled Lowlands (area LCA 8.2). Circa 1 ha within the southern part of site S148 (“S148 South”), immediately west of Dowdeswell Park and adjacent to London Road, is especially low in the landscape with low sensitivity. This remains the case and is very apparent from a site visit. \n3.\tIn reality, no part of the proposed development is in Flood Zone 3 because the layout of development would avoid the River Chelt. It is a positive feature not a constraint. This can be illustrated by reference to the following flood map for the southern part of site S148 (“S148 South”); the part of the site north of the river, being on higher ground, is also unaffected by flooding. \n4.\tAlthough the site is detached from the Principal Urban Area, it adjoins Dowdeswell Park; plus other development of residential and business floorspace has occurred successfully nearby. The site is separated from listed buildings by London Road and/or screened by trees. \n5.\tIt is an error to say that the site includes part of the adjacent “Mineral Safeguarding Area for Sand and Gravel”. Compared to the Title Plan (see separate attachment), the safeguarded area (shaded with the tan colour in the following plan) is to the west of the site boundary. \n6.\tWe understand that the council is waiting for new evidence on, for example, landscape, housing and employment matters; hence it is premature to judge site S148 or “S148 south” as unsuitable or unachievable. \n7 Maintaining flexibility in the supply of land is especially important given local housing requirements, plus the recent broadening of the Use Classes Order and Permitted Development Rights which have reduced the certainty of land supply being developed in particular uses. More than ever, prudent Forward Planning would ensure that there is a sufficient supply of sites to meet Local Plan objectives.\n8.\tSite S148 or “S148 south” could plainly help meet the area’s acute need for additional housing and/or the council’s aspirations for economic development. e conclude that Site 148 should not be filtered out or put into abeyance by the HELAA process and should be assessed positively for the reasons stated. The landowners confirm that the site is available for development."]
["Statutory/Specific Consultee","National Gas UK","","","","","","Yes","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","[National Gas Asset Map included] Dear Sir / Madam\n\nStrategic and Local Plan Regulation 18: Spatial Options and Key Policy Areas Consultation January – March 2024\n\nRepresentations on behalf of National Gas Transmission \n\nNational Gas Transmission has appointed Avison Young to review and respond to local planning authority Development Plan Document consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document. \n\nAbout National Gas Transmission National Gas Transmission owns and operates the high-pressure gas transmission system across the UK.\n\nIn the UK, gas leaves the transmission system and enters the UK’s four gas distribution networks where pressure is reduced for public use. National Gas Transmission assets within the Plan area Following a review of the above Development Plan Document, we have identified one or more National Gas Transmission assets within the Plan area.\n\nDetails of National Gas Transmission assets are provided below. \n\nAsset Description: \n\nGas Transmission Pipeline, route: WORMINGTON TO TREADDOW\n\nGas Transmission Pipeline, route: WORMINGTON TO TIRLEY \n\nWormington_3823 - COMP Gas Transmission Facility \n\nGas Transmission Pipeline, route: CHURCHOVER TO WORMINGTON DUPLICATE \n\nGas Transmission Pipeline, route: CHURCHOVER TO WORMINGTON \n\nGas Transmission Pipeline, route: WORMINGTON TO SAPPERTON \n\nGas Transmission Pipeline, route: WORMINGTON TO PUCKLECHURCH \n\nA plan showing details and locations of National Gas Transmission’s assets is attached to this letter. Please note that this plan is illustrative only. \n\nPlease also see attached information outlining further guidance on development close to National Gas Transmission assets. \n\nUtilities Design Guidance \nThe increasing pressure for development is leading to more development sites being brought forward through the planning process on land that is crossed by National Gas Transmission\ninfrastructure. \n\nNational Gas Transmission advocates the high standards of design and sustainable development forms promoted through national planning policy and understands that contemporary planning and urban design agenda require a creative approach to new development around underground gas transmission pipelines and other National Gas Transmission assets. \n\nFurther Advice \n\nNational Gas Transmission is happy to provide advice and guidance to the Council concerning their networks. If we can be of any assistance to you in providing informal comments in confidence during your policy development, please do not hesitate to contact us. \n\nTo help ensure the continued safe operation of existing sites and equipment and to facilitate \nfuture infrastructure investment, \nNational Gas Transmission wishes to be involved in the preparation, alteration and review of plans and strategies which may affect their assets. Please remember to consult National Gas Transmission on any Development Plan Document (DPD) or site-specific proposals that could affect National Gas Transmission’s assets. We would be \ngrateful if you could check that our details as shown below are included on your consultation database: \n\nMatt Verlander, Director nationalgas.uk@avisonyoung.com \n\nAvison Young, Central Square Forth Street Newcastle upon Tyne NE1 3P \n\nKam Liddar, Asset Protection Lead kam.liddar@nationalgas.com \n\nNational Gas Transmission National Grid House Warwick Technology Park Gallows Hill Warwick, CV34 6DA \n\nIf you require any further information in respect of this letter, then please contact us. \n\nYours faithfully Matt Verlander MRTPI\nDirector 0191 269 0094 \n\nmatt.verlander@avisonyoung.com \n\nFor and on behalf of Avison Young National Gas Transmission is able to provide advice and guidance to the Council concerning their networks and encourages high quality and well-planned development in the vicinity of its assets. Gas assets High-Pressure Gas Pipelines form an essential part of the national gas transmission system and National Gas Transmission’s approach is always to seek to leave their existing transmission pipelines in situ. Contact should be made with the Health and Safety Executive (HSE) in respect of sites affected by High-Pressure Gas Pipelines. National Gas Transmission have land rights for each asset which prevents the erection of permanent/ temporary buildings, or structures, changes to existing ground levels, storage of materials etc. Additionally, written permission will be required before any works commence within the National Gas Transmission’s 12.2m building proximity distance, and a deed of consent is required for any crossing of the easement. \n\nNational Gas Transmission’s ‘Guidelines when working near National Gas Transmission assets’ can be downloaded here: https://www.nationalgas.com/document/82951/download \n\nHow to contact National Gas Transmission \n\nIf you require any further information in relation to the above and/or if you would like to check if National Gas Transmission’s transmission networks may be affected by a proposed development, please visit the website: https://lsbud.co.uk/ \n\nFor local planning policy queries, please contact: nationalgas.uk@avisonyoung.com"]
["Planning agent or developer","SF Planning","","","","","","","","","","","No","","","","","","","","","","","","","","","","","","","","This question could perhaps also ask more about how infrastructure will be delivered. On sites which are allocated and in multiple ownership; the Council should advocate for a strategy to ensure that infrastructure can be delivered in the most efficient way, making the best use of land and ensuring a cohesive development across the whole allocation.","","","","","","","","","","","[Map of land near Hayden STW included] \n1. This representation is made by SF Planning on behalf of NEMA Strategic Land (NEMA). NEMA owns a substantial parcel of land forming part of a site which was allocated through the Joint Core Strategy (JCS) for development at West Cheltenham. \n\nThis is an employment-led mixed-use development for approximately 500,000 sq. ft of employment floorspace and approximately 350 new dwellings, consistent with the allocation policy and the vision within the Golden Valley Supplementary Planning Document (SPD). \n\nNEMA AND THEIR LAND OWNERSHIP \n\n2. NEMA are fully committed to delivering a high quality employment led, mixed use development at this site as detailed above and are currently working with Cheltenham Borough Council and other landowners to successfully deliver the allocation in accordance with Policies SA1 and A7 of the JCS and the SPD and accompanying appendices.\n\n3. Our client is preparing to make an outline planning application for approximately 500,000 sq. ft of employment floorspace and approximately 350 dwellings (as detailed above) at West Cheltenham. \n\nThe development is intentionally employment led, and our client has fully observed the allocation policy and the vision in the SPD in its detailed proposals. \n\n4. It is worth being aware that the development covered by the allocation may not have been fully delivered by the time this emerging local plan is adopted. ALLOCATION AND EMPLOYMENT LAND FIGURES \n\n5. The JCS, at policy SP1, confirms that 192ha of ‘Class B’ employment land should be provided to support 39,500 new jobs across the area. We understand that land was allocated in the JCS on this basis and with a view to meeting this need. \n\n6. The anticipated number of new jobs to be planned for was estimated in the Employment Land Assessment update (prepared for the examination of the JCS) to be between 39,500 and 46,600. \n\nAccordingly, the JCS was potentially quite limited in planning for employment land. \n\n7. As the demand for jobs (and therefore employment space) is expected to grow over the next 10 – 15 years, in line with ONS data, and given the reserved approach taken in the JCS, it would be logical to expect the employment land requirements in the emerging local plan to be significantly higher than in the adopted local plan. \n\n8. Against this background, the SLP consultation document refers to the most recent Gloucestershire Economic Needs Assessment (2020) which was prepared after the JCS was adopted. The figures provided within the SLP consultation document itself lack clarity in that it does not define what is meant by ‘Labour Supply Growth’ or ‘Labour Demand Growth 1’ (is growth 1 distinct from Growth 2 perhaps? If so, we are not certain how). Our interpretation is that supply growth is the amount of land which will be available and demand growth is the amount of land which will be needed but there is no explanation or context in order to confirm this interpretation is correct and how it has been calculated. Also, whilst the difference between the two can be calculated in order to ascertain potential need (assuming the interpretation above is correct), it should be spelled out more clearly within this document. Therefore, it is difficult to comment on how meaningful or instructive they are, and how that will translate into a final figure for the plan itself. \n\n9. In addition, the figures for supply and demand appear to be low when considering the JCS figures and the fact that the allocation has not yet been delivered (as may be the case with other employment allocations across the area). They also appear low when considering the general population growth predicted for Gloucestershire over the next ten years, based on ONS statistics. \n\n10. What is clear from this is that the evidence base for the emerging plan will need to include a robust, clear and transparent assessment of employment needs over the plan period and should ensure that growth is being properly planned for. The assessed employment need on which the emerging plan is based should reflect both past trends and economic forecasts, as advocated for in planning practice guidance (Paragraph: 029 Reference ID: 2a-02920190220). \n\n11. There are significant consequences to failing to plan fully for economic development. Paragraph 2.14 of the Employment Land Assessment update \nmakes the point effectively; “The perceived undersupply of employment land was considered to have a profound negative impact on the economy of the area, acting as a constraint for businesses and forcing them to move elsewhere. The shortage of employment land was identified as outweighing the area’s key strengths such as a high quality workforce and lower costs than other centres”. It is therefore important to ensure that there is sufficient employment land of sufficient quality available to businesses."]
["Planning agent or developer","Newland Homes","","","","","","","","","","","","","","","","","Yes","It is considered that the SLP should use the Standard Method for calculating annual housing needs. This is on the basis that the existing housing land supply and delivery is below current requirements and any further adjustments to the identification of need would likely create further delays in Local Plan adoption and create further abilities for challenges to the Council’s assessment method.","","","","","","","","","","","","","","","","","","","","","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","","",{"$cut":{"chars":22463,"head":"Dear Strategic and Local Plan Team \n\nRepresentation to Strategic and Local Plan (Regulation 18: Spatial Options and Key Policy Areas) Consultation\n\nRidge writes on behalf of our clients, Newland Homes, in order to submit a representation to the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (Regulation 18: Spatial Options and Key Policy Areas)\nConsultation (running 16th January until Tuesday 12th March 2024). \n\nThis representation focuses specially on development ‘Scenarios’ 1 to 6 and a recommendation for a residential \ndevelopment allocation on land at Up Hatherley Way, Shurdington, to the south-west of Cheltenham. \n\nSite Context\n\nThe land subject to this representation is largely comprised of agricultural fields, however it includes small amount of residential land known as ‘Oaklands’ to the east. \n\nThe land is enclosed by the A46 Shurdington Road to the east, Up Hatherley Way to the North and agricultural fields bound by Chargrove Lane to the south and west.\n\nA ‘Concept Plan’ of the relevant land is enclosed as Appendix 1 to this letter. The land is within the administrative boundary of Tewkesbury Borough Council, however, is located directly adjacent to the Cheltenham Urban Area to the north. \n\nThe entirety of the land is within the Green Belt, however within the wider Green Belt area (enclosed by Chargrove Lane) are a number of urban developments, including; the 1-storey Brizen Young Peoples Centre, Brizen Carpark, multiple 1- to 3-storey residential dwellings, 2-storey Chargrove Lawn Care Home, 2 storey office accommodation for Randall Payne LLP, a mixed use area known as ‘Oak Farm’, and a mixed use area used as Greatfield Hand Car Wash. \n\nAbout Newland Homes Newland Homes are a Small-Medium Enterprise (‘SME’) property developer based on Gloucester. Newland Homes take time to engage with the communities in which they build and deliver homes, which blend with and enhance the local vernacular. As lifestyle preferences and technology has evolved, so have their homes, and they are proud to push the boundaries so that they can invest in bespoke designs for the benefit of future residents. \n\nAlongside Newland Home’s expertise, they are discussing the ability to deliver the wider Site as part of a comprehensive development with another SME Redcliff Homes. Both developers are focused on quality and sustainability, and immediately able to begin development upon receipt of any planning approval. \n\nPlanning History \n\nParcels of land have had historical residential planning applications submitted. Applications of note are identified in the below table:\n\nApplication Reference 08/01453/OUT Address Oaklands Shurdington Road Shurdington (Small eastern plot only) Description Outline application for residential development of 96 dwellings, associated access road and public open space. Decision Refused 14 July 2009 \n\nApplication 17/00924/OUT Address Land South Of Up Hatherley Way Chargrove Lane Up Hatherley \nCheltenham Gloucestershire (Majority of land between Up Hatherley Way and Chargrove Land) Description Outline planning application for up to 500 dwellings; commercial/local centre of \n1,250sqm for a mix of uses including B1a, A1, A2, A3, A4, A5 and new informal and formal recreation space and means of access. (Appearance, Landscaping, Layout and Scale reserved for future consideration). Decision Refused 14 July 2009 Refused 16 January 2018 \n\nThe principal reason for the refusals on both sites was the conflict with the protection of the Green Belt. \n\nThe most recent planning policy history of relevance are the submissions for historical emerging Local Plan documents. Tewkesbury Borough Local Plan Inquiry (December 2002 and March 2003) The eastern portion of the site was an omission site and duly considered at the Tewkesbury Borough Local Plan Inquiry (December 2002 and March 2003). \n\nThe Inspector’s Report (December 2003) states that the Brizen Farm, on its northern, eastern and part of its southern boundaries, adjoins existing residential areas and in effect it forms a small wedge of Green Belt extending into the"}}]
["Planning agent or developer","Newland Homes","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","",null,"","",{"$cut":{"chars":32767,"head":"[All the comments below are from a submitted document Representations on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (Regulation 18: Spatial Options and Key Policy Areas) \n\nAll the comments are included in this general section as they are likely to repeat was was also submitted via the form] \n\n1.1 These representations to the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (Regulation 18: Spatial Options and Key Policy Areas) are submitted by Origin3 on behalf of Newland Homes. Newland Homes have an interest in Land at Northway, Tewkesbury, which is included in the area identified as having potential for the creation of Tewkesbury Garden Communities. \n\n1.2 The land at Northway has the potential to be brought forward as an opportunity to deliver around 450 new homes with associated community facilities and areas of green space. Although part of the Garden Communities being promoted by Tewkesbury Borough Council, Northway is not dependent on the Garden Communities to come forward, and could also be seen as a modest urban extension in its own right – a \nposition reflected in the way that the Tewkesbury Housing and Economic Land Availability Assessment assesses the site both as part of the Garden Communities and as a stand-alone site.\n1.3 Newland Homes wishes to promote Northway for development which could act as a precursor to the Garden Communities coming forwards, facilitating infrastructure required to deliver Garden Communities land further to the east, but able to come forward quickly as an extension to the Northway community to deliver new homes for Tewkesbury. \n1.4 These representations set out our initial comments on the Strategic and Local Plan being developed by Cheltenham, Gloucester and Tewkesbury. Representations have been submitted via the online questionnaire and also emailed to the Strategic and Local Plan team accompanied by the Vision Document that has been prepared to showcase the opportunity at Northway. \n2.1 Our comments on the Strategic and Local Plan are as follows: Strategic and Local Plan \n2.2 Chapter 2 of the Strategic and Local Plan sets out the rationale for the plan, the plan area being covered and suggests broad policy areas to be covered. We support the plan area and the topics as set out, and commend the authorities on their decision to progress a single joint local plan to replace the adopted Joint Core Strategy and all adopted Local Plans. A single joint local plan will provide a more straightforward and easily understood strategy and policy framework for the future development of the three local authority areas. \n2.3 Question 1 of the consultation asks, “How far into the future should the Strategic and Local Plan cover?” Paragraph 2.10 notes that the timetable for producing the Local Plan is for submission to the Secretary of State in 2026, which would lead to an end date for the plan of 2041 at the earliest. We would suggest that the plan period should be significantly longer than this, for the following reasons: a. The NPPF sets out that strategic policies (which the SLP will contain) should look forward for at least 15 years from the point of adoption (para 22 of the NPPF published in December 2023). Clearly, once the SLP is submitted in 2026 it will need to go through an Examination process which will last at least 6 months, and given the complexity of the plan potentially longer, which would mean adoption of the plan in 2027 at the very earliest. A plan period running to 2041 would not therefore meet the requirements of the NPPF. b. Paragraph 22 goes on to say that “Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.” Given that the SLP may well set out a spatial strategy that includes the creation of new settlements and urban extensions (as indicated in the Scenarios), this element of the NPPF would seem to a"}}]
["Planning agent or developer","Newland Homes","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","[Continuation of submitted document Representations on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (Regulation 18: Spatial Options and Key Policy Areas) - as cell maximum was reached] \n\nOnly approximately 10% is considered to be BMV and therefore, development would not significantly harm national agricultural interests. \n\n3.16 Ecological surveys were undertaken in 2022 and 2023, comprising a UK Habitat Classification survey and targeted surveys for bats, great crested newt (GCN), dormouse, birds, reptiles, otter and water vole. Habitats are to be retained and enhanced where possible as part of the development. The proposals are mainly situated on low ecological value habitats, namely the arable land and modified grassland.\n\nConclusion \n\n3.17 The Land at Northway is available for development in the short term and could form an important element of the spatial strategy to be set out in the SLP. We consider that it would fit well into: a. Scenario 2 – Urban Extensions, as a sustainable extension to Tewkesbury b. Scenario 3 – Urban Extensions avoiding the Green Belt, as s sustainable extension to Tewkesbury not in the Green Belt c. Scenario 4 – New Strategic Settlements, as a precursor to the Tewkesbury Garden Communities, providing a new stand alone community which also facilitates the infrastructure required to deliver the rest of the garden town. d. Scenario 5 – Sustainable Transport Corridors, if our suggestion above is taken forwards that the sustainable transport corridor should be extended to Tewkesbury and used as a guiding principle for developing the SLP spatial strategy. \n\n3.18 Origin3 would be happy to engage with the SLP authorities on behalf of Newland Homes to explain these points in greater detail."]
["Planning agent or developer","Inchbald Day Planning & Development",15,"Specific Affordable Housing and Self Build and Custom Build Site Allocations \n\nSmall business/retail/Distribution hubs for local employment, retail and collection/delivery. \n\nSecond homes/Air BnB use of housing stock.","None – the new plan should cover all aspects with only Neighbourhood Plans or SPD such as a Design Guide sitting alongside.","","The draft forms a good basis for discussion.","","","We are already in climate crisis and the policies will need to be implemented long before this plan is approved by the Secretary of State.","All new buildings should be carbon neutral or carbon plus. The new Plan should include policies making this a minimum requirement. \n\nAdaptive retention and reuse of existing buildings should be encouraged in accordance with RIBA best practice. \nBrownfield Land is also important here and below the Plan (or part of it) there should be both a Part 1 and a Part 2 Brownfield Land Register.","","","Yes","Yes but would suggest a separate call for sites for each potential use.","Schools, Medical Services, Community facilities (village hall, etc) either shops or on line distribution/drop off points.","Yes","Yes – solar and battery storage as a minimum but also other new technologies as they emerge.","Yes","Yes, as a starting point but it is considered that there should be separate housing targets that sit below the overall number e.g. a separate affordable housing target, older peoples homes, self build and custom build, first homes, etc. \n\nFor example, if the housing target is 10,000 homes, this should be:\n\n- 4,000 affordable homes incl. first homes, shared ownership, social and affordable rent \n- 1,000 self build and custom build \n- 5,000 open market homes of which a percentage should be for older people (say 50%) \n\nThis will help to deliver much-needed affordable homes, offer an alternative route to home ownership whilst providing a clear strategy for housing delivery and numbers (and avoiding viability arguments). \n\nStudent housing and HMOs should form a separate policy and not be part of the overall housing numbers. In order to provide robust figures using the standard method, other complementary policies in respect of second homes and Air BnBs should be included in the Plan to protect the existing housing stock.","","Yes, as a starting point but it is considered that there should be separate housing targets that sit\nbelow the overall number e.g. a separate affordable housing target, older peoples homes, self\nbuild and custom build, first homes, etc.\nFor example, if the housing target is 10,000 homes, this should be\n• 4,000 affordable homes incl. first homes, shared ownership, social and affordable rent\n• 1,000 self build and custom build\n• 5,000 open market homes of which a percentage should be for older people (say 50%)\nThis will help to deliver much-needed affordable homes, offer an alternative route to home\nownership whilst providing a clear strategy for housing delivery and numbers (and avoiding\nviability arguments).\nStudent housing and HMO’s should form a separate policy and not be part of the overall housing\nnumbers.\nIn order to provide robust figures using the standard method, other complementary policies in\nrespect of second homes and Air BnB’s should be included in the Plan to protect the existing\nhousing stock.","","See above – with the new provision of s123 of the Levelling Up and Regeneration Act 2023\nrequiring that only developments that are specifically described as self-build, count towards the\n12 month target, it is considered that separate site allocations for this type of housing should be\nincluded in the plan.\nThere could also be a policy to reflect intergenerational housing where 2 or 3 generations of the\nsame family seek to pool resources to make home ownership an affordable target.","","","Para 5.25 of the consultation document refers to the boat dwelling community but there is no specific question here. A policy reflecting the suggestions of paragraph 5.26 of the consultation document should be included.","The Plan should consider sites with access to the grid, broadband and new technologies or include within the larger sites, a requirement for renewables within the development.","The M5 corridor and associated integrated transport policy is essential as is providing appropriate housing. \n\nThere is no mention of the airport in the consultation document and whilst climate change will inevitably mean there is less air travel, this may be a medium term opportunity.","Yes – small business parks, near good transport links, provide important rural employment. Policies should not just be as part of a farm diversification scheme. It should allow for other land to come forward. Leisure and tourism are equally, an important part of the rural economy and should be encourages. Equally, with the increase in online shopping and working from home – small hubs with good internet connection, work spaces and delivery/collection could be provided in key rural locations.","Encourage adaptive reuses for redundant buildings and encouraging residential change of use in town centres. As the new Class E includes offices and retail and commercial use, including retail policies in a Plan to last for 20 years may not be forward looking. The importance of education as a use should also be reflected within these policies e.g the Debenhams in Gloucester. Where else can this be encouraged? It is suggested that Town centre SPD’s should be considered. These would have in-built flexibility on town centres becoming destinations - a hub of community activity especially as retail demand declines, particularly for Cheltenham with the festivals. How can open space be used and adapted to encourage visitors e.g. the Long Gardens are a public square with outdoor cinema/theatre/etc. Benches and seating areas with planting for shade and carbon capture rather than expensively maintained municipal planting.","See comment re. rural hubs","See comments re. access to grid, renewables and new technologies.","Look at the Commission for the New Town/English Partnership model (poss. Homes England?) where permissions were clearly phased to ensure that the necessary infrastructure (physical and social) was provided before all the houses built on larger schemes. A specific phasing policy (rather than equalisation figures) attached to the larger allocations would give clarity to developers at the outset and avoid viability arguments at a later stage.","It is suggested that a ‘hub and spoke’ approach is best considered with it being recognised that ‘service villages’ also cater for the needs of smaller villages and hamlets where new development can be catered for. So, in considering whether a development is suitable in a smaller village, recognition of the relationship with the service village is taken into account.","Yes","","","","","Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","See above re. hub and spoke model. ","[Q.1] 15 - 20 years\n[Q.8] The Plan should be in line with National Guidance but the 10% should be onsite. \nShould the provision be off-site then the policy could consider the amount to be offered by reference to the \ndirect benefits to the Plan area e.g. if the off-site provision is outside the plan area then a higher % should be required.\n\n[On the question: Should sites for traveller communities be provided as part of large developments for housing and/or employment? - a yes or no was not given but it was indicated that separate sites should be considered]\n\n[On the question: Are there any places not currently identified in the rural settlement hierarchy, which could/should be included? - a yes or no was not given but it was indicated that comments on the hub and spoke model should be considered].\n\nPolicies in respect of second homes, Air BNBs etc should be included as they impact on housing supply. See attached comments on HELAA – a separate call for sites submission has been made. The land at the West of Willow Bank Road, Alderton (HELAA ref: ALD016) represents an opportunity for a Self-Build or Custom Build site for up to 9 houses.\n\n[For question 29 the long answer is as follows: Inevitably a mix of a number of these scenarios are likely. Assuming Ashchurch goes ahead as a new settlement then Scenario 5 and 6 seem to reflect a sustainable approach to development whilst supporting much-needed rural housing]."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","The website states that the SLP Issues and Options Regulation 18 consultation is closed for comment, yet it also says that there is one day left to comment.\n\nMy comment relates to the IDP. This is a key document, a draft of which I would like to see consulted on at the same time as the Regulation 18 consultation of the SLP. That way we can see what infrastructure has been identified as necessary to support the plan and highlight any deficiencies or inconsistencies.\n\nIf necessary the SLP Regulation 18 consultation should be delayed to achieve this. I recognise that the draft IDP may be lacking in certain details at that time (eg costings), but it is difficult to overstate the importance of identifying infrastructure requirements as soon as possible. The current situation where developers are submitting planning applications without knowing whether adequate infrastructure is available cannot continue (I have in mind sewage, school places, medical facilities, transport links). The plans for these and many more will be documented in the IDP which will become a living document for the next 20 years or so, and help ensure that appropriate infrastructure is available when and where required."]
["Statutory/Specific Consultee","Badgeworth Parish Council","","","","","","","","","","","","","","","","","","","","","","There could also be a policy to reflect intergenerational housing where 2 or 3 generations of the same family seek to pool resources to make home ownership","","","","","","","","","","","","","","","","","","","","January 2021 Badgeworth Lane – The need for Traffic Management Improvements This paper details the concerns of Badgeworth Parish Council regarding the present and future use of Badgeworth Lane and, as such, has been circulated to key elected members and officers at County and District Council levels (Gloucester, Cheltenham and Tewkesbury) responsible for housing and business/commercial developments and highway improvements. The paper seeks to justify the consideration and approval of funding, principally through developer contributions (Section 106 and CIL agreements), for traffic management improvements to Badgeworth Lane. Description of the route of Badgeworth Lane and the current speed limits. Badgeworth Lane runs from its junction with the A46 on the southern side of Shurdington, past Shurdington School and out through a residential area under a 30mph limit (apart from a 20mph zone controlled by flashing lights outside the school). As the Lane exits the Shurdington residential area, the speed limit increases to 50mph, passing more residential houses and the entrance to a farm with industrial units. Badgeworth Lane then winds through a number of blind bends before reaching the outskirts of Badgeworth, where the speed limit reduces to 40mph. Passing through Badgeworth the Lane crosses the junction with Cold Pool Lane and Church lane and then exits the residential area meeting the junction with Brookfield Road, a major route in and out of Churchdown. Immediately past this junction the speed limit increases to 50mph as Badgeworth Lane ends and becomes Badgeworth Road. It is worth noting that a significant volume of traffic approaching the Badgeworth cross roads travels via Cold Pool Lane to Up Hatherley and Cheltenham which, as a narrow winding lane, presents further issues. Why are we concerned? Badgeworth Lane has seen a steady increase in traffic over the past decade and the Parish Council has become increasingly concerned about both the volume of traffic and the Page 2 suitability of the current speed limits along this stretch of highway. Residents who live along the length of Badgeworth Lane have raised serious concerns about their own personal safety when using the Lane or simply attempting to cross the road. They have also expressed anxieties about the safety of other users including pedestrians, cyclists and horse riders. Badgeworth Lane has become a principal link for vehicles travelling along the A46 who wish to cut across to the west of Cheltenham feeding into the Arle Court roundabout/Golden Valley/M5 junctions. It is relevant to note that the only sign to the Gloucestershire Airport along the A46 is the one located at the junction with Badgeworth Lane. The increasing volume of traffic occurs across a wide range of times, but it is at its peak during the morning and evening commutes. The risks to pedestrians, cyclists and horse riders increases over the weekend when the road is also used for leisure purposes. Also, there is a particular issue with the combination of traffic volumes and parked cars outside Shurdington Primary School at the times of pupils arriving and departing. The Parish Council has engaged with County Highways on a number of occasions over the last 3 years and traffic surveys have been conducted. The Highways department have confirmed an increase in traffic volumes for both motor vehicles and cyclists but have explained that there is no funding available to address the traffic management issues. Additionally, the Police mobile speed cameras have been regularly deployed in the 30mph zone as traffic leaves Shurdington. The Police data has shown that on average, over multiple occasions, they detected a vehicle speeding every 2 minutes. The Parish Council is extremely concerned that the situation will get worse as more developments take place in the areas at either end of Badgeworth Lane. At present we are aware of: • a significant increase in residential housing (1500 homes) to the north of Brockworth (currently under development), • a TBC local plan for housing development at the Shurdington end of Badgeworth lane for 50 homes • growth in Shurdington Primary School population with resultant major traffic congestion and parking problems • a proposed £1.9m development of a new business Park at the Gloucestershire Airport with a potential 1750 jobs • the further development of the BMW/Mini site on Grovefield Way • the West Cheltenham Cyber Central and garden community. A £400m development with 3000 homes. A cabinet member for Cheltenham Borough Council stated that this development would be an “economic boost felt across the whole town and beyond”. The combination of the above will be compounded by the existing high volumes of traffic using the A46 in and out of Cheltenham which frequently leads to slow moving or static traffic through Shurdington. A direct consequence of this is that road users seek to find alternative routes, and in this case Badgeworth Lane becomes the easiest option and the default “Southern Ring Road” around Cheltenham. Next Steps Badgeworth Parish Council believes that it has become critical that a plan be developed that recognises the increasing demands on Badgeworth Lane and examines the strategies that can potentially reduce the risk to road users and residents Without improvements to the Lane, residents and commuters face deteriorating safety levels which put lives at risk. The Parish Council believes that Badgeworth Lane will need more than simple cosmetic changes to improve safety. It may require a combination of: • consideration of weight restrictions, • improvements to the junction with the A46, • speeding alert signals, • improvements to reduce some of the difficult/ blind bends in the Lane • changes to the various speed limits • use of gateways to emphasise that drivers are entering a built-up area\n• a footpath/cycle way to protect pedestrians /cyclists. It is understood that some of these changes are expensive and it seems appropriate that developers should be asked to make contributions to introduce improvements - it may not be immediately obvious that some of the developments described above have a direct impact on Badgeworth Lane but geographical distances do not remove the fact that the Lane will continue to be increasingly used by commuters travelling to from these residential developments and new industrial/commercial enterprises.\nBadgeworth Parish Council is very keen to engage with all the relevant local authorities and to open discussion on this important topic. We feel it is important that the local authorities understand the issues affecting our Parish and can incorporate them into the local traffic planning and funding processes.  "]
["Resident",null,"","","","","","","","","","","","","","","","","","","","","",null,"","","","","","","","","","","","","","","","","","","","I came across your information quite by chance.  I note the workshops were poorly attended.  \n\nWhy aren’t you sending info leaflets to all households?  \n\nThere are a lot of people in my area, Stanwick Gardens, Swindon Road etc who would be dead against losing their green spaces and having extra pollution, mega traffic problems, and high density housing developments inflicted on an already crowded area. \n\nI think too that it should be remembered that not everyone who would want a say has a computer!"]
["","","","","","","","","","","","","","","","","","","","","","","",null,"","","","","","","","","","","","","","","","","","","","Now that money is no longer available due to the Government cuts, what vision of transforming Winchcombe will our County Council hold? Winchcombe is unique in its size as a town, and as written in many books, an historical town. \n\nWith this in mind is it possible to concentrate on the need of our own local housing list? \n\nFunds to keep students in higher education is this a waste of taxpayers’ money when a high number of 16 to 18 year olds would prefer to earn a living. Is this a waste of money when we need more workers? \n\nMore interest is needed for keeping areas clean and tidy. London thinks it is cheaper to keep tidy than to clean up mess. It cuts cost of clearance and keeps it ghetto free. \n\nOur taxes are essential and must be processed sensibly. \n\nCosts have to be taken into consideration starting with our own Town council. The High Street toilets were closed because we could not afford to keep two toilet blocks. Now we are told it is essential for the new Winchcombe park to have them. \n\nThe Wilding programme, we are told in our council minutes it was not to cost our council any money. That is not the case. Council housing put their rents up which led to credits being introduced. Who pays for them? We do, the taxpayer. Leaving very little recompense for potholes, pavements, verges, bins not washed or seats not maintained in other words overall caring."]
["","","","","","","","","","","","","","","","","","","","","","","",null,"","","","","","","","","","","","","","","","","","","","Please may I suggest that any plans should include affordable bungalows so the ordinary elderly can downsize? They would need to be priced similarly to an average semi detached house.\n\nPensioners make up about a fifth of the population and many are trapped in their family homes. Bungalows,  like the council ones in Hill Hay Road in Matson, are not currently being built for private sale. Only large ones that cost as much as 4 bedroom detached houses. \n\nMost pensioners cannot afford to buy \nMcCarthy and Stone type retirement flats or afford their monthly charges.\n\nIf pensioners could sell up & buy small purpose built bungalows near the shops, doctors & a bus route to the hospital they could remain independent much longer. This would free up family homes too."]
["","","","","","","","","","","","","","","","","","","","","","","",null,"","","","","","","","","","","","","","","","","","","","Dear Tewkesbury Planners \n\nWHITEHOUSE FARM, CHURCHDOWN CHU024 \n\nI would like to register my concern regarding the above proposed development. \n\nI know other residents have submitted letters of concern listing risk of flooding, access in and out of the site is dangerous with a high volume of cars already travelling at speed turning Oldbury Orchard, Brookfield Road and over the railway bridge into rat runs. \n\nBrookfield Road and Oldbury Orchard are already a complete bottleneck at pupil arrival and leaving times to the extent that if needed an ambulance or fire engine would be unable to get through. \n\nAn influx of 800 houses could mean at least a 1000 more cars being added to an already dangerously overloaded system. \n\nAdded to the above is the fact that the railway bridge on Badgeworth road is weak and can only accommodate single line traffic making this amount of extra traffic wholly undesirable. \n\nAir and dust pollution can only get steadily worse throughout the village. State of the roads from potholes and lack of general maintenance is deplorable and can only get worse with the influx of vehicles that will flow from a development of the sort you envisage. \n\nAll schools in Churchdown are oversubscribed for the foreseeable future as is the local dentist and surgery who cannot take any more new patients of this magnitude due to Churchdown and Innsworth having extensive new housing developments over the last few years so where will all these extra children go to school and who will provide the extra local surgery care needed. There are many new housing sites in development in and around Churchdown. \n\nHow can another very substantial scheme be substantiated. This proposed development is unnecessary and inappropriate. This is without taking into account the preservation of footpaths, the biodiversity of this huge site and the risk of flooding.\n\nI therefore ask that you take our objections and all our sincere heartfelt concerns and fears into account when coming to your decision."]
["I work for a charity or volunteer in the area","Inclusion Gloucestershire",15,"Redevelopment of brownfield sites or repurposing existing building does not appear to be mentioned. Specialist housing, mental illness, disability, retirement.","","Yes","","Yes","","Implementing what has been outlined and not delaying due to a plethora of reasons.","Safe, to building regulations and liveable quality.","","Yes","No","","Health, Fire, police, shops and entertainment.","","Wind and water.","Yes","Yes ","No","","Yes",null,"","","","Use of empty buildings and brown field sites.","Build in the right place, at the right time to the right quality to support new businesses and workforce needs.","Appropriate housing in the right pace to support rural workers.","Work closely with commerce and industry – to align plans.","By concentration of sufficient customer demand to sustain the business.","Health and local services, food, fuel and entertainment.","","","Yes","","","Yes","","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","","","[Q.1] 15 years in detail, 25 in general due to the protracted timescales involved with building \n\n[Q.26] [For the question: Should the Strategic and Local Plan safeguard sites or routes for longer term infrastructure projects?\nYes was answered but it was: Yes if the planning information is credible and available.] \n\n[Q.31] General comments: Housing growth needs to be matched by health, schools and other supporting service growth. Over-burden of existing resources will have adverse impacts upon individuals and communities."]
["","","","","","","","","","","","","","","","","","","","","","","",null,"","","","","","","","","","","","","","","","","","","","Response to Section 6 Planning for Sustainable Development Context: It is recognized that the Consultation is focused on principles. However, these cannot be completely divorced from specific site issues. These comments are made in association with land on the perimeter of the settlement of Churchdown (CHU010 of the HELAA). Settlement Hierarchy \n\nThe settlement hierarchy as defined in the JCS leaves a black hole with respect to non strategic potential development sites at those settlements, such as Churchdown, which have been defined as part of the urban area of Gloucester. By virtue of policy SD2 of the JCS, the only development site adjacent to Churchdown identified in the JCS and the TBP is the strategic South Churchdown Urban Extension. \n\nSince the urban extension settlements, such as Churchdown, are sustainable by definition, the dismissal of other smaller potential development sites, results in lost opportunities for further sustainable development. \n\nWhilst a settlement hierarchy may have merit it should not be defined in such a way as to create such potential black holes for sustainable development. Green Belt \n\nThe Green Belt abuts the northern settlement boundary of Churchdown. The Borough Plan process did not address the appropriateness of parts of this boundary despite the finding of the Tewkesbury Borough Council Partial Green Belt Review 2017 that the harmful loss of CHU010 (parcel 09 of the Review) from the Green Belt would be Low. Indeed, there was no other overriding reason within the Borough Plan process to revise the green belt boundary to the north of Churchdown since policy SD2 of the JCS precluded further potential development at the ‘black-hole’ of Churchdown. \n\nThe SLP process should facilitate the review of small-scale changes to the green belt boundary in sustainable locations where green belt inappropriateness has clearly been identified. The removal of inappropriate green belt designation would enable a site such as CHU010 to be identified for sustainable development."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I wanted to make my comments about future planning on Greenbelt area in Hatherley.  \n\n1. The Area is special because firstly the Wildlife which over the years has already had land built on. We have Deer,Badgers Foxes,Bats and many birds and  small mammals. There are ancient orchards. The public use it for recreational purposes and is so important for mental health to be able to get away from their busy lives for excersise.\n\n2. Cheltenham can no longer expand outwards as there would be no Greenbelt from Cheltenham to Gloucester (North/West of Stoke rd (Bishops Cleeve) or in non- coalescing Green Belt at Boddington which would be a quasi extension of the JCS-permitted 'Cheltenham West' urban extension.The Roads around Hatherley  and Shurdinton are already heavy with traffic.\n\n3. This precious Greenbelt needs to be protected for Wildlife and Recreational purposes for people's Health.\n\n4 We have enough shops but Doctors and Dental services are needed when building new houses and Water reservoirs.\n\n5. Plant more trees wherever possible. Don't destroy the Greenbelt. Build affordable housing not Luxury build Energy saving houses. "]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I have lived happily in the centre of Gloucester on Brunswick Square for the past three years. As you know, we take responsibility for this and we are glad it allows a small green space for flora and fauna in the area.\n\nI  have been increasingly concerned about the closure of grocery and other domestic outlets in the centre of town. I understand the Eastgate Market is due for a renovation and hope that this will provide encouragement for small local greengrocers and other fresh food vendors. They buy locally and use less plastic than the supermarkets so bring more ecological sustainability, together with support for local growers. They also allow for smaller quantities so creating less waste. We are very lucky to have the fresh fishmonger there and hope this will continue. It will also benefit the health of the community in having access to less processed foods.\n\nI certainly hope we will continue to have the pedestrianised zone around the ‘gate’ streets; it would be good if this could be extended to the end of Westgate Street given the historical significance of the buildings down there. The history of Gloucester is amazing and encouraging tourists here boosts the city’s income. As the library moves to Northgate Street, it would be perfect to expand the museum into this space to display the many artefacts that are currently archived there.\n\nWalkways along the side of the river would provide great benefits to the health of local residents and visitors alike.\n\nThese are just some ideas I would like you to share with you. I know you will be inundated with suggestions so I thank you for this opportunity."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I would like to register my opposition to the proposed development plans in Churchdown. \n\nThe proposed development is unnecessary considering all of the new builds near Cheltenham Road East.\n\nBrookfield Road and surrounding roads are too busy at peak times as it is without adding additional traffic.\n\nWe struggle with getting doctor appointments etc as it is aswell so this will only add to the problem."]
["I visit the area for work, but I live elsewhere","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Yes","","","","","","","","[Q26] Of the Growth Scenarios, Option 6 ‘Sustainable transport’ should point to development of rail transport in the Plan area but does not mention rail development.\n\nIn the section on ‘Retail and city/town centres’ at pages 29-31, there is no discussion of rail stations and their locations. In Gloucester the station is close to the city centre but it is not on the main Bristol-Birmingham line and thus not served by the most important trains. In Cheltenham the station (Lansdown) is 1½ miles (2.5km) from the centre of the town and up to half-an-hour’s walk. In Tewkesbury the station (Ashcurch) is 2½ miles (4 km) from the historic town centre, though nearer to the modern development east of the centre. Rail is thus poorly sited to serve the town centres and not attractive for local travel to work, education or shopping.\n\n\nIn the ‘Infrastructure’ section (page 32), the provision and improvement of rail services is not mentioned. However there is recognition the need to safeguard transport routes:\n\nSubmission and proposal\n\nThere is a need for a new planning policy for the railways and railway stations at Gloucester, Cheltenham and Tewkesbury (Ashchurch).\n\nThe location of the one Gloucester station prevents good quality rail service to the city. The loss of the Eastgate Loop and station in 1975 has partly cut the city off from the main line through it.  If the Eastgate loop cannot be restored, a new through station at the Barnwood triangle is needed with an automatic shuttle unit moving between that station and Gloucester Central station.\n\nA through station at Barnwood has been assessed from time to time but never pursued. This leaves the city with a permanently poor rail service. IT should now be proposed in the Jkoint Plan with a site allocated and protected.\n\nA policy should specify that a shuttle unit (automatic) be provided between it and Gloucester Central station/Bus station.  Such a shuttle exists beyween Birmingham International Station and Birmingham Airport.\n\nCheltenham Lansdown Station is inconvenient and badly located. The 1997 Arup Gloucestershire CC on a new station in Cheltenham and new rail connections should be reviewed and updated.\n\nThe ‘Honeybourne Line’ former rail route, now protected in the Cheltenham Local Plan Policy TN1 for sustainable transport use, should be proposed for a new north-south line through the town with a station as close to the town centre as possible. A connection from the NE_SW (ex-Midland) main line should be built and the Stratford-Cheltenham (now GWSR) line extended from Racecourse station south to follow its old reoute through the town.\n\nLansdown station should remain but with platforms on the Honeybourne line tracked added. The existing main line through the west of the town, which has two level crossings on it, should be retained for freight and non-stopping trains only. That will mean its level crossings need to be closed only occasionally.\n\nA better connection into Tewkesbury than is currently available from Ashchurch station should be examined.\n\nEnclosures:\n\nExtracts from ‘Disconnected’ (2015 Austin and Faulkner) about Gloucester and Cheltenham stations\n\nCheltenham Local Plan Map extract 2018 sahowing existing and potenrtial rail lines and site of potential new central station for Cheltenham"]
["Resident",null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","The Examination in Public of the Stroud Local Plan Review and the objections to the planning application number 23/2428 by Taylor Wimpey for Whaddon Grange have shown there are major constraints on the Whaddon G2 site, including :\n\nThe SALA assessment conducted by Stroud District Council shows Whaddon G2 having the lowest score for accessibility for any site in Stroud District caused by the lack of crossings over the railway line to the West.\n\nCounty Highways have submitted that the site is not suitable for conventional housing and requires low traffic neighbourhoods with active travel access to he West of the railway. This is unattractive to the mass housing developers.\n\nThe proposed route to the West via Naas Lane including a virtual pedestrian pavement is shown to be unsafe and inadequate.\n\nAs yet, no solution meeting the approval of the County Council has been offered to solve St. Barnabas' congestion issues. The view taken by the County is that the traffic impacts of the Whaddon site will be severe and cannot be solved at that junction. A radical reduction of car travel is required and that is unpopular.\n\nThe sustainability of the Whaddon site is in doubt both because of the accessibility and traffic issues but also because the public transport options are based on buses all of which have to route through St. Barnabas to the City. There are no rail options and the active travel proposals from Taylor Wimpey have been dismissed by Active Travel England as unambitious and underfunded leading to minimal progress on modal change over the planned 10 year period."]
["Planning agent or developer","Land owner",20,"","","","","","","","","","","","","","","","","Every plan should seek to meet the full objectively assessed housing need in accordance with the requirements of the NPPF. The standard method provides only the minimum number of homes such that account needs to be taken of other factors such as previous levels of housing delivery, or previous assessments of need, economic and demographic considerations, and the needs of specific groups. \n\nThe annual housing need figure needs to ensure that it represents positive planning, is justified, and will be effective in meeting housing needs and addressing the local and national housing crisis and is consistent with national policy and guidance. \n\nIt is strongly recommended that the plan include for a greater number of homes (through increasing the housing requirement figure or allocating additional sites) to address problems in the delivery of new homes. This was recommended by the Inspectors who examined the adopted Joint Core Strategy (JCS). Given the significant problems in delivering the necessary growth identified in the adopted JCS the new Plan should make an even greater allowance this time around. \n\nWe are concerned that the current overall 20-year target of 35,700 new homes does not satisfy the above aims. \n\nThe need for urgent delivery of homes is underlined by the 2023 Cheltenham Housing Land Supply Position Statement identifying a supply of 4.84 years, the 2023 Tewkesbury Interim Housing Position Statement stating a supply of 3.24 years and the 2023 Gloucester Five Year Housing Land Supply Statement identifying 5.2 years. \n\nThe overall target of 35,700 is noted; however, it is considered that identification of adequate amounts of land does not guarantee its timely or eventual delivery. This is typified by evidence of delivery in Cheltenham, with examples including: \n• Elms Park Urban Extension (Ref. 16/02000/OUT) – Submitted in 2016 and undetermined as of February 2024. \n• The ‘Golden Valley’ Urban Extension (Ref. 23/01875/OUT) – Allocated in 2017 JCS and only submitted for Planning in November 2023.","","","","","","","","","","","","","","","","","","","","Scenario 1 ‘Urban concentration’ is supported in principle. The conversion or rebuilding of retail or other town centre properties into housing or mixed-use schemes is considered to be an appropriate way of enhancing both the quality and placemaking of an area, as well as helping to increase local housing supply. \nDespite the support in principle for Scenario 1, it is clear that this scenario alone could not deliver sufficient new homes and jobs for two key reasons. First, the number of opportunities that are currently available is very limited. Secondly, the cost and difficulty in redeveloping brownfield sites makes this option very uncertain in terms of delivery. As a result, further scenarios are considered to be required to deliver the necessary housing over the plan period in tandem with Scenario 1. \n\nScenario 2 ‘Urban extensions’ \nScenario 2 ‘Urban extensions’ is strongly supported and considered to be a sound option to ensure that new housing is delivered in sustainable locations where there is existing infrastructure in place. It is fully agreed that this method can deliver a range of available sites that will enable the Council’s to meet their housing and economic needs in full. \nMany of the potential urban extension parcels would include land without long-leases that would otherwise hamper development timeframes. This means that urban extension sites, such as our Client’s Site at Land to the East of the A417, Churchdown, Gloucester, can be delivered quickly and efficiently to create the new homes and jobs that are desperately needed. \nWe note that one of the identified benefits of this scenario is that ‘Development can be delivered close to where the need arises, reducing the likelihood of unnecessary travel into and out of the area.’ We fully agree with this statement. The importance of this benefit should not be understated, as it would create the context to support sustainable travel and would allow areas to self-sustain. In other words, they could thrive independently and outside of intervention/local authority funding. \nThis scenario would also allow additions to urban areas to be made carefully, with an emphasis on placemaking. We also agree that this scenario would create the ‘Opportunity to enable sites to be comprehensively planned to incorporate social, economic and environmental infrastructure, e.g., everyday shops and services and open spaces.’ \nOverall, this scenario is considered to be particularly pertinent to the ensuring the delivery of the necessary housing over the plan period in a timely manner. It is also considered to be by far the most sustainable scenario for the delivery of housing over the plan period. \n\nScenario 3 ‘Urban extensions, avoiding the Green Belt’ \nWe do not support Scenario 3 ‘Urban extensions, avoiding the Green Belt’. Paragraph 145 of the NPPF is clear that Authorities may choose to review and alter Green Belt boundaries through the plan making process where exceptional circumstances are fully evidenced and justified. \nIn our opinion, it is clear that such a scenario would be detrimental to meeting housing needs and ensuring the plan achieves its goals in relation to achieving sustainably located residential development in locations which are on existing public transport corridors and/or near existing key services and facilities that can be accessed by sustainable transport modes. \nIn addition, this scenario fails to fully consider the level of statutory protection that should also be afforded to the AONB. \nWe support the Council’s assessment that a combined restriction would only provide for a limited range of housing types, sizes and tenures and therefore not meet the required delivery rates over the plan period. \nIt is considered that this scenario would be detrimental to the spatial strategy as it would exclude more suitable and sustainable locations for the delivery of new homes when these are often in the most sustainable locations on existing transport corridors and near a range of existing employment provision as well as other services and facilities that are accessible by sustainable transport modes. \n\nScenario 4 ‘New strategic settlement’ \nIn our opinion, Scenario 4 ‘New strategic settlement’ should only really be considered when all other opportunities have been exhausted. First and foremost, it is considered to be better to locate development where it will support existing services and facilities as per Scenario 2: Urban Extensions. \nSecondly are the concerns associated with the delivery of new settlements: \nThe costs for the delivery of new infrastructure can have significant impacts on overall viability. This can result in the delivery of sub-standard infrastructure and supporting services, limited affordable housing, or even a scheme that cannot progress or is subject to lengthy delays. \nLarge schemes take a significant amount of time to develop masterplans and work through the planning and political frameworks. If then approved, time is required for infrastructure delivery before any homes or employment sites can come forward. \nNew settlements have limited benefits for existing residents, with new homes being located away from existing jobs and populations being taken away from existing business that depend on local footfall for their economic success. Given the collective lack of housing land supply for Cheltenham, Tewkesbury and Gloucester, and the time delays associated with new settlements, it is considered that any overreliance on Scenario 4 could result in long-term harm to the SLP being able to adequately deliver housing where it is needed. \n\nScenario 5 ‘Rural Dispersal’ \nScenario 5 ‘Rural Dispersal’ is supported in principle, but this should be delivered in tandem with scenarios 1 and 2 to ensure the broadest range of possible options to deliver the homes needed across Cheltenham, Gloucester and Tewkesbury is achieved and to ensure that sustainable patterns of development are achieved. \nDevelopment in rural areas is important for the growth and longevity of smaller settlements. However, it is our opinion that the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan should have an overall focus on providing housing allocations in larger, more sustainable settlements which have better infrastructure provision and are in proximity to Cheltenham, Gloucester and Tewkesbury. \n\nScenario 6 ‘Sustainable transport scenario’ \nScenario 6 ‘Sustainable transport scenario’ is supported due to the limited infrastructure costs associated. \nThis scenario would ensure that development can be promoted that encourages the reduction in use of private vehicles and supports a movement towards walking and cycling. \nIt is noted that this scenario is not considered to be independent of other scenarios and in appropriate locations would work alongside scenarios 1, 2 and 5. In fact, we would argue that the best location for this approach is at sites on the edge of the existing settlements such as our client’s Site.\n\nIn summary it is clear that scenarios 1 and 5 would not be capable of delivering sufficient levels of development to meet the required targets alone. We are also concerned that scenario 4 would pose significant issues for ensuring that homes are delivered in a timely manner and in the most sustainable places to meet identified needs.\nOverall, we fully support Scenario 2 and we also consider that a hybrid approach incorporating scenarios 1, 2, 5 and 6 would provide the most sustainable option that will ensure that housing delivery is maximised and that housing needs are suitably addressed throughout the plan period.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","Q[1] It is not unacceptable for the Plan period to cover a 15-year period albeit the 15 years should start from the point of adoption. Notwithstanding this, given the area’s constraints, previous and current problems in the delivery of the necessary growth (as evidenced by the delivery of the adopted JCS overall strategy) and to provide certainty on the release of the Green Belt we would recommend the new Plan looks forward over a longer timeframe of say 20 years.\n\n[Q8] We support the proposed 10% Biodiversity Net Gain requirement as it is in line with legislation and national policy requirements. It should also be noted that Paragraph 006 of the PPG specifically states:\n\n“Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.”\nParagraph: 006 Reference ID: 74-006-20240214 \n\nAs such, if such a policy was to be considered, this would need to be fully justified and its impact on the viability considered and evidenced to ensure such a policy is justified and in accordance with national policy.\n\nSite submission 71 hectares Land East of A417 Churchdown"]
["Planning agent or developer","Stansgate Planning",30,"","","","","","","","","","","","","The SLP must seek to address the needs of all members of the community. The consultation paper recognises that the population is aging and as such accommodation should be made  available specifically to meet the needs of older persons. Permanent residential caravans are highly sought after by older people for many reasons, \nincluding:\n• They are generally lower cost;\n• They are usually warden maintained providing an element of security for residents;\n• Properties are single storey thereby removing the need to climb stairs which can prove \ndifficult for older persons;\n• Private garden areas are very small and thus more manageable for residents\n• They allow older people to stay in their own homes for longer, in accordance with the \nGovernment aims\n• They create small communities which is beneficial to residents health and wellbeing\nThere should be a specific policy in the SLP which recognises the important contribution permanent \nresidential caravans can make towards meeting the housing need of the older population, and land\nshould be allocated to meet the identified demand – as extensions to existing sites and new sites","","","","","","","","The SLP must seek to address the needs of all members of the community. The consultation paper recognises that the population is aging and as such accommodation should be made available specifically to meet the needs of older persons.","","","","","","","","","","","","","","","","","","","","[Q1.] Paragraph 22 of the Framework (December 2023) requires strategic policies to look ahead over a  minimum period of at least 15 years, to be extended to at least 30 years where larger scale  developments (new towns or significant extensions to existing settlements) to take into account  the likely timescale for delivery.  It is likely that this plan will have to allocated larger scale developments and as such a longer  timeframe should be adopted, at least 20 years and potentially 30 years, to ensure delivery. The end date should also take into account the likely delays in plan preparation rather than proposing the minimum 15 years to minimise risks.\n\n[29] The Plan acknowledges that the eventual strategy will include elements from a number of the development scenarios and this recognition is strongly supported. In particular existing sustainable settlements must be able to continue to meet their housing needs, for both market and affordable housing. New allocations should therefore be made to all settlements already \nidentified as Rural Service Centres and Service Villages.\nIn making this response it is noted that Woodmancote remains a sustainable settlement with a range of local services and facilities including two nursery schools, a primary school, a newsagent, a public house, a village hall and playing fields. There is a limited bus service taking residents to a major supermarket twice weekly. The village also abuts Bishops Cleeve which contains a substantial range of services and facilities, together with bus links to several other settlements including Tewkesbury and Cheltenham. Additional land for housing should made available for development at the settlement to meet future needs and to ensure it retains its current level of local services and facilities. Given the already successful permanent residential caravan site within the settlement, further extensions to that development should be supported."]
["Planning agent or developer","Tritax Symmetry Ltd","","","","","","","","","","","","","","","","","","","","","","","","","",{"$cut":{"chars":24727,"head":"The NPPF (2023) states 85: “Planning policies and decisions should help create the conditions \nin which businesses can invest, expand and adapt. Significant weight should be placed on the \nneed to support economic growth and productivity, taking into account both local business needs \nand wider opportunities for development. The approach taken should allow each area to build \non its strengths, counter any weaknesses and address the challenges of the future. This is \nparticularly important where Britain can be a global leader in driving innovation, and in areas \nwith high levels of productivity, which should be able to capitalise on their performance and \npotential.” (Paragraph 85). [emphasis added]\n2.16 NPPF Paragraph 87 states “Planning policies and decisions should recognise and address the \nspecific locational requirements of different sectors. This includes making provision for clusters \nor networks of knowledge and data-driven, creative or high technology industries; and for \nstorage and distribution operations at a variety of scales and in suitably accessible locations.”\n(Paragraph 87 of the NPPF). [emphasis added]\n1.20 NPPF Paragraph 86 states “That Planning policies should: a) set out a clear economic vision and \nstrategy which positively and proactively encourages sustainable economic growth, having \nregard to Local Industrial Strategies and other local policies for economic development and \nregeneration….” As stated above, the sites are located on land surrounding Quedgeley \nInterchange, where Junction 12 of the M5 intersects the B4008 and the “The M5 spine is a focus for growth in Gloucestershire and beyond” (GFirst LEP Draft Local Industrial Strategy 2019, page \n16), therefore development on the site for logistics has regard to the Local Industrial strategy.\n2.17 Furthermore, the economic objectives of sustainable development (NPPF paragraph 8) states \nthat the planning system needs to be responsive by ensuring sufficient land of the right types is \navailable in the right places and at the right time to support growth, innovation and improve \nproductivity. PPG (paragraph: 031 Reference ID: 2a-031-20190722 (Revision date: 22 07 2019), \nstates that: “The logistics industry plays a critical role in enabling an efficient, sustainable and \neffective supply of goods for consumers and businesses, as well as contributing to local \nemployment opportunities, and has distinct locational requirements that need to be considered \nin formulating planning policies (separately from those relating to general industrial land).”\n2.18 According to the British Property Federation (BPF) economic productivity of £124 billion was \ngenerated by the logistics sector in 2019 (‘Delivering the Goods in 2020: The Economic Impact \nof the UK Logistics Sector’, (2020)). There is robust growth in the industrial and logistics market \nas structural change is witnessed in high street retail and growth of e-commerce drives activity \ninto the logistics sector.\n2.19 In a recent Secretary of State Call In decision (APP/N4205/V/20/3253244), he agreed with his \nInspector’s analysis of need including (paragraph 227): “Information from the British Property \nFoundation (BPF) confirms a widely held view that rapid growth being experienced in the logistics \nsector of the UK has been due to structural changes to high street retailing and a commensurate \ngrowth in e-commerce. This shift has been accelerated by the ongoing Covid19 pandemic \nrestrictions on personal movement. The warehousing and logistics sector has proved resilient in \nthe current pandemic. It is therefore to be expected that this sector will be instrumental in the \npost-pandemic recovery of the wider UK economy.”\n2.20 More recently the British Property Federation (BPF) (Levelling Up – the Logic of Logistics’ January \n2022) states that in the light industrial, B2 and B8 Use Classes (i.e., the uses classes that require \nwarehouses or factories with associated yard space) £232 billion of GVA was generated and 3.8 \nmillion jobs. The report concludes that the sector generates significant economic "}}," Paragraph 5.29 of the Issues and Options paper for the SLP states “One of the roles of the SLP \nwill be to establish the right level of employment growth and ensure that the right type of \nemployment land is provided in the right sorts of locations for business wishing to invest, expand \nand adapt.\n2.53 The Paragraph 5.36 of the of the Issues and Options paper for the SLP recognises that the M5 \ncorridor is a “magnet for employment growth, as acknowledged in the Local Transport Plan. This \nis because businesses, their supply chains, workers and consumers collectively depend upon a \ngood quality highway network to move goods, for delivery services, travel to work and other \nservice facilities. “\n2.54 As stated above, there is an established need for employment floorspace in Gloucestershire. It \nis submitted that the next considerations should be where should the employment floorspace \nbe located taking account of designations affecting a site, access to the strategic road network \nand the ability to access the site using sustainable modes of transport.\n2.55 The Local Transport Plan recognises that the importance of the M5 corridor to employment \ngrowth stating it is a magnet for employment growth. The Strategic Local Plan should therefore \nallocate new employment sites in locations that are in close proximity to the M5. The sites that \nare allocated should be deliverable and developable in order to ensure they can meet \nemployment needs once planning consent has been granted.\n2.56 As stated above, the BPF representations set out in paragraph 3.39 above suggests a two-tiered\napproach to employment allocation identifying ‘larger-than-local’ employment sites alongside\nsites to meet local needs and that where unmet need cannot be met within the market area will \nbe met through cross-boundary co-operation/collaboration. It is submitted the TSL sites in \nStroud which are located adjacent to the boundary of the SLP (but outside of) meet these \ncriteria. The site(s) suitability for development is summarised in Appendix 3.\n2.57 The key criteria for successful logistics (Use Class B8) sites are motorway proximity, junction \naccess, connectivity to road, rail, air and sea as well as the size of the site and the potential \nquantum of accommodation.\n2.58 The M5 corridor has been identified in the SLP as a key location for industrial and distribution \noccupiers in Gloucestershire. \n2.59 It is important to take advantage of the location to the M5, flood risk and Green Belt affecting \nthese sites and Gloucestershire economic strengths in terms of labour supply. The SLP should \ntake a pro-active role in creating the conditions within which existing and potential new \nemployers can flourish, with a particular emphasis on spatial planning. Action should be taken \nto identify the appropriate scale and distribution of employment allocations, with the potential \nvalue of strategic sites to serve a larger area fully considered.\n2.60 Given the close proximity of Sites 1 and 2 to the M5 they are considered suitable and sustainable \nlocations for future employment development through a mix of B2 and B8 Units.\n2.61 The submission of the planning application for Site 1 demonstrates TSL commitment to bring \nthe site forward for development. At this stage there are no known technical or physical reasons \nthat would prevent the development of sites 1 or 2.\n2.62 Subject to the granting of planning consent both sites can be delivered without delay. We \ntherefore consider that Site 2 should be allocated as ‘larger than local’; ‘cross boundary’ site in \nthe Joint Strategic Local Plan for B2 and B8 employment development."," Paragraph 5.29 of the Issues and Options paper for the SLP states “One of the roles of the SLP \nwill be to establish the right level of employment growth and ensure that the right type of \nemployment land is provided in the right sorts of locations for business wishing to invest, expand \nand adapt.\n2.53 The Paragraph 5.36 of the of the Issues and Options paper for the SLP recognises that the M5 \ncorridor is a “magnet for employment growth, as acknowledged in the Local Transport Plan. This \nis because businesses, their supply chains, workers and consumers collectively depend upon a \ngood quality highway network to move goods, for delivery services, travel to work and other \nservice facilities. “\n2.54 As stated above, there is an established need for employment floorspace in Gloucestershire. It \nis submitted that the next considerations should be where should the employment floorspace \nbe located taking account of designations affecting a site, access to the strategic road network \nand the ability to access the site using sustainable modes of transport.\n2.55 The Local Transport Plan recognises that the importance of the M5 corridor to employment \ngrowth stating it is a magnet for employment growth. The Strategic Local Plan should therefore \nallocate new employment sites in locations that are in close proximity to the M5. The sites that \nare allocated should be deliverable and developable in order to ensure they can meet \nemployment needs once planning consent has been granted.\n2.56 As stated above, the BPF representations set out in paragraph 3.39 above suggests a two-tiered\napproach to employment allocation identifying ‘larger-than-local’ employment sites alongside\nsites to meet local needs and that where unmet need cannot be met within the market area will \nbe met through cross-boundary co-operation/collaboration. It is submitted the TSL sites in \nStroud which are located adjacent to the boundary of the SLP (but outside of) meet these \ncriteria. The site(s) suitability for development is summarised in Appendix 3.\n2.57 The key criteria for successful logistics (Use Class B8) sites are motorway proximity, junction \naccess, connectivity to road, rail, air and sea as well as the size of the site and the potential \nquantum of accommodation.\n2.58 The M5 corridor has been identified in the SLP as a key location for industrial and distribution \noccupiers in Gloucestershire. \n2.59 It is important to take advantage of the location to the M5, flood risk and Green Belt affecting \nthese sites and Gloucestershire economic strengths in terms of labour supply. The SLP should \ntake a pro-active role in creating the conditions within which existing and potential new \nemployers can flourish, with a particular emphasis on spatial planning. Action should be taken \nto identify the appropriate scale and distribution of employment allocations, with the potential \nvalue of strategic sites to serve a larger area fully considered.\n2.60 Given the close proximity of Sites 1 and 2 to the M5 they are considered suitable and sustainable \nlocations for future employment development through a mix of B2 and B8 Units.\n2.61 The submission of the planning application for Site 1 demonstrates TSL commitment to bring \nthe site forward for development. At this stage there are no known technical or physical reasons \nthat would prevent the development of sites 1 or 2.\n2.62 Subject to the granting of planning consent both sites can be delivered without delay. We \ntherefore consider that Site 2 should be allocated as ‘larger than local’; ‘cross boundary’ site in \nthe Joint Strategic Local Plan for B2 and B8 employment development.","","","","","","","","","","We request that the employment land requirements for the emerging SLP are specified. The \nemerging SLP should identify sites to meet this employment need and include reference to joint \nworking with Stroud District Council to bring forward Symmetry Park, Gloucester West and East \nfor large scale employment use. \n2.64 The Adopted JCS recognises that there is insufficient land inside the administrative boundary of \nGloucester to meet its housing needs:\n“In meeting the needs of Gloucester, it has been necessary to allocate sites on the edge of the \nurban area in Tewkesbury Borough. However, due to significant constraints and availability of \nland it has not been possible to allocate sites in the JCS to meet all of Gloucester’s need over the \nplan period. Nevertheless, Gloucester has a good supply of housing land for the short to medium \nterm that will enable it to meet its requirements to at least 2028/29. This will allow adequate \ntime for an early review of the plan to explore further the potential for additional sites to meet \nGloucester’s needs in the longer term towards the end of the plan period. This would also allow \nthe consideration of additional development options that may become available, both within and \noutside the JCS area. This could include the unlocking of further development opportunities \nwithin the urban area, as well as potential new urban extensions in Tewkesbury Borough and \nStroud District or elsewhere in the housing market area. The JCS authorities have a Memorandum \nof Understanding in place with Stroud in this regard” (Paragraph 3.2.16 Adopted JCS, December \n2017) \n2.65 The Adopted JCS recognises that a plan review will need to explore additional sites to meet \nGloucester’s housing needs, and we consider that the strategy set out in paragraph 3.2.16 of the \nAdopted JCS should also apply to the strategic employment needs of Gloucester. \n2.66 In the Adopted JCS, Policy SP2 addresses the Distribution of New Development. The reasoned \njustification for the policy states: \n“In addition, there is joint working with Wychavon District Council to look to bring forward the \ncross-boundary site at Mitton, adjacent to the town [Tewkesbury]. The adopted South \nWorcestershire Development Plan (2006- 2030) already includes a policy commitment to \nconsider, including through a review of the plan, meeting the needs of other authorities within \nthe SWDP area. The site at Mitton is specifically referenced in this context. In addition, there is \njoint working with Wychavon District Council to assess the potential and possible release of land \nat Mitton.” (Paragraph 3.2.17, Adopted JCS, December 2017) \n2.67 The Adopted JCS recognised that a site within the neighbouring authority of Wychavon could \nhelp to address the housing need of Tewkesbury in the right location immediately adjacent to \nthe town. This should also be the case for Symmetry Park, Gloucester West and East as the sites \nare strategically located in a logical position for employment use, that meet the specific \nlocational requirements of the logistics sector, and could contribute to Gloucester’s future \neconomic growth which is otherwise threatened by the lack of land within the administrative \nboundary. The sites are also easily accessible to Gloucester.\nGreen Belt\n2.68 It is acknowledged that parts of the SLP areas are designated as Green Belt land which prevents \nthe City from coalescing with Cheltenham.\n2.69 Land surrounding Junction 11 of the M5 is designated as Green Belt which is located north of \nGloucester and therefore restricts development unless very special circumstances through a \nplanning application or exceptional circumstances through the development plan process can \nbe demonstrated. The availability of non-Green Belt land to meet such development needs \nwould mean very special or exceptional circumstance would not be met. \n2.70 The NPPF is clear that strategic planning authority should be able to “demonstrate that it has \nexamined fully all other reasonable options for meeting its identified need for development \nbefore making changes to Green Belt boundaries”. It goes on to state that this will be assessed \nthrough the examination of its strategic policies and “whether the strategy has been informed \nby discussions with neighbouring authorities about whether they could accommodate some of \nthe identified need for development, as demonstrated through the statement of common \nground” (Paragraph 146).\n2.71 As stated above one of the most important locational requirements for strategic employment \nsites is an accessible location close to the motorway network. Gloucester’s economic success is \nunderpinned by its immediate access to two motorway junctions onto the M5, however the land \nsurrounding Junction 11 is designated Green Belt whereas the land surrounding Junction 12 is \nnot. \n2.72 Land outside of the Green Belt which is sustainably located, available and deliverable, such as \nSymmetry Park, Gloucester West and East, should therefore be considered for development \nbefore Green Belt land.\n2.73 The following scenarios are considered the most appropriate for SLP, notably all these scenarios\ninclude lager scale development options on the boundary on the SLP area (potentially extending \nbeyond its boundary) and sites 1 and 2 could meet the requirements of these scenarios.\ni. Scenario 2 Urban Extensions\n2.74 The pros for this scenario as set out below are agreed with:\n• Likely range of available sites may enable housing and economic needs to be met in full. \n• Development can be delivered close to where the need arises, reducing the likelihood \nof unnecessary travel into and out of the area. \n• Provides the opportunity for a wide range of housing types, sizes, and tenures to meet \nlocal need.\n• Urban extensions to existing urban areas would increase the catchment population to \nshops, services and facilities in city and town centres, access to employment \nopportunities, and existing/improved public transport, walking, and cycling (depending \non location). \n• Would provide opportunity to be supported by high quality public transport \ninfrastructure such as Mass Rapid Transit. \n• Opportunity to enable sites to be comprehensively planned to incorporate social, \neconomic and environmental infrastructure, e.g. everyday shops and services and open \nspaces.\nHowever, it is noted that this scenario does include sites within the Green Belt. As stated above, \nhe NPPF is clear that strategic planning authority should be able to demonstrate that it has \nexamined fully all other reasonable options for meeting its identified need for development \nbefore making changes to Green Belt boundaries. \n2.76 There is therefore a clear emphasis on the need to work with neighbouring authorities before \nGreen Belt boundaries are amended to accommodate the needs for development.\nii. Scenario 3: Urban extensions, avoiding the Green Belt\n2.77 The pros for this scenario as set out below are agreed with:\n• Protects the existing Green Belt, limits the loss of green field sites and higher quality \nagricultural land. \n• Some benefits from an increased catchment population to shops, services and facilities \nin city and town centres, access to employment opportunities, and existing/improved \npublic transport, walking and cycling, due to constraint on development and less \nsustainable locations. \n• Would provide opportunity to be supported by high quality public transport \ninfrastructure such as Mass Rapid Transit. \n• Some opportunity to enable sites to be comprehensively planned to incorporate social, \neconomic and environmental infrastructure, e.g. everyday shops and services and open \nspace.\niii. Scenario 6: Sustainable transport scenario\n2.78 The pros for this scenario as set out below are agreed with:\n• A pattern of growth which would provide optimum accessibility by sustainable transport \nand active travel, making a significant contribution to creating a more sustainable \nGloucestershire and mitigating the effects of climate change.\n• Development close to main existing settlements would provide opportunities for \naccessing larger shops, services and facilities and jobs by connecting with existing and \nenhanced sustainable transport networks and the opportunity for active travel. \n• Would enable a significant proportion of, or all, housing and employment needs to be \nmet close to where they arise, reducing the likelihood of unnecessary travel into and \nout of the JSP area. \n• Could provide a wide range of housing sizes, types and tenures; and a choice of \nemployment space. \n• Strategic scale development in locations along mass transit routes would support the \nvitality and viability of city and town centres and enable clusters of employment growth \nclose to large built-up areas. \nWould support the development of brownfield sites within and adjoining large \nsettlements.\n• Opportunity to enable sites to be comprehensively planned to incorporate social, \neconomic and environmental infrastructure, e.g. everyday shops and services and open spaces.","Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","","","Duty to Cooperate \n2.3 The NPPF (2023) at paragraph 11 states:\n“Plans and decisions should apply a presumption in favour of sustainable development.\nFor plan-making this means that:\n• all plans should promote a sustainable pattern of development that seeks to: meet \nthe development needs of their area; align growth and infrastructure; improve the \nenvironment; mitigate climate change (including by making effective use of land in \nurban areas) and adapt to its effects;\n(b) strategic policies should, as a minimum, provide for objectively assessed needs for housing \nand other uses, as well as any needs that cannot be met within neighbouring areas 6 , unless:\n(i) the application of policies in this Framework that protect areas or assets of particular \nimportance provides a strong reason for restricting the overall scale, type or distribution of \ndevelopment in the plan area 7 ; or\n(ii) any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, \nwhen assessed against the policies in this Framework taken as a whole.” (emphasis added)\n(6) As established through statements of common ground (see paragraph 27). “\n2.4 Paragraphs 24 to 27 of the NPPF states that:\n“Local planning authorities and county councils (in 2-tier areas) are under a duty to cooperate \nwith each other, and with other prescribed bodies, on strategic matters that cross \nadministrative boundaries.\nStrategic policy-making authorities should collaborate to identify the relevant strategic matters \nwhich they need to address in their plans. They should also engage with their local communities \nand relevant bodies including Local Enterprise Partnerships, Local Nature Partnerships, the \nMarine Management Organisation, county councils, infrastructure providers, elected Mayors \nand combined authorities (in cases where Mayors or combined authorities do not have planmaking powers).\nEffective and on-going joint working between strategic policy-making authorities and relevant \nbodies is integral to the production of a positively prepared and justified strategy. In particular, \njoint working should help to determine where additional infrastructure is necessary, and whether \ndevelopment needs that cannot be met wholly within a particular plan area could be met \nelsewhere.\nIn order to demonstrate effective and on-going joint working, strategic policy-making authorities \nshould prepare and maintain one or more statements of common ground, documenting the \ncross-boundary matters being addressed and progress in cooperating to address these. These \nshould be produced using the approach set out in national planning guidance, and be made \npublicly available throughout the plan-making process to provide transparency.” (emphasis \nadded)\n2.5 The NPPF is clear that “strategic policies should, as a minimum, provide for objectively assessed \nneeds for housing and other uses as well as any needs that cannot be met within neighbouring \nareas.” (Paragraph 11, NPPF). \n2.6 In addition, the NPPF at paragraph 87 and the PPG is clear that the warehouse and logistics \nsector have very specific locational requirements, which includes significant amounts of land \nand excellent accessibility to the strategic road network. \n2.7 During the future Examination of the emerging SLP, the Inspector will assess the plan to \ndetermine if it is sound. One of the ‘tests of soundness’ for the Local Plan is for it to be, \n“Positively prepared’ – providing a strategy which, as a minimum, seeks to meet the area’s \nobjectively assessed needs and is informed by agreements with other authorities, so that unmet \nneeds from neighbouring areas is accommodated where it is practical to so and is consistent with \nachieving sustainable development.” (Paragraph 35a, NPPF).\n2.8 The “positively prepared” test is underpinned by the requirement for Local Authorities to \ncomply with the Duty to Cooperate. Gloucester City are one of the Joint Core Strategy (JCS)\nauthorities, and together with Tewkesbury and Cheltenham have prepared a strategic document \ncovering the areas of 3 local authorities. We do not dispute that this is a good example of Duty \nto Cooperate, however, the JCS authorities should still cooperate with its other neighbouring \nauthorities including Stroud District on strategic matters including employment where it cannot \nmeet its identified needs. \n2.9 The SLP will need to demonstrate in a written evidence base how they have cooperated with \nneighbouring authorities on cross boundary issues including employment need and therefore \ncomplied with the Duty to Cooperate. In this respect we consider that the SLP should collaborate \nwith Stroud District Council on how the demand for large scale employment could be met. Site \n1 (Gloucester West) is already a draft allocation in the emerging Stroud Local Plan and Site 2\n(Gloucester East) (which is an obvious extension to Site 1) could be shown as a cross boundary \nsite to meet the SLP’s needs for logistics floorspace. \n2.10 As stated above:\n• There is a significant need for additional logistics floorspace in the SLP area;\n• This need is unable to be met in the SLP area boundaries/area and therefore the SLP will \nneed to look at sites beyond its boundary, in particular on sites on the Strategic Road \nNetwork (i.e. within close proximity to the M5) locations that meet the locational \nrequirements of the logistics sector;\n• To request that the SLP should support the allocation of Site 1 (Gloucester West) which \nis a draft allocation in the emerging Stroud District Draft Local Plan which is currently \nunder examination (and recognise that it is a suitable site); and \nRepresentation on the Joint Strategic Local Plan 8 Frampton Town Planning Ltd\nLand at M5 Junction 12 February 2024\nOn behalf of Tritax Symmetry. PJF/NW/LS/10945\n• To request that the SLP support the potential allocation of Site 2 (Gloucester East) by \nrecognising in the emerging SLP that sites are required beyond the SLP boundaries and \nby supporting the allocation of Site 2 in any further full or partial review of the Stroud \nDistrict Plan (i.e. post adoption of the current emerging plan which is under \nexamination);\n• To confirm the sites are in an entirely suitable and sustainable location to accommodate \nemployment development.\n• To confirm that the sites are deliverable, available now and can be readily developed, \ntaking into account respective constraints.\n2.11 The SLP needs to assess economic needs by a two-tiered approach to employment allocations, \nidentifying ‘larger-than-local’ employment sites alongside site to meet local needs, and \ndemonstrate where unmet need within the relevant market area will be met through crossboundary co-operation/collaboration."]
["Planning agent or developer","Wain Homes",30,"","","No","The Draft Vision set out within the SLP sets out at its third paragraph that: \n“People’s housing needs will have been met through the provision of \nsustainable, high-quality market, affordable and other specialist homes set in \nbeautiful, safe places and conforming to sustainable standards of design and \nconstruction. The focus will have been on making best possible use of \nbrownfield sites in built up areas and large-scale, comprehensively planned \nnew development to ensure our valuable green spaces and highest quality \nfarmland are preserved”. \nThe following paragraph goes on to state that “Growth in sustainable locations will \nhave enabled the provision of healthy, accessible and walkable neighbourhoods”. \nWhilst we fully agree with the thrust of the above, we are concerned that the Draft \nVision, while highlighting the benefits of brownfield development, does not refer to the \nneed to consider advantages of well managed and sustainable development on \nappropriate greenfield or as yet undeveloped locations to deliver requisite housing and \njobs. \nAs such, we consider the failure of the Draft Vision to acknowledge that well planned \ngreenfield development is likely to be required in some form to be remiss. We would \ntherefore recommend that additional wording is included within the fourth paragraph \nof the Draft Vision to refer sustainable greenfield growth where further assessment \nwork deems this to be appropriate. \nThe Draft Strategic Objectives identified within the draft JCS include the following \nunder the objective of meeting the challenges of climate change: \n“Ensuring growth takes place in sustainable locations that minimise the need \nto travel and provide genuinely sustainable transport and active travel options. \nMaking the most effective use of previously developed land, including higher \ndensity development in city and town centres and other locations well served \nby public transport. \nEnsure development effectively integrates with existing development, and / or \nis a self-contained development that provides shops, services, facilities through \nwalking, cycling or public transport”. \nThe locational Strategic Objectives set out above clearly place an emphasis on \naccessibility when making decisions about locations for housing development. Our \nanalysis leads to the conclusion that this is not just a question about existing \ninfrastructure but also new infrastructure and how development can better integrate \nthe existing urban area together. \nThis leads to our recommendation that reference is made within the Draft Startegic \nObjectives under the banner of meeting the challenges of climate change to \nappropriately considered development on greenfield land, given that some element of \nthis approach is likely to be required. This is reflective of the opportunity afforded in \nterms of contribution to development objective on sites such as Tuffley. \nUnder the objective of delivering a wide choice of homes that meet the needs of our \ncommunities, the points identified include: \n“Delivering sufficient new homes in the right places to meet the needs of our \ncommunities, including market and affordable, specialist homes (e.g. older \npersons), Gypsys, Travellers and Travelling Showpeople and those wishing to \nbuild their own homes (self and custom build homes). \nWe wholly agree with the above and consider this a fundamental objective for the SLP. \nIn our view, it is clear that larger scale greenfield sites, such as that at Tuffley, can be \nseen to offer the most sustainable opportunities to deliver on this. \nfundamentally our position is that the Draft Vision and Draft Strategic Objectives must, in order to be \nrealistic and indicative of the likely shape of the development plan as a whole, refer to \nthe need for some level of development on greenfield sites which offer opportunities \nfor sustainable development, tackling previous unsustainable development patterns \nacross the three districts. \nPursuant to the above, we note that HELAA Draft Site Assessments for Gloucester City\nincludes the identification of the Site as being potentially developable, as per the extract \nbelow, with a density range of between 40 and 50 dwellings per hectare. As set out \nabove, the site boundary below differs very slightly from that to which these \nrepresentations relate, with the eastern boundary having been pulled back slightly. We do not consider that this change affects any of the key considerations with relation to \nthe suitability, availability and deliverability of the Site for development","","","","","","No","","","","","","No","National policy and guidance are clear that the standard method can be used to \ncalculate a minimum annual local housing need figure, which is an advisory starting \npoint. NPPG states that the standard method identifies a minimum annual housing \nneed figure; it does not produce a housing requirement figure2. It is clearly stated \nwithin the NPPG that there will be circumstances where it is appropriate to consider \nwhether actual housing need is higher than the standard method indicates. \nFurthermore, the Standard Method does not take into account any unmet need from \nneighbouring authorities or historic underdeliver amongst the SLP authorities. It is also \nthe case that the housing need figure generated by way of the standard method may \nchange as inputs are variable. Therefore, whilst the SLP should use the standard \nmethod to calculate local housing need, this should not be simply translated into the \nhousing requirement figure. The final housing requirement figure will evolve over the \nplan preparation process and should be informed by evidence, including evidence of \nany unmet need from neighbouring authorities and analysis of affordable housing need. \nThe housing requirement may therefore need to increase to accommodate unmet need \nfrom neighbouring areas, the extent of which is to be determined through the Duty to \nCooperate. \nThe latest Gloucestershire Local Housing Needs Assessment was published in 2020 and \nincludes analysis for all Gloucestershire authorities, including Forest of Dean, Stroud \nand Cotswold. The LHNA reiterates the above, noting at paragraph 10 that “The LHN \nprovides the starting point for establishing the final housing requirement which will be \nplanned for through strategic policies. In determining the local plan housing target, it \nwill be necessary for the local authorities to consider whether or not the LHN could be \nmet within their area, taking account of any constraints on land availability. In \nparticular, it will be important to balance the need for housing against policies intended \nto restrict development in Areas of Outstanding Natural Beauty and any other areas \nwith similar constraints”. \nBoth the Cotswold and Stroud areas are heavily constrained by the Cotswold AONB \nand large areas of Flood Zone 3. It is therefore likely that that there will be significant \nunmet need from these neighbouring areas, which should be planned for as part of the\nSLP. \nThe LHNA goes on to set out an analysis of affordable housing need (“AHN”), noting \nat paragraph 8.65 that “the overall need for affordable housing would comprise a total \nof 44,205 dwellings over the 20-year period 2021-2041, equivalent to an average of \n2,210 dwellings per annum”. This equates to 67% of the LHN. \nThe LHNA then seeks to justify a reduction in this figure by applying affordability criteria \nto identify an effective demand from those able to afford the various products that will \nbe available, despite neither the NPPF nor the NPPG identifying any such affordability \ncriteria to be applied to those households who aspire to own their own home. This \nreduction results in a figure of 19,037 over the 20 year period, equivalent to 30% of \nthe LHN. \nData published on an annual basis by the Department for Levelling Up, Housing and \nCommunities (“DLUHC”) indicates that average annual affordable housing delivery in \nGloucester over the past eight years has amounted to only 164 units per year, \nsignificantly below the estimated need in the SHMA 2015 (282 affordable units per \nannum)3. Furthemore, the number of households on the Council’s waiting list stood at \n4,817 in 2023, a higher figure than in 30 of the preceeding 36 years.\nAs such it is clear that there are pressing affordability issues and a need to increase \nthe delivery of both market and affordable housing. We therefore strongly recommend \nthat the Councils increase the local housing requirement over that of the LHN \nsufficiently to arrest the trend of worsening affordability and affordable housing need.\n3 DLUHC (November 2023) Table 1011: additional affordable housing supply, detailed breakdown by local authority, \nTable 1011c\n4 DLUHC (December 2022) Table 600: numbers of households on local authorities’ housing waiting lists, by district, \nEngland, from 1987","","Our only comment in respect of the above is that any use of a figure below that arising \nfrom the standard method would be wholly inappropriate and counterinturitve given \nthe range of policy objectives the LPAs are looking to achieve. As above, we consider \nthat the allocation of the Tuffley site for development offers the opportunity to make \nsignificant contributions to housing delivery.","","","","","","","","","","","","Paragraph 5.51 of the draft SLP sets out that “The use of greenfield sites may raise \nviability issues due to the need for new infrastructure, or environmental constraints \nsuch as flood risk which will need to be mitigated. However, brownfield (sometimes \ndescribed as Previously Developed Land) often pose their own viability challenges”.\nWe agree with the broad principles of the above, but note that there is a distinction to \nbe drawn between greenfield sites located some distance from existing urban areas \nand those located adjacent or more proximate – such as the Tuffley site, which, as \nabove, can be considered to benefit from nearby facilities and infrastructure, as \ndiscussed further below.","","","","","","\"As per paragraph 6.3, the JCS identifies the key urban areas of Cheltenham and \nGloucester as the focus for new development where housing and employment needs \ncan be provided close to where they are needed and where occupiers of new \ndevelopment can benefit from the existing and enhanced sustainable transport network. \nParagraph 6.4 furthers that due to limited land for development within Cheltenham and \nGloucester, the strategy also relied on urban extensions to their built-up areas, mostly \non land within Tewkesbury Borough Council’s area. \nThis section of the draft SLP sets out six different scenarios or ‘Spatial Options’ for \ndevelopment which are being examined in order to identify a preferred approach. It \nis noted that none of the scenarios will on their own deliver sustainable development; \nthe final strategy will be a combination of different elements. \nIt is noted at paragraph 6.11 that all currently known site opportunities in the urban \narea (i.e. the baseline capacity) are included as the starting point for all scenarios, in \norder to ensure that all brownfield sites, and those in urban areas, are identified first, \nbefore then considering other options, including sites on undeveloped land. \nParagraph 6.14 confirms that the consultation on the identified scenarios also presents \nan opportunity for “those who have already submitted a site to the councils to provide \nany new or updated information they may have to help the councils consider the \nopportunity fully”\nScenario 1 – Urban Concentration\nThis option is set out as comprising “much more intense development than would \ntraditionally be expected on urban sites in Gloucester and Cheltenham, particularly on \npreviously developed land”. It is noted that this scenario would not deliver sufficient \nnew homes and jobs, would only provide a limited range of housing types and would \nlikey result in harm to the setting and significance of important heritage assets. \nFurthermore, as acknowledged in para 5.51 of the Consultation Document, brownfield \nsites present viability challenges, which in turn would result in a lower rate of affordable \nhousing delivery. \nThe Gloucestershire SLP Authorities Sustainable Transport Strategy Broad Site \nAssessment Report, published in December 2023 comprises an assessment of draft \nHELAA sites for the SLP area against the range of development scenarios, aligning each to the development scenario with which it is deemed to best fit. The purpose of this \nassessment is to guage initial disadvantages and advantages from a transport \nperspective, taking four objectives and eight sub-objectives. For the purposes of the \nReport, we understand the Tuffley site to have been aligned with Scenaro 1, as per \nFigure 2-2 (extract in attachement)\nWhilst we fully support the recognition that the Tuffley site does indeed benefit from \nsignificant advantages in respect of its adjacency to the existing built up area of \nGloucester and therefore proximity to existing services and facilities, we do not agree \nthat the Site best fits with the ‘urban concentration’ scenario. In our view, the site \npresents an urban extension option, with the ability to deliver a sustainable pattern \nand form of development in a highly sustainable location. We refer to this below. \nScenario 2 – Urban Extensions\nIt is noted that this option would mean “seeking to deliver development as urban \nextensions to the key urban areas of Cheltenham, Gloucester and Tewkesbury Town, \nand could include sites which fall within the designated Green Belt”. The draft SLP \nfurther sets out that “Urban extensions may be one of the most effective ways of Whilst we fully support the recognition that the Tuffley site does indeed benefit from \nsignificant advantages in respect of its adjacency to the existing built up area of \nGloucester and therefore proximity to existing services and facilities, we do not agree \nthat the Site best fits with the ‘urban concentration’ scenario. In our view, the site \npresents an urban extension option, with the ability to deliver a sustainable pattern \nand form of development in a highly sustainable location. We refer to this below. \nScenario 2 – Urban Extensions\nIt is noted that this option would mean “seeking to deliver development as urban \nextensions to the key urban areas of Cheltenham, Gloucester and Tewkesbury Town, \nand could include sites which fall within the designated Green Belt”. The draft SLP \nfurther sets out that “Urban extensions may be one of the most effective ways ofWhilst we fully support the recognition that the Tuffley site does indeed benefit from \nsignificant advantages in respect of its adjacency to the existing built up area of \nGloucester and therefore proximity to existing services and facilities, we do not agree \nthat the Site best fits with the ‘urban concentration’ scenario. In our view, the site \npresents an urban extension option, with the ability to deliver a sustainable pattern \nand form of development in a highly sustainable location. We refer to this below. \nScenario 2 – Urban Extensions\nIt is noted that this option would mean “seeking to deliver development as urban \nextensions to the key urban areas of Cheltenham, Gloucester and Tewkesbury Town, \nand could include sites which fall within the designated Green Belt”. The draft SLP \nfurther sets out that “Urban extensions may be one of the most effective ways of Whilst we fully support the recognition that the Tuffley site does indeed benefit from \nsignificant advantages in respect of its adjacency to the existing built up area of \nGloucester and therefore proximity to existing services and facilities, we do not agree \nthat the Site best fits with the ‘urban concentration’ scenario. In our view, the site \npresents an urban extension option, with the ability to deliver a sustainable pattern \nand form of development in a highly sustainable location. We refer to this below. \nScenario 2 – Urban Extensions\nIt is noted that this option would mean “seeking to deliver development as urban \nextensions to the key urban areas of Cheltenham, Gloucester and Tewkesbury Town, \nand could include sites which fall within the designated Green Belt”. The draft SLP \nfurther sets out that “Urban extensions may be one of the most effective ways of supporting high quality public transport infrastructure such as the Mass Rapid Transit \nscheme proposed in Gloucestershire County Council’s Local Transport Plan”. \nAs above, whilst we note that the Gloucestershire SLP Authorities Sustainable Transport \nStrategy Broad Site Assessment Report appears to categorise the Tuffley site \nrepresenting ‘urban concentration’, we are of the view that it represents ‘urban \nextension’, involving the delivery of a sustainable parcel of greenfield land – a strategy \nwhich has been accepted in the JCS as being both appropriate and necessary to meet \nthe development needs of the partner authorities. \nWhilst we do not intend to set out here full commentary of the Broad Site Assessment \ninsofar as it relates to the Tuffley site, it is clear that the Site performs strongly against \nmany objectives and sub-objectives, including ‘very high’ against both ‘access to key \nservices, including schools, employment, healthcare and retail within 20-min cycle’ and \n‘access to existing high quality bus services’. Critically, development within this location \noffers a unique opportunity to provide new homes which are already in close proximity \nto jobs, community facilities and retail and leisure services irrespective of where \nindividual homes are located on the site, and does not rely on over densification to \ndeliver viability on a challenging brownfield location. \nIt is noted at Section 4.6.1 of the Report that “A thread of commonality across the \nassessed HELAA sites and their associated development scenarios is that sites which \nare located either within or adjacent to areas that benefit from from good access to \nexisting sustainable transport networks and services emerge more positively from the \nBroad Site Assessment. Broadly speaking, Urban Concentration and Urban Extensions \nperform best due to the existing urban areas of Gloucester, Cheltenham and \nTewkesbury which also have a significantly higher frequency and wider offering of \nhealth, education, leisure, employment, open space and retail services. They therefore \nprovide the opportunity for these assets to be accessed by sustainable modes”. We \nfully agree with this, noting that the urban extension option – including the Tuffley site \n- therefore has the abiity to both deliver the range and quantum of housing required, \nas well as presenting a sustainable option in transport and access terms. \nIn our view, the above echoes paragraph 3.2.10 of the JCS, which sets out that “urban \nextensions are considered to be the most sustainable locations for new development \n(following existing urban areas) as they can share transport, social and service \ninfrastructure with existing urban areas and are located close to essential services”. \nWe also note that the diagram associated with this scenario identifies a larger scale \ndevelopment to the south of Gloucester and straddling the boundary with Stroud, \nbroadly reflective of the G2 site as set out above. As a complementary development \nopportunity to this wider development, we are of the view that the Tuffley site best \nsits in alignment with this scenario. \nScenario 3 – Urban Extensions, avoiding the Green Belt\nAs above, the presentation of Scenario 2 above notes that it could include sites \ncurrently falling within the Green Belt. Whilst the Tuffley site does not comprise Green \nBelt land and could therefore be considered to be aligned with Scenario 3, we are of \nthe view that given the policy implications for Green Belt land which will stand \nregardless, these two scenarios can effectively be combined to simply consider urban \nextensions, with sites considered on their merits. \nWe are mindful that an arbitrary avoidane of development on Green Belt sites would \nnot deliver sufficient new homes and jobs and would only provide for a limited range \nof housing types, sizes and tenures ad and that consequently such an approach would \nbe inconsistent with NPPF objectives of boosting the supply of housing as well as the \nDraft SLP Vision. \nScenario 4 – New Strategic Settlement\nThis option looks at the delivery of development through one or more comprehensive, \nmaster-planned new settlements of a minimum of 4,000 new homes, with supporting \ninfrastructure. It is noted that three potential locations have been identified to date, \nas follows: \n- around Boddington on land to the south of the A4109 between the A38 and M5 \ncorridors; \n- straddling the boundary of Tewkesbury Borough and the Forest of Dean between \nChurcham and Highnam in the south west of the SLP area; \n- to the east of the M5 at Ashchurch on the edge of the built-up area of Tewkesbury. \nThe third of these options is known as the Tewkesbury Garden Town, having been \nawarded Garden Town status in 2019. On this basis, work is currently being \nundertaken to develop plans for the site, including proposals for major improvements \nto Junction 9 of the M5.\nIt is noted that while this scenario could reduce the need to build on Green Belt land \n(except at Boddington) and would enable the provision of a wide choice of housing \nsizes, types and tenures, it would also be unlikely to provide for all of the new homes\nand jobs required, “resulting in worsening housing unaffordability and constrained \neconomic growth”. It is also acknowledged that this option would require longer lead \nin times to the delivery of homes and jobs, given the need for a significant amount of\nmasterplanning work and the co-ordination of transport and community infrastructure. \nFor these reasons, we do not support this development option, or this being a leading \ndevelopment option. In our view, the implementation of Scenario 2 (i.e. an urban \nextension scenario) would better deliver the objectives of enabling the provision of a \nhigh number and wide range of housing, without the costly – both in financial and \ntemporal terms – implications of massive transport and commununity infrastructure. \nScenario 5 – Rural Dispersal\nThis scenario looks at the distribution of growth widely across the rural area. It is \nnoted that while this scenario would be likely to safeguard the Green Belt, it would \nlikely harm the character and setting of existing settlements and surrounding \ncountryside and would be unlikely to provide for the full amount of new homes and \njobs needed. Whislt we recognise the broad merits of this approach, we do not support \nthis as a sole or primary scenario given the already identified negative implications for \nexisting settlements and their inhabitants. \nScenario 6 – Sustainable Transport Scenario\nThis scenario looks at delivering development in locations along existing and potential \nhigh frequency public transport, walking and cycling routes, specifically high frequency \nbus routes, Gloucestershire’s cycle spine and the proposed Gloucestershire Mass Rapid \nTransport system. \nThis scenario identifies the delivery of a Sustainable Transport Corridor extending \nnorth-south through the centre of Gloucester, linking to Stroud to the south, with an \nassociated development option broadly reflective the locaton of the Tuffley Site / Site \nG2. It is noted that this scenario would enable a significant proportion of, or all, \nhousing and employment needs to be met close to where they arise. \nIn general terms, Wain Homes are supportive of Scenario 6, noting the significant ‘pros’ \nidentified within the draft SLP document.\"","Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","","","[Q1.] Paragraph 2.8 of the draft SLP states that “the Government requires a plan to cover a period of at least 15 years from the point of adoption. Where the plan includes larger \nsites that will take longer to develop, the vision and policies can look further ahead to at least 30 years”. This is reflective of paragraph 22 of the NPPF.\nWhilst the draft SLP sets out at paragraph 2.10 that “The current timetable for the SLP is for submission to the Secretary of State in April 2026…On this basis, the SLP would \nneed to plan up to at least 2041”, it does not identify a plan period start date. This is an important consideration given the significant period of time across which the area will be without up-to-date strategic policies. \nThe Inspector’s Report relating to the adoption of the JCS notes at paragraph 76 that \n“Whilst the JCS authorities have sought to meet the full housing requirement for the Plan period, it is apparent from the HIS that insufficient sites can be identified at present for Gloucester and Tewkesbury. Overall, against the requirement of 35,175, there is currently a supply of 31,824 dwellings, leaving a shortfall of 3,351. However, there appear to be a number of possibilities for locating additional land and, therefore, focused reviews of Gloucester’s and Tewkesbury’s supply are proposed”\nParagraph 106 further states that “The unmet needs of Gloucester and Cheltenham, beyond their administrative boundaries, are only to be delivered on identified strategic allocations and any other sites with an agreed sharing mechanism through a \nMemorandum of Agreement. In order to allocate any additional SUEs, a review of the Plan would be necessary”.\nParagraph 106 further states that “The unmet needs of Gloucester and Cheltenham, beyond their administrative boundaries, are only to be delivered on identified strategic allocations and any other sites with an agreed sharing mechanism through a \nMemorandum of Agreement. In order to allocate any additional SUEs, a review of the Plan would be necessary”.In conclusion, paragraph 112 sets out that “Although the JCS is unable to provide \nsufficient, deliverable housing at the current time, it appears that there are credible options for identifying additional supply within the Plan period. Accordingly, by giving a policy commitment to undertake early focused reviews of Gloucester’s and \nTewkesbury’s supplies, this part of the Plan is made sound”. Consequently, JCS Policy \nREV1 states that “A partial review of the housing supply for Gloucester and Tewkesbury \nwill commence immediately upon adoption of the JCS.” An immediate review of the \nJCS did not and will not occur, given that it is to be replaced by the SLP.\nThe draft SLP does not mention the requirement for an immediate review of the JCS\nwithin the Introduction and Context chapter, which is a significant omission. The SLP \nmust take into account and plan for the period of time that the area is without an upto-date strategic plan and any shortfall in housing that arises in the interim. Our\nsuggestion is that the plan period should at the latest start in 2022.\nTurning back to the original question of how far in the future the SLP should cover, \npara 22 of the NPPF states “Where larger scale developments such as new settlements \nor significant extensions to existing villages and towns form part of the strategy for the \narea, policies should be set within a vision that looks further ahead (at least 30 years), \nto take into account the likely timescale for delivery.” Therefore to some extent the \nanswer to the question is dependent on the development strategy that is considered \nto be the most appropriate for delivering growth. However, we consider it likely that a \ndevelopment strategy that is able to meet the housing and economic needs of the area \nwill involve a component of larger scale development. We therefore suggest that the \nSLP should plan for a minimum of 30 years with the precise plan period to be informed \nby the likely timescales for delivery of any strategic allocations.\n\n Introduction\nMcLoughlin Planning has been instructed by Wain Homes to submit representations to \nthe Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan Issues and \nOptions Consultation (hereafter “the SLP”), in respect of their interests in land to the \neast of Stroud Road, Tuffley, which lies to the south of the built up area of Gloucester. \nCheltenham Borough Council, Gloucester City Council and Tewkesbury Borough \nCouncil (hereafter “the Councils”) are producing a Strategic and Local Plan (hereafter \n“the SLP”), which will replace the Joint Core Strategy (hereafter “the JCS”) and the \ncurrently adopted Local Plans for each Council area. \nThis Report makes a series of representations on the Draft SLP and seeks to promote \nWain Homes’ interests at Tuffley, which broadly reflects the site assessed as being \n‘potentially developable’ in the December 2023 Draft Housing and Economic Land \nAvailability Assessment (hereafter “the HELAA”), under reference 16NEW22. \nThe representations contained herein have been structured to follow the order and \nstructure of the Draft SLP and where relevant respond directly to the posed questions. \nWe look forward to engaging with the partner authorities further in the development \nof the SLP and welcome the opportunity to discuss the below in more detail should \nthat be required. \n[Q8} Planning Practice Guidance1 states:\n“Plan-makers should not seek a higher percentage than the statutory objective of 10% \nbiodiversity net gain, either on an area-wide basis or for specific allocations for \ndevelopment unless justified. To justify such policies they will need to be evidenced \nincluding as to local need for a higher percentage, local opportunities for a higher \npercentage and any impacts on viability for development. Consideration will also need \nto be given to how the policy will be implemented.”\nNo evidence has been provided as part of the consultation that justifies a higher \npercentage than 10% and we are not aware of any local circumstances that would \njustify such a policy."]
["Statutory/Specific Consultee","NatureSpace Partnership","","Section (d) should be expanded to include biodiversity, protected species and the nature recovery strategy.","","","","","","In relation to the construction of new buildings, where they present a risk to great crested newts the district licence is available as an option for developers to reduce their impact on great crested newts. ","","","","Yes"," Not only does the Council hold a District Licence for great crested newts, which can be highlighted in the Local Plan, but the Council is also in receipt of baseline data with regard to the use and implementation of the licence. Data is available in the form of great crested newt Impact Risk Zone and Strategic Opportunity Area maps (where the compensation habitat created is aimed to be created in) of the Districts, which have been produced in consultation with the Council and other relevant bodies prior to applying for the council’s District Licence application to Natural England. These have been provided to the council and to the Nature Recovery Strategy.","","","","","","","","","","","","","","","","","","","","","","","","","In each of the scenarios the fragmentation of habitats should be considered, as more divided habits negatively impact protected species and biodiversity. Bigger, better and joined up habitats (the Lawton principal) enhance ecological networks.","","","","We wish to draw attention to the Great Crested Newt District Licensing Scheme, for which Cheltenham, Gloucester and Tewkesbury district Councils hold their own licences that has been granted by Natural England (NatureSpace are the delivery partner). We suggest that data, including maps, associated with this scheme would provide a strong evidence base for the emerging strategic and local plans. \n\nI appreciate these are brief comments, however we are happy to provide further information if required."]
["","Cheltenham Chamber of Commerce","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","On behalf of Cheltenham Chamber of Commerce I would like to place our full support to the submission from the LEP. We have been involved in the discussion and fully agree with their comments."]
["Statutory/Specific Consultee","Churchdown Parish Council ","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Churchdown Parish Council would like to be involved and consulted at all stages of the \ndeveloping Strategic Local Plan.\nLack of time precludes the Council from agreeing a fuller and more detailed response \nbut Members ask that take the following comments into account ;\nChurchdown’ s sense of identity as a parish , its place and relationship with \nneighbouring parishes , and its unique social and business assets, demand of the \nParish Council that we fully engage with TBC and neighbouring district authorities in this \nprocess, as the Strategic Local Plan develops. \nIn particular we ask that you respect the importance and value of the following policies \nin any decision regarding the future of Churchdown as a Community.\nThe policies referred to are : \nJoint Core Strategy \nSD3 - Sustainable Design and Construction ; SD5 - Green Belt; SD6 - Landscape\nSD9 – Biodiversity; INF 1- Infrastructure; INF 2 - Flood Risk; INF 3 - Green Infrastructure\nTewkesbury Borough Plan \nGRB2 – Gloucestershire Airport ; GRB4 – Cheltenham – Gloucester Green Belt. \nLAN5 – Local Green Spaces\nThe Churchdown and Innsworth Neighbourhood Plan \nAll policies"]
["Statutory/Specific Consultee","Forest of Dean District Council ","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","It is evident from the consultation paper that the SLP seeks to provide approximately 35,700 homes, including the existing allocations and commitments up to 2041 (though this plan period is not yet fixed). Along with other requirements, a portfolio of six \n“scenarios” is discussed, highlighting some basic advantages and disadvantages of each and setting out how they may contribute to the overall goal. In reality, we believe it likely that a combination of these scenarios is most likely to go forward into any plan.\n4. A SUMMARY OF THE SCENARIOS AND FODDC’S COMMENTARY\n4.1. The aims and objectives of the SLP are considered appropriate to enable the key aspects to be addressed through its possible policies. These include supporting/ enabling transport networks, avoiding areas vulnerable to flooding, supporting the housing (including affordable housing needs) of the area, and enhancing the economy wth workforce development. Whilst these are supported, we would suggest that any \ndevelopment proposed through the SLP ensures good connectivity with, and support \nof, existing settlements within the surrounding areas, which will mutually benefit the wider area.\n4.2. Of the six scenarios, it may be that the sixth entitled “Sustainable Transport”, is best regarded as a fundamental requirement of any spatial distribution and that the SLP is led by this in establishing the overall strategy. Such an approach would likely support several other of the six as set out in the consultation. It is also one where links to other areas may be considered, as neighbouring districts such as FoDD could benefit from easy access to improved transport connections in and around the SLP area.\n4.3. Scenario five is badged “Rural Dispersal” and seeks widely distributed growth. It is the most unlikely to be considered suitable from a sustainability approach, nor would be likely to retain or enhance the character of much of the rural areas affected. \n4.4. Scenario one, “Urban Concentration” is proposed as an underlying component of the SLP and follows well understood principles. It will appear as a part of any Local Planand is generally supported. However, it cannot deliver the required scale of change alone, and therefore other approaches adopted in conjunction with it are essential. \n4.5. Scenarios two and three consider urban extensions- either respecting or reviewing the Green Belt. The approach which allows for the review of the Green Belt may deliver better spatial options, whereby the planned urban extensions option can deliver well placed development which could enhance existing communities and associated Green Infrastructure (GI), with improved natural areas. Development under either scenario should be located where improved transport connections can be made and should take advantage and feed any rapid transit. It’s important to note that either variation would lose agricultural land, as would all options bar scenario one, “Urban Concentration”.\n4.6. Scenario four addresses “New Strategic Settlements”. In principle, these can deliver long term development in sustainable locations but need to be very well planned and capable of a degree of self-containment. Given the nature of the SLP area and the current planned settlement at Ashchurch, it is an approach that any plan must consider. As with other scenarios, potential locations are referred to but only in the context of existing proposals or representations. There is reference to a third-party proposal for development at Churcham / Highnam which straddles the FoDD boundary. Nevertheless, while the FoDDC are aware of this, it is not supported in the FoDDC emerging Local Plan and neither is the broad concept of a new settlement thin the district. ","Scenario 6: Sustainable transport scenario","","","BACKGROUND\n1.1. Cheltenham Brough Council, Gloucester City Council and Tewkesbury Borough \nCouncil are currently producing a Strategic and Local Plan (SLP). It is understood that \nthe SLP will provide an overarching planning strategy and cross-boundary strategic \npolicies covering the whole area, and local policies for each local authority. \n1.2. The current consultation – Regulation 18: Spatial Options and Key Policy Area (‘Issues \nand Options’) – commenced on Tuesday 16th January for a period of eight weeks, \nand so FoDDC are required to submit any formal response by Tuesday 12th March \n2024. In consideration that FoDDC’s recommended response was only considered at \nCabinet on the 14th March, we realise that any formal response will be provided outside \nof the set consultation period, and as such we have previously requested an extension \nof time in order to submit our comments, which was subsequently granted. In the spirit \nof our duty to co-operate, we have also participated in a meeting with our neighbouring \nLPAs (Cheltenham and Tewkesbury) on the 6th February 2024 and have provided a \nverbal indication of our potential concerns as well as the aspects of the SLP we could\nsupport. \n1.3. It is understood that the current consultation is seeking views on a paper which \nsuggests key issues and potential strategies for the joint SLP covering Cheltenham \nBorough, Gloucester City, and Tewkesbury Borough. The document does not propose \nany particular approach, nor does it advocate any specific site. It does explore a range \nof options which in many cases are components of a potential approach rather than \nbeing exclusive options. FoDDC’s response therefore covers comments on possible \ncomponents of any strategy from the FoDDC’s point of view; these include \nconsiderations of both the scope for the FoDD to benefit from them and also concerns \nfor their impact.\n2. FODD’S CONNECTION WITH THE SLP AUTHORITIES\n2.1. The FODD has the most important connections with Gloucester and Cheltenham, with \nmany higher-level services, much employment and social and recreational activities \nserving the district located in and around the SLP area. It is important from the FoDD’s \nviewpoint that these connections and services are maintained, along with the \nintroduction of improved and more sustainable access where possible. There is \npotential for existing travel issues, such as the periodic A48/ A40 congestion, to be \npartially addressed by the SLP (for example in association with any mass rapid transit \nnetwork that may develop in Gloucester/ Cheltenham areas), but they may also be \ncompounded.\n2.2. At present, the FoDDC’s emerging Local Plan has no intention of providing for any \nneeds of neighbouring LPAs, and at this stage (’Issues and Options’ consultation), it \nis our understanding that our neighbouring LPAs (Cheltenham, Gloucester and \nTewkesbury) do not seek provision within the FoDD. Any such proposal would need \nto be the subject of discussion under the duty to co-operate.\nCONCLUSION\n5.1. The SLP approach enables a degree of strategic planning undertaken by the three \nLPAs for closely related areas at the core of the County. As such, it must deliver a \nmore sustainable pattern of development that is able to be supported by infrastructure \nthat will be deliverable when required. In doing so, a reduction in the need to travel, \nscope for active travel and the ability to support and develop better public transport \nwill be important. \n5.2. It is felt that overall, the ‘Issues and Options’ paper is a fair discussion of the elements \nthat could be brought forward as part of a new strategy, however it is recognised that \nany of the scenarios forming the current paper require further development and \ntesting. As suggested by the paper itself, the scenarios are elements of a potential \nstrategy, rather than exclusive options. Whatever option (or combination of options) is \neventually brought forward, the SLP will have to deliver the best climate and \nenvironmental solutions, whilst also encouraging the most sustainable long term \nspatial pattern of development. From a FoDDC point of view, the SLP should seek to \nmeet all of its needs within its own boundaries and do so in a manner that supports \nbetter linkages to the FoDD. \n5.3. It is understood that the SLP process is at an early stage with the next steps being a \npreferred option. "]
["Resident",null,20,"The physical and mental well-being of local people also needs to be considered including factors such as air quality, access to green areas for walking and cycling. It's not just about providing housing, but making it a pleasant and safe area where people enjoy living.","It is important to restrict urban sprawl and infringement of greenbelt land. Over the past few years many of our town centres, including Cheltenham, have deteriorated with empty shops/buildings, whilst large areas of development have been carried out of countryside such as around Churchdown affecting traffic, pressure on services, flooding and using up countryside . Building on green belt land should be an absolute last resort. By investing in attractive, characterful, quality housing in empty buildings and on brown field sites close to the town centre and ensuring it is a safe, low crime/crime free area, people will be attracted to living there and in turn will give a much needed boost to the local economy.","Yes","Whilst we agree with the \"vision\", the reality is much removed from this. You cannot build housing and retain the natural environment in the same area. Aspects of the vision are not appropriate for some semi-rural areas and are more relevant to already established urban areas.","Yes","","Preserving the greenbelt should be a priority and planting areas of trees could be considered. Community orchards would not only act as carbon sinks and storage, but would also mitigate flooding and improve air quality and noise pollution whilst adding to the general aesthetic. Regeneration of town centres and cities would allow people to commute in a sustainable way (walk/cycle/public transport) rather than by using private cars so reducing the use of fossil fuels and pollution. Plants could be utilised on roofs and in urban spaces to remove pollution, sound proof, provide shade and reduce temperatures in areas of high concrete density. Use of existing buildings and roads would reduce the use of environmentally damaging building materials such as concrete. Therefore brownfield sites and existing buildings should be always seriously considered in the first instance. Any new housing should have climate protective measures as an integral part of the design.","Greenbelt areas, such as those around Churchdown/Chosen Hill area should be protected and preferably planted with trees to reduce flooding and take up carbon dioxide and pollutants. These areas should not be used for housing development. As aforementioned brownfield sites and existing buildings should be used. Any new housing should meet stringent sustainability criteria and have an integral eco-friendly design and materials.","","Yes","Yes","The land near Brookfield road, Churchdown and Oldbury orchard already has rich biodiversity in terms of amphibians, birds, reptiles and larger mammals such as deer, foxes and badgers. It is well-used by local residents as there are a number of existing public rights of way on this land. By enhancing the local natural environment for example tree planting, this area would fulfil a number of environmental purposes, such as reducing flood risk, reducing noise and traffic pollution from the nearby MS, increasing take up of carbon by vegetation and increasing BNG. It used to have an orchard in this area so for example a community orchard would fulfil all of the above with the added merit of improving the health and wellbeing of people using it and providing local produce.","","","","","","","","","","","","","","","More land retained for agriculture and not built on requiring farm workers. Allow farmers to convert buildings in a sustainable way to use for holiday accommodation. Green leisure areas such as in Forest of Dean, which require people to work in and maintain the areas.","","","","","","","","The focus should be on housing in existing towns and cities. By regeneration of these areas private vehicle use is reduced. The local economy is stimulated and there is reduced usage of construction materials as people would be using public transport to travel on existing roadways.","Yes","Yes, scenario 1) appears most appropriate and building should be in keeping with the character of the existing heritage/conservation area.\nScenario2) is most undesirable as it damages the natural environment, exacerbates climate change and potential flooding. Will lead to increased use of private vehicles, more building of roadways and the negative environmental impact associated with that; increased pollution and reduced air quality\nScenario 3) will result in loss of valuable agricultural land; a factor that as a country we need to be self sufficient and protect food security.\nScenario 4) Last resort\nScenario 5) destroys character of historical and often picturesque villages/hamlets. Only replacement of existing individual homes in these areas should be considered or very small numbers of affordable housing.","Scenario 1: Urban concentration","","","It is pertinent to note that a recent appeal to build on land on Parton Road, Churchdown has been dismissed by the planning inspectorate on the grounds that it would result in harm to the openness of the greenbelt and would lead to encroachment into the countryside\".\nAs mentioned in the other sections, by regenerating town centres, many of the aspects of the strategic \"vision\" could be fulfilled. Not only would developing these urban areas help to mitigate climate change and provide a range of housing for a variety of ages close to facilities, but natural environments/greenbelt could be preserved and indeed enhanced that would provide much\nneeded green spaces to positively impact the physical and mental well-being of local people.\n\n[Q1] 15 - 20 years.\n\n[Q8] Yes, the Environment act 2021 has a mandatory requirement for 10% BNG. We should definitely be aiming to exceed this and building on the greenbelt is not conducive to meeting this target. Local plans should promote conservation, especially where the existing area is countryside/greenbelt.  Meeting the BNG should not be carried out offsite and used as a \"loophole\" to permit building on the greenbelt."]
[null,"","","","","","","","","","","","Yes","Yes","Chargrove Lane 'Valued Landscape' of small farms, orchards, oaks, hedgerows, heavy-clay pasture and available footpaths. There is no better amenity candidate in the CGT area.","Greenspace and countryside, around every few hundred dwellings, in a scattered Milton Keynes-style layout. These countryside separations can be walked and cycled across. Maybe Tewkesbury \"garden communities\" envisage this. ","","","","For most desirable, residential Cheltenham, there should be little provision for affluent in-comers (e.g. escaping from the South East). ","","For AONB and Green Belt-constrained Cheltenham, the major factor needs to be housing Restraint (on the achievable numbers). ","","","",""," Rural sites in less sensitive landscapes.","","Inward investment but NOT inward migration.","","","","A distributor ROAD network, for vehicles (not cycles). ","","Away from the Cotswold Escarpment.  A medium-size (Aldi size) superstore. ","Yes","Yes"," (1)\tRestraint, for too attractive, land-constrained Cheltenham;\n(2)\tAn outspill 'satellite settlement' for environment-constrained Cheltenham, extending North from Stoke Road (west of Bishops Cleeve) on flat land between the railway mainline and the A435. ","No","No. The reasons are skewed towards the cheap option of urban extensions, further deleting the Green Belt which prevents Gloucester swallowing (coalescing with) Cheltenham. ","","","JCS, Local Plan and Appeal verdicts ruled that Shurdington (the only village entirely surrounded by this smallest Green Belt) has ample facilities available nearby in the two large towns, and should therefore not expand geographically. ","[Q1] There should be some long-term planning for preserving prime, desirable Gloucestershire's rural-urban balance, against incessant population increase through successive strategic plans.\n[Q8] Why not. 10% is a most modest objective, too easy for developers' agents to argue that it would be delivered. \n[Q26] In the medium-term, a North-South distributor road ROUTE from Tewkesbury-East 'new setlement' at Aston Cross (A46), down to the Bishops Cleeve Bypass, and onward to the Golden Valley Bypass, to reach Quedgeley, (without loading local traffic onto the national M5). \n[Q29] Will depend on the additional 2031 to 41 housing numbers, and the specific sites found  acceptable; and the \"combination\" can differ by District. Thus, this is a pointless question, other than to state that further Green Belt erosion must be ruled out."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I write in respect of the above consultation. I am aware the consultation has just closed but I would like to make the following comments regarding land which has been included: Site reference: G43 - West of Highnam\nRodway Hill Golf Course has been included within the above parcel of land. The site is an operational golf course, which offers both membership and pay and play options. There are currently 402 members and over 30, 000 rounds of golf played at the site every year. The site also includes a driving range and tourist eco pods which are a popular draw to the site and the surrounding area. On that basis, the site is not a suitable preferred option for residential development and would be met by strong opposition from those who value the facility and the local community."]
["","","","","","","","","","","","","","Yes","I am writing in regards to the strategic local plan for Cheltenham and the feedback due before 12th March.\n\nThis is in regards to Hardwick Green in St Pauls, Cheltenham.\n\nI am writing to give my feedback in believing this should be designated a green space for the use by the local community.\n\nCurrently the space is a highly used green space by the local community, for dog walkers, use during the summer and also use by local youth groups including the boys brigade.\n\nIn loosing this space we will be loosing the only green space within the St Pauls Ward. \n\nHaving spoken with many from the local community they all want this to remain a useful green space for community use and not developed further. \nI hope this will be taken into consideration when looking into the strategic plan.","","","","","","","","","","","","","","","","","","","","","","","","","","","","",""]
["","","","","As a resident of Leckhampton we wanted to put forward our views in advance of the next strategic plan meeting (SLP) and the potential plans in future to build in the vicinity of the A46 Shurdington / Kidnappers Lane and on any current green belt land.  I hope this is the correct email to send this, please forward as necessary.\n As you know, the A46 Shurdington Road is one of the most congested entrances to Cheltenham.  With a further 360 homes now been granted planning permission next to Kidnappers Lane, this will lead to a worsening of this already terrible situation. Any further development to this side of Cheltenham, along Shurdington and towards Brockworth will bring certain chaos.\nGreen Belt sites such as Brizen Farm (Newbridge Construction owned) have been refused planning permission in the past, on more than one occasion, with very clear and lengthy lists of objections. I am sure you are aware of these and nothing has changed since then, other more homes have been built putting stress on infrastructure and taking away more of such precious green spaces in this area. This land is Green Belt and should clearly remain so for all those reasons seen by the planning department.\nIn addition to the congestion the traffic brings, as a family is young children safety is also at the forefront of our minds. Our children attend Leckhampton Primary School and we already have seen the impact of drivers using Church Road and Kidnappers Lane as a cut through to avoid Shurdington Road, with these roads. With the addition of the Miller Homes on the way, this is only going to worsen this bad situation and impact the safety of our children travelling to school by foot or bike at both the primary school and of those attending High School Leckhampton.\nLeckhampton has had its fair share of building works over the last 5 years (Redrow, Kendrick, Newlands, HSL and now Miller Homes) and any further building is going to impact every resident here as well as putting pressure on an already stretched infrastructure and on people who use these travel routes to get into Cheltenham. It is time to plan for something different, other than building on small pockets of land, which drastically change the lives of the residents already living here.","","","","","","Protection of habitats ","","","","","","","","","","","","","","","","","","","","","","","","","","Yes","We believe the SLP should consider alternative plans for growth in the future, such as a ‘new town’ somewhere in the Cheltenham, Tewkesbury, Gloucester area which will provide affordable housing, businesses and with that, jobs.","","","Scenario 4: New strategic settlement; Scenario 5: Rural Dispersal ","","","[Q 29] Alternatively, looking at options in rural areas where housing is also very much needed. Perhaps a combination of these things will be the ideal scenario."]
["","","","","I wish to express my deep concern about the amount of houses being built in Churchdown and surrounding areas.\nI am particularly very worried about the amount of farmland and green belt areas up for consideration. Especially the proposed plans to build hundreds of houses on White House Farm land in Churchdown.\nMy property overlooks this land and I have observed an abundance of wildlife living in these fields.i.e roe deer, badgers, rabbits, foxes and many others.Also we have birds of prey and beautiful hedgerow species.\nI am also concerned about the amount of traffic which would increase on our already crowded, sometimes gridlocked roads.","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","[Q 7] What will happen to all these animals? Especially as their habitats are being eaten up by building projects…..Our countryside is environmentally extremely important and needs to be protected"]
["Planning agent or developer","Point Consultancy Ltd","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Scenario 2: Urban extensions","","","[Q1] Whilst national planning policy requires local plans to look ahead at least 15 years,  good planning and certainly a concern for sustainable patterns of development \nrequires a regard for a longer time horizon. Shorter time frames enable the housing  need to be minimised encouraging a ‘make do’ approach and discouraging real \nvision and setting in place a move towards a real change for the better. It would be good if the consultation on the SLP developed and tested scenarios that would \nbecome more appropriate if a longer time horizon was considered.  By way of illustration these further ‘think long but start now’ scenarios might include \nthe patterns of development that would best facilitate and be serviced by some form  of mass transit system, even though this might be more than 15 years in delivery. In \ndoing so this would act to break the cosy but terminal reciprocal relationship between development and road building that has taken planning in entirely the wrong direction \nfor decades.\n\n[Q29] Large parts of the SLP area are cursed with green belt designation. This entirely archaic, misguided and misunderstood remnant of 1950’s development control-led \nplanning has long inhibited intelligent and positive decision-making in the area and should be removed. As a statutory local plan the SLP at least provides the means to change the extent and the boundaries of green belt, and unless this is done, based on real planning evidence rather than political lethargy, the makers of the SLP will fail the statutory requirement placed on plan makers of seeking more sustainable development. In those circumstances a challenge to the submitted SLP on both legal compliance and soundness grounds would be inevitable, further delaying the adoption and implementation of good planning. These issues are not fully explained in the presentation of the six scenarios.\n\n[Q31] It is good to see work getting underway on the SLP. Strategic spatial planning that addresses places, activities, markets and infrastructure networks rather than being \nbound by historic and inappropriate administrative boundaries is the only way to achieve the integration of development and infrastructure and take the opportunity \npresented by land use planning. It is noted and welcomed that the strategic approach being pursued leaves it entirely possible for district-specific policies to be \nincluded, where appropriate and justified. The participation of the three local authorities in making the SLP is necessary but not sufficient. It is entirely predictable that the housing (and perhaps other development) needs arising from these three administrative areas will not be able to be satisfactorily met within the identified plan area, and land in Stroud and the Forest of \nDean districts will also be needed. These areas already have strong relationships with Gloucester and Cheltenham in particular, for employment, education, retail and \nleisure activities as well as having strong transport links. The unmet development needs from Gloucester Cheltenham and Tewkesbury will have to be properly \nplanned into the future of Stroud and the Forest of Dean districts together with meeting their own needs. These local planning authorities for political and technical \nreasons should be part of the SLP. The apparent commitment to lead the SLP with a spatial strategy developed through the testing of a range of illustrative options that are representative and manageable is a good way forward. It also will help ensure that the SLP can be put beyond legal challenge citing the EIA regulations. It is inevitable that the spatial strategy that \nemerges will be a ‘hybrid’ of the scenarios presented, perhaps bringing in other approaches too. Everything else contained in the SLP must be there to implement the spatial strategy. "]
["Resident","Southcourt Green Residents Group Community Interest Company","","","","","","","","","","","","Yes","Southcourt Green be designated as a Local Green Spsace. The Green contributes to the local community’s health, wellbeing, sense of community & social interaction. The Green Provides Local Environmental Benefits. The Green Provides Economic Value","","","","","","","","","","","","","","","","","","","","","","","","","","","","",""]
["Statutory/Specific Consultee","Cotswold National Landscape",15,"","The conservation and enhancement of the Cotswolds National Landscape (CNL) is relevant to all  three council areas. The CNL overlaps with Cheltenham Borough and Tewkesbury Borough but not with Gloucester City. However, the CNL boundary is adjacent to the Gloucester City boundary to the south west of Upton St Leonards (on the opposite side of the M5 motorway). In addition,  Gloucester City Boundary is within approximately 220m of elevated, publicly accessible viewpoints  on the Cotswold escarpment within the CNL. As such, Gloucester City is located within the setting \nof the CNL. Aspects of national planning policy relating to national landscapes / areas of  outstanding natural beauty (AONBs) are, therefore, relevant to development in Gloucester City, as well as to development in Cheltenham and Tewkesbury Boroughs.","","Overall, the Cotswolds National Landscape Board agrees with the aspirations that are set out in  the draft Vision. However, we would like to make the following suggestions to improve the draft Vision. The first paragraph of the draft Vision states that ‘Growth will have afforded the highest possible quality of life for all in a manner which achieves carbon reductions and addresses the causes and  effects of climate change’. Achieving carbon reductions is not aspirational enough. Instead, the Vision should set out an aspiration to achieve ‘net zero’. The fifth paragraph of the draft Vision refers to ‘conserving the area’s special landscapes’. We support the inclusion of aspirations relating to landscape within the draft Vision. However, we do not consider that this statement is aspirational enough and does not reflect national policy \nrelating to landscapes. Firstly, we consider that this statement should make explicit reference to the CNL and its setting, reflecting the national importance of this designation. Secondly, the statement should make explicit reference to the statutory purpose of CNL designation, which is to conserve and enhance the natural beauty of the area. We suggest that this statement should be  changed to:\n• Conserving and enhancing the natural beauty of the area’s special landscapes, including \nthe Cotswolds National Landscape and its setting. (N.B. Underlining added for emphasis).\nThe fifth paragraph also refers to ‘a network of green spaces’ helping to secure ‘a high-quality \nenvironment for people and nature’. It also refers to ‘improvements to biodiversity’. Again, these \nstatements are not aspirational enough. The aspiration, with regards to biodiversity, should be to \ndeliver a nature recovery network that is of sufficient quality, scale and connectivity to secure \nnature’s recovery.","Yes","","In principle, the Cotswolds National Landscape (CNL) Board supports the measures that are set out in the Strategic and Local Plan consultation document. It would be helpful if the Strategic and Local Plan could differentiate between climate change  mitigation and climate change adaptation, where appropriate. With regards to climate change mitigation, we consider that this can be most effectively  addressed by applying the energy hierarchy shown below, whereby priority should be given to  energy conservation and reducing the demand for energy. We recommend that the Strategic and  Local Plan should make explicit reference to this energy hierarchy (or equivalent). Within the CNL and its setting, measures to mitigate and adapt to the impacts of climate change  should be delivered in a way that is compatible with – and, ideally, positively contributes to – the statutory purpose of conserving and enhancing the natural beauty of the CNL. Priority should be  given to measures that help to deliver this aspiration. To help deliver this aspiration, we encourage the local authorities to have regard to – and endeavour to align Strategic and Local Plan policies with - the following publications during the development of the Strategic and Local Plan. Climate change mitigation and adaptation are addressed in Policies CC1 and CCC2, respectively of the CNL Management Plan 2023-2025. Further guidance on these issues is provided in the Board’s Climate Change Strategy. In 2022, the Board commissioned Small World Consulting (SWC) to assess baseline greenhouse gas emissions in the CNL and to identify potential pathways to achieving net zero. The SWC report was published in March 2023, with a ‘layman’s guide’ being published in July 2023. In autumn / winter 2023, the Board ran a series of workshops to explore the recommendations  that were made in the SWC report. These workshops were facilitated by 3Keel Sustainability Consultants and were attended by over 250 people. From these workshops, 3Keel has published a report which summarises the outputs of these workshops and sets out an action plan for working towards net-zero in the CNL.7 This report was adopted by the Board in February 2024. This report is a sector-leading plan of action for addressing climate change in a protected landscape. The Board is particularly keen that the Strategic and Local Plan aligns closely with the action plan that is set out in the 3Keel report.","The Cotswolds National Landscape (CNL) Board recommends that the Plan should make provision  for a design code based on different character areas. Within the Cotswolds character area,  particular emphasis should be given to conserving and enhancing locally distinctive Cotswold character, in line with Policy CE3 (Local Distinctiveness) of the CNL Management Plan 2023-20258 and associated guidance. Consideration should be given to relevant ‘special qualities’ of the CNL, as set out in Chapter 4 of  the CNL Management Plan 2023-2025. These include:\n• The unifying character of the limestone geology – its visible presence in the landscape and use as a building material.\n• Variations in the colour of the stone from one part of the National Landscape to another which add a vital element of local distinctiveness.\n• Distinctive settlements, developed in the Cotswold vernacular with high architectural quality and integrity.\n Consideration should also be given to the guidance that is set out in:\n• The Cotswolds National Landscape Climate Change Strategy in relation to buildings and new development.\n• The Board’s Local Distinctiveness and Landscape Change report, particularly with regards to the built environment.\n• The Board’s guidance on ‘Traditional Cotswold Buildings – Saving Energy’.","","Yes","","","The Cotswolds National Landscape Board considers that the key services and facilities that are most important to be provided within easy reach of developments include shops, schools, health services, green infrastructure and public transport (at a level that is sufficient to enable access to and from key services / facilities and to enable commuting to and from jobs (e.g. in local towns and cities)).","","The Cotswold National Landscape Board’s position on renewable energy is set out in the Board’s  Renewable Energy Position Statement.13 We recommend that the Strategic and Local Plan’s approach to renewable energy generation and storage within the CNL and its setting should align with the Renewable Energy Position Statement. The Board considers that the allocation of sites specifically for renewable energy generation or storage, within the CNL and its setting, could potentially be acceptable, provided that the type and scale of renewable energy generable / storage that would be accommodated in the allocation is compatible with: (i) the statutory purpose of conserving and enhancing the natural beauty of the CNL; and (ii) the Board’s Renewable Energy Position Statement. Allocations for large-scale renewable energy schemes in the CNL (and, to a lesser degree, it setting) would not be compatible. We consider that the identification of ‘suitable areas’ for renewable energy (specifically wind and \nsolar energy) is a higher priority than the allocation of specific sites. This is particularly important  for wind energy, as national planning policy states that ‘a planning application for wind energy  development involving one or more turbines should not be considered acceptable unless it is in an area identified as suitable for wind energy in the development plan or a supplementary planning document’.14 As such, not identifying suitable areas for wind energy development in the Local Plan would, in effect, block such development plan across the whole of the Local Plan area. As outlined in the Board’s Renewable Energy Position Statement, we advocate an approach to the identification of suitable areas that is underpinned by a landscape sensitivity assessment and by  consideration of relevant constraints (including constraints that relate to the natural beauty of the \nCNL). In this approach, areas that are identified as having high landscape sensitivity to particular scales of wind and solar energy should not be included within the ‘suitable areas’, at least in the CNL and in the neighbouring Landscape Character Areas. Careful consideration will also need to be given to types and scales of renewable energy that are identified as resulting in ‘moderate-high’ landscape sensitivity. Within the CNL, such development is likely to constitute ‘major development’ in the context of paragraph 183 of the National Planning Policy Framework, for which there is, in effect, a presumption against granting planning permission (other than in exceptional circumstances). n this approach, the area that is identified as being a ‘suitable area’ will vary according to the scale of the proposed development, as larger scale development is likely to result in higher levels of landscape sensitivity.\nWith regards to major development, the urgent need to mitigate the impacts of climate change would potentially make it easier to demonstrate exceptional need. However, exceptional need does not necessarily equate to exceptional circumstances. For example, there may be other, more compatible ways of mitigating the impacts of climate change or less harmful locations for the \nproposed development, including locations outside of the CNL. An additional option would be to ‘safeguard’ particular areas for renewable energy, particularly for large-scale wind energy, for which the extent of areas that are technically viable are likely to be \nrelatively limited. However, this should not be conflated with the identification of ‘suitable areas’. The identification of ‘suitable areas’ is intended to help secure the development of renewable energy in these areas. Safeguarding, in this context, is about ensuring that areas of land where large-scale wind energy schemes might be technically viable, are not lost to other forms of \ndevelopment that might make wind-energy schemes in a particular location no longer viable. However, this should not be the case for ‘safeguarding areas’. Safeguarding should not convey any presumption that renewable energy schemes will be permitted.","","The Cotswolds National Landscape (CNL) Board does not object to the ‘standard method’ figure  being used as a starting point for identifying the housing requirement that will be set out in the  Strategic and Local Plan. However, we strongly object to the principle of this figure being used as a target. It is important to note a recent (December 2023) change to paragraph 61 of the National Planning  Policy Framework (NPPF), which now clarifies that ‘the outcome of the standard method is an  advisory starting-point for establishing a housing requirement for the area’.19 In a recent speech,  the Secretary of State, Michael Gove, stated that ‘it has always been the case’ that the number of homes identified using the standard method ‘was supposed to be advisory’. He went on to state that the new NPPF ‘now, more clearly, upholds the spirit of the original intention. Local authorities have the comfort of knowing that they need not re-draw the green belt or sacrifice protected landscapes to meet housing numbers’. This reflects the statements that were made in the Government’s response to the local housing need proposals in ‘Changes to the current planning system’, in 2021, including:\n• More broadly, we heard suggestions … that in some places the numbers produced by the  standard method pose a risk to protected landscapes and Green Belt. We should be clear that meeting housing need is never a reason to cause unacceptable harm to such places.\n• Within the current planning system, the standard method does not present a ‘target’ in plan-making, but instead provides a starting point for determining the level of need for the area, and it is only after considerations of this, alongside what constraints areas face … and the land that is actually available for development, that the decision on how many homes should be planned for is made. It does not override other planning policies, including the protections set out in Paragraph 11b of the NPPF… It is for local authorities to determine precisely how many homes to plan for and where those homes most appropriately located. In doing this they should take into account their local circumstances \nand constraints.\nIt also reflects:\n• Paragraph 11bi and footnote 7 of the NPPF, which set out the circumstances in which it may not be necessary for strategic policies to meet objectively assessed needs (i.e. the standard method figure) in full.22\n• The Government’s planning practice guidance on the ‘Natural Environment’, in relation to development in protected landscapes, which states that the NPPF’s policies for protecting these areas ‘may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process’.23\n• The Government’s planning practice guidance on ‘Housing and economic land availability assessment’, which addresses the way in which ‘constraints’ should be addressed when identifying housing requirement figures in local plans. The Board addresses this issue in its Housing Position Statement, which recommends that the standard method should not be treated as a target.\nConsideration will need to be given to whether it is realistic to achieve the standard method figure  without causing (significant) harm to relevant assets, including the Cotswolds National Landscape (CNL) and the green belt. If it is not possible the deliver this quantum of housing without causing (significant) harm to these assets, consideration should be given to setting a lower housing requirement figure.\nThis does not necessarily mean that there should be no development within these assets. It just means that the quantum of development should be at a level that does not cause (significant) harm (or that exceptional circumstances apply to justify harmful development).","Yes","To help assess whether potential allocations are likely to be harmful to the natural beauty of the  CNL, including its landscape and scenic beauty, a landscape sensitivity assessment should be undertaken for parcels of land surrounding settlements within the CNL and its setting, where allocations could potentially be located. It is worth noting that there are several factors that contribute to the natural beauty of the CNL (in addition to its landscape and scenic beauty). These include the area’s cultural heritage (including historic environment), natural heritage (including biodiversity), relative tranquillity and ‘special qualities’. If a proposed allocation was likely to have harmful effects on any of these factors, then it is also likely to have a harmful effect on the natural beauty of the CNL. This should be made \nexplicit in relevant assessments. An assessment should be undertaken to assess if proposed allocations are likely to increase traffic movements on roads within the CNL and along its boundary. As outlined in Section 4.5 of the Board’s Tranquillity Position Statement, the Board considers increases in traffic movements of 10% or more to be significant. An assessment should also be undertaken for all proposed allocations within the CNL to identify if the allocation constitutes major development, in the context of paragraph 183 of the National Planning Policy Framework. If any allocations are identified as constituting major development, in this context, an assessment should be undertaken to identify whether exceptional circumstances apply and whether the proposed allocation would be in the public interest.\nFurther guidance on the issue of major development is provided in the CNL Management Plan 2023-202527 and in the Board’s Landscape-led Development Position Statement28 (including \nAppendix 5, which provides a checklist of things to consider when deciding whether a proposed allocation / development constitutes major development).","Yes","The Cotswolds National Landscape (CNL) Board recommends that, within the CNL, priority should \nbe given to the provision of affordable housing, particularly housing that is affordable in \nperpetuity. This is reflected in Policy CE12 of the CNL Management Plan 2023-2025.\nPolicy CE12 also advocates, inter alia:\n• at least 50% affordable housing in market housing developments;\n• 100% affordable housing on Rural Exception Sites, with a lower percentage only being \npermitted in exceptional circumstances and the absolute minimum being 75%;\n• on-site affordable housing provision for housing developments of five units or fewer.\nFurther guidance and context on these issues is provided in the Board’s Housing Position \nStatement.2","","","","","","","","The Cotswolds National Landscape (CNL) Board recommends that consideration should be given to applying the ‘20-minute neighbourhood’ approach to rural areas. For example, consideration should be given to identifying and facilitating clusters of villages that collectively provide a range of services and facilities. The Strategic and Local Plan should facilitate car-free travel between these villages, for example, by facilitating the use of bicycles (including e-bikes). This may include measure such as ‘quiet lanes’, reducing speed limits, setting up e-bike ‘hubs’, car-free routes, etc. An example of this approach is provided by the Velocity project at Blenheim Estate.","The Cotswolds National Landscape (CNL) Board consider that the following types of infrastructure \nare critical:\n• Sewerage infrastructure\n• Green infrastructure\nSewerage infrastructure\nOne of the ‘special qualities’ of the CNL is:\n• River valleys … with high-quality water.\nAs a special quality, this is one of the key attributes on which the conservation, enhancement and  management of the CNL should be based.\nA key consideration in ensuring high-quality water within the rivers and watercourses of the CNL is to ensure that new development does not overload the sewerage infrastructure. To achieve this, we recommend that the Plan should require ‘Grampian conditions’, whereby planning \npermission is conditional upon there being in place adequate sewerage facilities to cater for the requirements of the development without ecological damage. If the developer indicates that they intend to deal with the problem of sewerage by connecting to the public sewer, planning permission should be conditional upon the sewerage authority first taking any steps necessary to ensure that the public sewer will be able to cope with the increased load.\nGreen Infrastructure\nThe National Planning Policy Framework (NPPF) defines green infrastructure as:\n• A network of multi-functional green and blue spaces and other natural features, urban and rural, which is capable of delivering a wide range of environmental, economic, health and wellbeing benefits for nature, climate, local and wider communities and prosperity. Green infrastructure should be delivered in line with Natural England’s Green Infrastructure Framework. The Plan should identify how green infrastructure provision will link with the delivery of biodiversity net gain, nature recovery strategies, nature recovery networks, natural capital and opportunities for quiet, outdoor recreation.","The Cotswolds National Landscape (CNL) Board consider that the following types of infrastructure \nare critical:\n• Sewerage infrastructure\n• Green infrastructure\nSewerage infrastructure\nOne of the ‘special qualities’ of the CNL is:\n• River valleys … with high-quality water.\nAs a special quality, this is one of the key attributes on which the conservation, enhancement and  management of the CNL should be based.\nA key consideration in ensuring high-quality water within the rivers and watercourses of the CNL is to ensure that new development does not overload the sewerage infrastructure. To achieve this, we recommend that the Plan should require ‘Grampian conditions’, whereby planning \npermission is conditional upon there being in place adequate sewerage facilities to cater for the requirements of the development without ecological damage. If the developer indicates that they intend to deal with the problem of sewerage by connecting to the public sewer, planning permission should be conditional upon the sewerage authority first taking any steps necessary to ensure that the public sewer will be able to cope with the increased load.\nGreen Infrastructure\nThe National Planning Policy Framework (NPPF) defines green infrastructure as:\n• A network of multi-functional green and blue spaces and other natural features, urban and rural, which is capable of delivering a wide range of environmental, economic, health and wellbeing benefits for nature, climate, local and wider communities and prosperity. Green infrastructure should be delivered in line with Natural England’s Green Infrastructure Framework. The Plan should identify how green infrastructure provision will link with the delivery of biodiversity net gain, nature recovery strategies, nature recovery networks, natural capital and opportunities for quiet, outdoor recreation.","The Cotswolds National Landscape (CNL) Board considers that the key services and facilities that are most important when deciding if a rural settlement is a suitable location for new homes, etc., \ninclude shops, schools, health services, green infrastructure (including accessible natural green space) and public transport (at a level that is sufficient to enable access to and from key services / facilities and to enable commuting to and from jobs (e.g. in local towns and cities)).","Yes","Yes","The Cotswolds National Landscape (CNL) Board recommends that consideration should be given to a scenario that doesn’t involve: (i) major development within the CNL; or (ii) development \nwithin the CNL and / or its setting that would harm the natural beauty of the area. \nThis doesn’t necessarily have to be a separate / additional development scenario but the extent to \nwhich this can be delivered should be explicitly addressed in relation to any proposed scenario.\nIt is important to note that such a scenario doesn’t necessarily mean that there should be no \ndevelopment within the CNL.","No","The Cotswolds National Landscape (CNL) Board considers that the pros and cons identified for the six development scenarios are fair and accurate. However, there are some additional points that should be reflected within the pros and cons, as outlined below.\nScenario 1 – Urban concentration\nThe ‘pros’ should include reducing development pressure on the CNL.\nThe ‘cons’ should include potential loss of – and / or lack of provision of - green infrastructure, including accessible natural greenspace and sustainable drainage.\nScenario 2 – Urban extensions\nThe ‘cons’ should include:\n• Potential urbanisation of the CNL (for urban extensions within the CNL, such as at Oakley Farm).\n• Adverse impacts on views from and to the CNL, with regards to development in the \nsetting of the CNL.35\n• Could potentially result in the coalescence of Cheltenham and Gloucester, which, in turn, would have an adverse impact on views from the CNL.\n• Potentially excessive increase in traffic movements within – and along the boundary of –the CNL (i.e., an increase in traffic movements of 10% or more).\nScenario 3 – Urban extensions, avoiding the Green Belt\nIn addition to the points raised in relation to Scenario 2, the ‘cons’ should include potential increased development pressure on the CNL and its setting.\nScenario 4 – New Strategic Settlements\nWith regards to the potential new strategic settlement at Ashchurch, the ‘cons’ should include:\n• Potential adverse impacts on views from the CNL.\nScenario 5 – Rural Dispersal\nThe ‘cons’ should include:\n• Excessive development pressure on the CNL, potentially including ‘major development’,\nsuch that the scale and extent of development would not be limited, thereby conflicting \nwith national planning policy in this regard.\n• Potential adverse effects on the natural beauty of the CNL.\n• Potentially excessive increase in traffic movements within – and along the boundary of –the CNL (i.e., an increase in traffic movements of 10% or more)",null,"","","[Q5] Overall the Cotswolds National Landscape Board agrees with the draft Strategic Objectives]\n\n[Q8] The Cotswolds National Landscape (CNL) Board recommends that the Strategic and Local Plan  should require more than the mandatory minimum 10% Biodiversity Net Gain through \ndevelopment, particularly in the CNL and in locations that are identifies as priority locations for nature recovery. Policy CE7 of the CNL Management Plan 2023-2025 recommends that ‘development proposals should provide a net gain in biodiversity of at least 20%’. In delivering BNG within the CNL priority should be given to the species and habitats listed in Appendix 7 of the CNL Management Plan. The relevant ‘special qualities’ of the CNL are also important in this regard, specifically, the area’s flower-rich grasslands (particularly limestone grasslands) and the area’s ancient, broadleaved woodland. Further context on why 20% BNG is merited in the CNL is provided in Appendix 8 of the CNL Management Plan. It is worth noting that the Board considers lowland calcareous grassland and ancient hedgerows to be ‘irreplaceable habitat’ (in addition to ancient woodland and ancient / veteran trees), as specified and defined in Policy CE7 of the CNL Management Plan 2023-2025. As such, these habitats should be treated separately from BNG.\n\n[Q26]The Cotswolds National Landscape (CNL) Board recommends that consideration should be given to safeguarding sites or route for longer term infrastructure projects. A key issue, in this regard, is the proposed ‘M5 Junction 9 and A46 (Ashchurch) Transport Scheme’, which would involve a new or re-configured M5 junction and would re-route the existing A46 around Ashchurch to the Teddington Hands roundabout.34 Housing schemes (and other development) are being permitted on the proposed route. If this was to continue, this would  potentially make such a scheme unviable, severely limiting the scope for large scale developments without exacerbate existing traffic issues.\nThe proposed scheme is located within the setting of the CNL. As such, consideration would need to be given to the potential impacts of the scheme on views from the CNL and to potentially increases in traffic movements through – and along the boundary of – the CNL.\n\n[Q29] The Cotswolds National Landscape (CNL) Board considers that, in reality, the Strategic and Local Plan will probably need to combine aspects of all of the identified development scenarios. In principle, we support development being located close to (or which facilitates easy, car-free access to) existing services and facilities, including public transport (i.e. in settlements that are \ntowards the top of the settlement hierarchy). Whilst we recognise the importance of the Green Belt, we would not support a development strategy that prioritised the protection of the Green Belt at the expense of the natural beauty CNL (i.e., a strategy that resulted in excessive development in the CNL and its setting as a result of completely avoided development in the Green Belt). The preferred development strategy should be one that helps to ensure thriving and vibrant communities within the CNL in a way that is compatible with – and, ideally, positively contributes to - the statutory purpose of conserving and enhancing the natural beauty of the area. The scale and extent of development within the CNL should be limited (in line with national planning policy), with major development only being allocated / permitted in the CNL in exceptional circumstances and where the allocation / development would be in the public interest. With the main urban areas (Gloucester, Cheltenham and Tewkesbury) being so close to the CNL, careful consideration will need to be given to the potential impact that allocations / development in the setting of the CNL might have on the natural beauty of the CNL. This includes impacts on:views from and to the CNL; the relative tranquillity of the CNL (including increases in traffic movements within, or along the boundary of, the CNL); the dark skies of the CNL. Development in the setting of the CNL should be sensitively located and designed to avoid or minimise adverse impacts on the designated areas, in line with national planning policy.\n\n[Q31] The Cotswolds National Landscape (CNL) Board would like to highlight the new statutory duty on relevant authorities to seek to further the purpose of designation (i.e. to conserve and enhance the natural beauty of the CNL), which came into effect on 26 December 2023. The three local authorities will need to take this statutory duty into consideration as they progress the Strategic and Local Plan. It is anticipated that Defra will be publishing guidance on this ‘seek to further’ duty within the next few weeks. However, it is worth noting that Natural England has already produced advice on  this issue – this is provided in Appendix 1, below. In line with Natural England’s advice, we recommend that the Strategic and Local Plan should \nrequire development proposals to demonstrate the measures that have been taken to further the statutory purpose of conserving and enhancing the natural beauty of the CNL. We would be happy to discuss this ‘seek to further’ duty with you in more detail."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Yes","1. The SLP as it stands is woefully inadequate in terms of sustainable Transport policy, particularly on rail and is not in accordance with the national Climate Change Emergency agenda. Rail services are not even mentioned in “Scenario 6: Sustainable transport scenario,” and the important role they can play in new developments and transport that delivers modal change from the car.\n\n2. There is a need for the SLP to continue route safeguarding of the former Cheltenham-Honeybourne-Stratford railway, including the safeguarding the Racecourse deviation, linking Cheltenham Racecourse with the Network Rail mainline, in the vicinity of Swindon Lane and the potential development of a Strategic Park and Ride facility at the existing Cheltenham Racecourse station – attached plan.\n\n3. Such safeguarding would be in accordance with NPPF, December 2023, para 110.c) on route protection of former rail lines, the Gloucestershire Local Transport Plan, 2020 and the Gloucestershire Rail Investment Strategy, March 2020.\n\n4. It is not without significance, the 28 mile Cheltenham - Stratford railway has been protected for reinstatement as a railway, in the Local Plans of Stratford, Wychavon, Cotswold, Tewkesbury and Cheltenham Local Plans, since 1992. Restoration of the railway is also supported in the Gloucestershire Local Transport Plan 4 and the Worcestershire LTP3. Of the original 28 miles, 18 have now been reinstated for rail use. Restoration of the railway throughout should not be lost sight of. It is therefore important that this policy approach is continued in the SLP, to ensure consistency in planning policy on the 28 mile rail corridor and the Racecourse deviation protected.\n\n5. Restoration of the original route to south of the Racecourse to Cheltenham Lansdown Station is highly unlikely in view of the numerous breaches of the trackbed. The original safeguarding was in the context of a Light Rail Scheme that never happened and which did not take into account the vertical alignment and levels necessary to restore a heavy rail connection.","","","","","","[Q31] Gloucestershire’s Local Transport Plan, 2015-41, 2020, Policy PD5.2 aim:-\n\n•\t“Work with the rail industry, local authorities and other stakeholders to consider the reinstatement of the rail link between Honeybourne and Stratford on Avon.”\n\n-\tIt also seeks to ‘Improve connectivity Interchange Hubs,’ in which  \n                “Moreton in Marsh could be regarded as Gloucestershire’s gateway\n                 to the cyber hub from the north east and vice versa for the Growth\n                 Arc from the west. This allows the potential for the station with its\n                 connections to London and Oxford to become a major interchange\n                 hub for sustainable travel. Rail station improvements will help\n                 encourage much needed mode change on the A429 corridor.\n\n7.  Gloucestershire Rail Investment Strategy, March 2020\n\nThe Gloucestershire Rail Investment Strategy was published March 2020 - link below, and identifies a potential Cardiff/Bristol-Cheltenham-Stratford-Nottingham service.\n\nhttps://www.gloucestershire.gov.uk/media/2096940/gloucestershire-rail-strategy.pdf\n\nP.29.\n\"4.4.6 Corridor 6 - A46 Corridor East Midlands to South West Midlands.\n\"• Continuing interest in the potential of the Stratford-upon-Avon to Honeybourne route, and work already done for Worcestershire and Warwickshire County Council using the SYSTRA model on the economic value this route could offer\n• Inclusion of the Stratford-upon-Avon-Honeybourne route on the agenda of the NCLTF.\n• The protection of the Honeybourne-Cheltenham corridor afforded by the heritage Gloucestershire-Warwickshire Steam Railway.\"\nP30.\n\"The tests proposed are:\n\n• BASE SERVICE: None – these tests assume a wholly new group of services via Stratford-upon-Avon \n• TEST 6A: Referencing previous tests undertaken for Warwickshire/Worcestershire County Councils covering East Midlands-Coventry-Stratford-u-Avon-Worcester-Gloucester-Bristol services\n• TEST 6B: As 5A but to Cardiff Central rather than to Bristol.\n• TEST 6C: As 5A & 5B via reinstated Honeybourne-Cheltenhamroute and NOT via Worcester.\n\nP52.\n\n\"11. A46 Corridor\n\n11.1 Service Options\n\nThe A46 Corridor options should be considered as a very long-term opportunity to provide an alternative routing from Gloucestershire to the East Midlands avoiding Birmingham, and has synergies with Midlands Connects A46 road corridor aspirations. Services would be routed from Nottingham to Cardiff or Bristol via Leicester, Coventry Leamington Spa, Stratford-upon-Avon and either Worcester or a reopened route from Honeybourne to Cheltenham. Clearly the delivery of such a route would require very substantial investment with two routes requiring reopening.  \nThe service options that have been tested are as follows:  \n• 2TPH Nottingham – Bristol via Stratford and Worcester \n• 2TPH Nottingham – Cardiff via Stratford and Worcester \n• 2TPH Nottingham – Bristol via Stratford and direct to Cheltenham \n• 2TPH Nottingham – Cardiff via Stratford and direct to Cheltenham.\n\nThe results show that such a service would generate substantial GVA impacts for Gloucestershire with new connectivity provided to parts of the East Midlands where no direct services currently operate.\"\n\nA46 Corridor CO6 \nAssociated with CO1, connectivity at Birmingham Moor Street/Curzon Street with Midland Rail Hub (MRH) services to Leicester and Nottingham and HS2 services to East Midlands Interchange\nA46 Corridor CO6 Associated with CO1, connectivity at Birmingham Moor Street/Curzon Street with Midland Rail Hub (MRH) services to Leicester and Nottingham and HS2 services to East Midlands Interchange. GVA (£m pa) 8 to 9.\n\n8. Alex Chalk, M.P, Cheltenham, in his statement to the Cheltenham Local Plan Examination, ED017, 23-01-19, stated:-\n\n“I am conscious that late submissions are being requested to support the safeguarding of the route of a Southern rail connection between the GWSR and the Midland Main Line. This would include the concept of creating a park-and-ride station at the eastern end of such a connection, with parking available on the racecourse's adjacent car park. Whilst such a park-and-ride and its connection to the main line may be of little economic benefit to the GWSR, it would be of significant benefit to Network Rail, the Jockey Club (the owners of Cheltenham Racecourse) and Cheltenham Town.”\n\n9. A report ‘Missing Main Lines’, April 2021, Greenguage21, identified three Missing Main Lines That Could Be Re-Opened:-\n\n“The first of these is the line from Stratford upon Avon to Cheltenham via Honeybourne. The report authors say that the loss of this connection as a useful diversionary route is a critical factor in the case for its re-instatement. We agree. and alongside linkages between Oxford and Stratford upon Avon (of great value to tourism flows), there is the ability to re-create a linkage from Cheltenham to Stratford and on into Birmingham’s Moor Street – which is set to become a new rail hub, alongside Curzon Street HS2 station.”\n\n               http://www.greengauge21.net/missing-main-lines/  \n\n\n10. A High Court judgement in 2002, Mansard County Homes v Surrey Heath Council case, confirmed that local authorities can protect rail lines even if no immediate rail use is identified, as long as this policy is defined in Local Plan.\n\n\n\n11.  Air Quality\n\nThe Government has a 2050 target, to reduce emissions by 80%. That was agreed by MPs under the Climate Change Act in 2008, and now amended to the new, much tougher, goal. Poor air quality is a major influence on public health, causing particular problems for those with respiratory illnesses and cardio-respiratory conditions. Road transport is responsible for 80% of Nitrogen Dioxide emissions, while rail accounts for just 1.6%. NO2 emissions also account for 29,000 premature UK deaths pa.\n\nRoad traffic currently accounts for 72% of total greenhouse gas (GHG) emissions from transport (73% of passenger-kilometres), aviation accounts for 14% (8% of passenger-kilometres), and rail accounts for less than 1% (6% of passenger-kilometres).2\n\n12. 2024 marks the 30th anniversary of the landmark, DfT- SACTRA report, December 1994. This concluded that after 40 years of building roads to meet demand was a failed policy.\n\nWhen a new road is built, new traffic will quickly fill it up. Some will be diverted from other roads, but many people will make trips they would otherwise not make, and will travel longer distances just because of the presence of the new road.\n\nThis well-known and long-established effect is known as ‘induced traffic’. Induced traffic means that the predicted congestion benefits of a new road are very quickly eroded.\n\nTraffic on bypassed roads often also rises faster than expected, all of which means the promised congestion benefits of a new road can evaporate very quickly\n\n*The Standing Advisory Committee on Trunk Road Assessment (SACTRA) is an independent committee appointed by the Secretary of State for Transport to advise on issues related to the appraisal of trunk roads."]
["","Gloucestershire Community Rail Partnership ",20,"Strategically there are a number of areas to be covered in more detail i.e.\n•\tIntegrated transport, and in particularly the role of ‘last mile’ multimodal connections to housing and employment sites – especially in relation to urban fringe and market town/rural locations\n•\tThe strategic role of rail needs to be more ambitious, linked to active travel community transport, bus and innovative low carbon ‘e’ modes of travel\n•\tThe plan needs to recognize the impact of housing allocations already made in existing local plans but are which still to come forward or which are not yet fully built/occupied. There is a policy imperative to ensure that sustainable transport alternatives are ‘retrofitted’ to influence travel behaviour more radically, alongside the packages triggered through ‘fresh’ housing numbers as set out in this CGT SLP\n•\tCommunity engagement and consultation needs to be through a step change. \n•\tThrough detailed evidence from GCRP’s Connecting New Communities 3-year project, we realise that too many planning decisions carry ‘perception based’ transport packages and solutions, made early on as part of the outline application, rather than enabling the ‘real residents’ that move in to prioritise where funding can be spent. \n•\tThe current policy framework has allowed Section 106 and other developer obligations to be spent on measures that do not optimise public transport use, because they were prescribed too early in the planning process. \n•\tThe CGT SLKP should allow for Section 106 and other ‘flexipots’ allowing both capital and revenue benefits to be spent in the way that has most impact and connects people to the rail stations, town centres and community provision that the public ask for.   \n•\tTherefore, a clear change is needed in the consultation and engagement model on planning applications and the associated mitigation package needs to have policy backing consistently across the 3 Borough areas and reinforced through the new SLP. ","•\tThe last mile package of sustainable transport improvements\n•\tThe community’s actual access needs evidenced through more advanced, intuitive and engaging tools that the conventional residential travel plan model\n•\tWe are able to share evidence from GCRP’s Connecting New Communities major project to support in this understanding ","","","","","•\tThe role of Net Zero transport and sustainable travel needs to be advocated more strongly\n•\tIt is also critical that last mile connections to key bus corridors, rail stations (new and existing) are optimised - especially within the standard walk/cycle catchments (see attached catchment maps) ","•\tEco standards and greening of construction should be stressed heavily\n•\tConstruction management plans also need to go through a step change with their own guidance (linked to the Local Transport Plan but reinforced by the SLP) given the longevity of impact of construction vehicles on local communities and often the way in which land options come forward for developers ","","Yes","Yes","•\tConsideration of railway embankments and cutting being used as wildlife net gain should be developed with Network Rail. \n•\tRedundant railway land/green corridors and rail station envelope that are not used operationally should also be considered. \n•\tDevelopers should be asked to contribute into ‘greening’ transport corridors; note that this could also include highway verges and other mini habitat/patch spaces ","•\tOur Connecting New Communities ongoing research (now in its 3rd year) provides a key evidence bank of the impact of new development and how those moving into new homes have their own hierarchy of service needs and access. For the Community Rail Partnership, safe and easy access to public transport, going where the customer needs to go, is critical to the success of expanded housing areas and new settlements \n\n•\tIt is also essential that youth voice is heard in this debate and the Equality Impact Assessment of SLP really goes into the detail of underrepresentation. ","Yes","Yes, and potentially linked to sustainable energy generation of road signs. Bus stops and other transport infrastructure ","No","•\tThe calculation needs to be adjusted to consider the last mile community access issue raised earlier, and also the relationship of the new housing need levels to existing housing that is committed but not yet built/occupied. \n•\tHousing sites that can give clear, multiple, site permeability and accessibility option to active travel users, is essential – including time advantage for pedestrians, cyclists and bus users. \n•\tFrom a sustainable transport optimisation viewpoint, both categories of ‘undeveloped housing’ are equal in terms of achieving net zero targets as the ‘real residents’ have not yet moved into their homes and travel habits formed.","Yes","in relation to provision of the correct number of affordable homes so that travel distances and accessibly to jobs does not continue to be a problem ","Yes","housing for young people especially those unable to normally access the housing ladder","No","","","•\tWe have favoured Option 6 (sustainable locations) on the ground that transit-oriented development (i.e. based on public transport accessibility) should be favoured wherever possible – or enable easy retrofitting to the transport network to provide the necessary connections ","Asa above, based on transit-oriented development first","•\tOptimising locations that reduce the need to travel and/or which allow rural mobility hubs and easy last mile service to be put in place ","•\tConsider the strategic relationship between the town/city and its railway stations.\n•\tSee GCRP’s access maps for Cheltenham and Gloucesterer\n•\tRefer to https://www.gloucestershirecommunityrail.org/access-maps\n•\tWe have initial proposals for a similar map for Ashchurch, Northway and Tewkesbury. ","•\tBuild these facilities into the rural mobility hub concepts so there is pass through trade as well as hyper local use ","•\tSee Excel sheet but from a CRP viewpoint, this would prioritise active travel routes, bus/community transport services and access to the nearest rail station from first occupation ","•\tBus and Community Transport connectivity, and also new/enhanced rial station with improved service frequency. \n•\tAlso ensuring that there are sustainable 18/24 or 24/7 land uses introduced next to new or existing rail stations to ensure round-the-clock community activity and safety. \n•\tThere is an ideal opportunity for this as Ashchurch station on the back of the Garden Town proposals ","•\tAs above, including easy access to local health, education, retail and social/meeting facilities. \n•\tOur in-depth research at Great Oldbury in Stroud District pointed to the importance of ‘meantime’ spaces that can be used by the community pending the construction of for example, the school or community meeting hall. ","Yes","Yes","•\tYes, with ‘aggressive’ super-sustainable transport interventions, including the retrofitting of these measures into the ‘existing’ population to achieve additional mode shift. \n•\tWe can explain more about this methodology on request ","Yes","","Scenario 6: Sustainable Transport","","","[Q8] The opportunities should be maximized including the sensitive dual use of green infrastructure corridors as active travel corridors to encourage healthy lifestyles and mental wellbeing]\n\n[Q15] Sites need to be optimised in terms of accessibility and access to core services such as health, education etc] \n\n[Q26] Plan for long term infrastrucuture including strategic cycle highways, new stations, and major green corridors for travel and wildlife. \n•\tProtection of redundant rail lines and community transport corridors is also important \n\n[Q31] Rail Travel. Even though scenario 6 promotes sustainable travel, it fails to mention rail travel. The SLP has missed an important opportunity to promote rail travel, so changes need to be made to prioritise it.\nScenarios 2, 3 and 6 mention the proposed Gloucestershire Mass Rapid Transport System which will likely be a segregated bus route, but could involve light rail.If a mixture of bus and light rail is implemented, it would be a significant improvement to Gloucestershire's Integrated Transport System.\nScenarios 1, 2, 3 and 6 would be the most likely to promote rail travel.A mixture of these scenarios should be implemented. Last mile accessibility warrants its own policies.\nMost mentions of sustainable transport are quite vague, with no reference to the cost of transport infrastructure and the types of infrastructure needed in each general area. It may be beneficial for the SLP to provide a few of the key points raised in the other 2 documents to make it easier for stakeholders to give feedback.\nProfessional and recreational use of rail links should continue to rise as more jobs are being created in the area and tourism has surged in many countryside areas. The integrated transport system in the area needs to be made as efficient as possible to cope with increased demand, with potential to increase capacity, strengthen the links between different types of transport, provide information to promote sustainable travel, and increase accessibility.\nThe development of rail travel is not seen as a significant priority for the Gloucester, Cheltenham and Tewkesbury councils. Rail travel is mostly ignored in the document, so more effort needs to go into explaining how it can be developed and promoted.\nEmissions is mentioned 7 times, but only mentioned in reference to sustainable transport once, not mentioned in regard to rail. Research needs to be undertaken to assess how the scenarios will impact carbon emissions in the transport sector.\nIntegrated transport is explicitly mentioned once, in the draft vision, but is implied in all of the scenarios except scenario 5. The impacts of scenario 5 on integrated transport needs to be mentioned.\nAccessibility is mentioned in regard to transport, but not specifically to rail. The report should detail how accessibility will be improved for rail travel.\nRail connectivity is key for reducing congestion on the M5 and ensuring that Gloucestershire is quick and easy to access. Heavy rail infrastructure in Gloucestershire needs to be promoted to commuters and tourists, as well as residents. This may mean that rail capacity and frequency of train journeys will need to be increased.\nSustainable transport is a key theme throughout the report, but the main methods of transport mentioned are cycling and walking. Lower cost forms of transportation are prioritised in the report, this means that heavy rail infrastructure is not likely to be developed in the near future due to affordability issues.\nThe maps are vague and not fixed, but only the scale of development is available so it is difficult to look at specific areas. This makes it difficult to visualise the scenarios and make accurate judgements on the effectiveness of the strategies.\nOne of the proposed developments is Tewkesbury Garden Town, which is centred around Ashchurch for Tewkesbury station. This would increase the popularity of the station, as at least 4000 more people would be living nearby. Tewkesbury Garden Town would be the most beneficial option because large scale developments should always be linked to rail. The Garden Town development would allow a step change in the functionality and role of the station\nScenario 6 appears to promote travel accessibility more than the other scenarios. The other scenarios should go into more detail about the impacts of the strategies on travel accessibility, this would allow the local community to evaluate the SLP more accurately.\nCommunity Cohesion. Scenario 1 would significantly increase population density in the chosen urban areas. The local community may see the new residents as intruding upon their space due to the higher population density.\nScenario 1 could lead to the loss of employment and commercial space. If sufficient jobs are not created in the surrounding area it would make the job market more competitive locally. So the current community may link this issue to the development of the new communities and the triggering of higher levels of local unemployment.\nScenario 1 could damage the character of heritage sites and the urban area. Heritage sites can be instrumental in strengthening community cohesion and involvement, so if they are made to be less significant then this would damage the community. Also, if the character of urban areas is damaged, this would weaken community cohesion as well.\nScenario 1 limits the potential for community infrastructure and could lead to a strain on existing infrastructure and services.\nThis could lead to segmentation between the old and new communities as infrastructure and services become less accessible, so the old community fails to properly integrate with the new community. Retrofitting of the enhanced public transport connectivity to 'existing' and 'permitted' development is critical alongside the additional housing proposed through the CGT SLP\nScenario 4 involves the creation of a new community, which could lead to exclusion by the current locals. But the council is working with the local community to prevent this from happening. Whenever a large scale development is proposed, the local government must listen to the existing community to avoid damaging community cohesion.\nScenario 4 may require a longer timescale to implement due to the size and complexity of the project. This could weaken community cohesion if the locals are waiting for construction to finish for a significant amount of time. If the area is a construction site for several years, this may  cause frustration with existing members of the community on safety, transport and other grounds. A step change in the content and approach of construction management plans and construction travel plan is needed \nScenario 5 is likely to revitalize smaller rural communities. Infrastructure and services are already more sparse in rural areas, so more infrastructure needs to be built to avoid making the issue any worse.\nThe SLP recognises the importance of community cohesion and placemaking. This potentially means that the SLP document will undergo a rigorous review process to allow the community to fully contribute and make the necessary changes.\nScenario 5 could damage community cohesion in rural areas. If scenario 5 is implemented, it needs to involve a significant amount of consultation with locals to determine whether new developments are viable.\nHousing. Scenarios 1, 3, 4 and 5 do not provide enough housing when utilised separately. If these strategies were implemented on their own, housing would likely become less affordable.\nScenarios 1, 3 and 5 would not provide a range of housing types, sizes and tenures. This means that there would be less housing available for those with specialised wants or needs (e.g. travellers). \nScenario 2 should be able to fill the housing quota. Hopefully this will result in housing becoming more affordable in the development areas.\nScenario 4 has the potential to provide the most certainty over long-term supply of housing. This makes the scenario vital to implement as the country is currently in a housing deficit.\nScenario 4 would take the most time to implement, this is because it is the largest in scale. This allows time for other scenarios to be focused on, while the plans are being drawn up for this scenario. But, it isn't able to meet immediate housing needs.\nScenarios 2, 4 and 6 are the most likely to provide a wide range of housing types, sizes and tenures. This makes these options more viable, as there are a wide range of groups who require specialist housing.\nScenario 5 strives to provide affordable housing in rural areas. This should help to disperse some of the demand for affordable housing in Gloucestershire. It also means that a wider variety of people can live in these new developments.\nThe housing provided in scenario 6 only caters for key urban areas, ignoring rural, and low-frequency areas. This could lead to worsening housing affordability in rural, and low-frequency areas. However this would allow sustainable travel options and last mile connectivity to be optimised in urban areas \nNone of the scenarios mention social housing. This shows that it isn't a priority for the council, which needs to be rectified.\nLand Use. Scenario 5 is likely to safeguard the green belt and could involve the utilisation of brownfield sites. This scenario would be the most beneficial for the environment.\nScenarios 2, 3, 4 and 6 would lead to the loss of greenfield sites, but scenarios 2 and 6 would also damage the green belt. It is very difficult to avoid the use of greenfield sites in the proposed developments, so it is likely that some will have to be utilised. Even though this will anger environmental groups, the council will have to choose between sufficient housing and the environment.\nThe Boddington location in scenario 4 would lead to loss of green belt land. This would be the least beneficial development location in scenario 4.\nScenario 1 has potential land-use issues. This may result in less employment opportunities for new residents\n"]
["Other","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","1) There should be no more development within Churchdown or in the surrounding area until issues concerning local infrastructure are addressed. This means\n\n1.1 the capacity of local schools and of the local doctors surgery\n1.2 the inadequacy of the local road network.\n•\tThis has been significantly degraded by the so-called 'flagship' cycle lane project which is currently managing the construction of a cycle lane alongside the B4063. This road will have all the lay-bys at each bus stop removed, so that the speed of the traffic will now be that of a bus, halting whenever the bus stops.\n•\tCyclists are still able to use the road instead of the cycle lane, so the speed of the traffic could be that of a cyclist. (The B4063 is now so narrow that it will not be possible for cars to overtake a cyclist without contravening the passing clearance requirements of the Highway code.)\n•\tThe B4063 is home to both an ambulance and a fire station. So it is quite likely that we will have a cyclist at the head of a long line of cars,  vans and a bus or two and possibly including an emergency vehicle 'on a shout' with the traffic queue travelling at the speed of the cyclist.\n•\tIt is said that drivers should use the A40 Golden Valley by pass instead of the B4063. However you need to use the latter to access the former. Also, at the Elmbridge Court roundabout, the B4063 is the only road onto the roundabout that is not controlled by traffic lights. So the traffic flow from the B4063 onto the Elmbridge Court roundabout depends upon the gaps in the roundabout traffic and so is a hit and miss affair, with greatly reduced traffic flow as a result.\n•\tLocal traffic flow is highly influenced by the dreadful parking out side the many local schools, both at the start and end of the school day and during. This will only get worse if more development is allowed. The risk of injury to a child remains and will increase. Proper off road drop off and pickup is needed urgently before further development.\n•\tThe local road infra-structure is also being degraded by the structural problems associated with the hump back railway bridge in Badgeworth Road - a major route in and out of Churchdown that offers a bypass to the B4063. The current position is that the embankments leading up to the bridge are subsiding so traffic over the bridge is restricted to a single lane in the middle of the carriageway, with traffic light control, in the hope that this will reduce the rate of subsidence. This is a dangerous solution as a vehicle or cyclist jumping the lights could easily cause a serious accident and blockage of that route in and out of Churchdown (it is not possible to see if anything is coming over the hump). Traffic flow on this route is anyway currently severely limited and, if the subsidence continues, prolonged closure of Badgeworth Road could be necessary.  Resolution of this issue, which the County Council has known about for more than twenty years, will be a long term project, involving the closure of Badgeworth Road (if it has not already happened), the construction of a new bridge and possibly re-routing Badgeworth Road over the new bridge. The railway authority will be involved and they are not known for being responsive. There must be no further local development until the Badgeworth Road railway bridge issue is completely resolved.\n•\tThis latter point illustrates the complete inability of local authorities to actually engage in joined up thinking. Given that most families have two working parents with the need for the parents to travel to and from work and to transport children to and from school (and there may also be grown up off-spring living at home) there will always be pressure on local road infrastructure. Given that the B4063 cycle lane project, the Badgeworth Road railway bridge problem, the Strategic Plan and the schools' traffic issue will each increase the pressure on the road infrastructure, the resolution of these problems, in order, should have been:\no\tThe schools' traffic, drop-off and pick-up problem\no\tThe Badgeworth Road railway bridge (there were twenty years in which to sort this out)\no\tThe M5 bridges\no\tThe B4063 cycle lane\no\tThe transport issues arising from the Strategic and Local Plan, bearing in mind that there is already significant through traffic on a poor road infrastructure.\n    As it is, these issues have become quite entangled. I hope that the Local Authorities are ashamed of what has transpired. They should be. \n2) Desecration of Local Green Open Spaces\nOne of the main benefits of living in Churchdown is the local access to countryside, with all the benefits that brings in term of health and fitness. If the Plan is implemented, Churchdown will become a part of one big housing estate with Chosen Hill sticking out of the middle. The opportunity for long local country walks will be gone for ever. How does this fit in with the Green Agenda of the Government and the concern for the health and well being of local inhabitants? The aim would appear to be to compel everyone to live in the middle of an urban sprawl and, if you currently have local access to green fields and fresh air, the faceless local authorities will see that this benefit is quickly removed"]
["","",15,"","","Yes","We broadly support the draft vision's focus on sustainable growth, addressing climate change, meeting housing needs, and creating high-quality living environments. These goals align with our commitment to responsible development that benefits the community.\nWe would like to offer specific feedback and suggest the following changes: Firstly, we recommend setting ambitious housing targets that reflect current 3 and projected market demand. Our analysis suggests that a higher target is both achievable and necessary to address the area's housing needs. Secondly, we advocate for incorporating greater emphasis on flexibility in housing types, densities, and design approaches. This allows developers to respond effectively to diverse market segments and create more vibrant communities. Thirdly, we advocate for the inclusion of a clear infrastructure plan outlining necessary upgrades and timelines. This should specifically address transport, utilities, schools, and other essential services needed to support new residential developments. Finally, while appreciating the long-term vision, we propose incorporating shorter delivery timeframes for specific housing elements within the plan. This will support timely delivery and contribute to meeting the community's more immediate needs.\nWe believe these suggested changes will enhance the draft Local Plan and create a framework that fosters sustainable development while ensuring that housing needs are met in a timely and effective manner. Hannick is committed to working collaboratively with the council and local communities to deliver high-quality residential projects that contribute to the area's long-term prosperity and align with the principles outlined in this vision.","","","","","","No","","","","","","No","Hannick, a land promoter focused on delivering essential housing, supports the adoption of the annual housing need calculation derived from the Standard Method as a starting point. We believe this offers a transparent, data-driven, and consistent way to identify a minimum housing target that supports a sustainable housing market. 5 2.15 Given the acute housing needs within the area, we encourage the Councils to carefully consider whether an upward adjustment to the Standard Method calculation is warranted. This adjustment should reflect the most up-to-date market analysis and demographic trends, ensuring the housing target aligns with both current and future demand. A more ambitious target would send a strong signal to the development sector, encouraging the delivery of muchneeded housing. 2.16 We understand the importance of balancing housing delivery with other planning considerations. However, the Standard Method provides a robust foundation for setting realistic goals. We are committed to working collaboratively with the Councils to bring forward suitable, deliverable sites that help meet the area's housing needs, as identified through the Standard Method, or through a carefully considered upward adjustment.","No","Hannick strongly believes that the number of houses planned for in the Strategic and Local Plan should not fall below the calculated need identified through the Standard Method. In fact, we urge the council to consider an upward adjustment to this figure to address the area's acute housing needs. A comprehensive market analysis and assessment of demographic trends are essential. This ensures the housing target aligns with both current and projected demand, tackling the undeniable housing shortage within the area. Delivering less than the calculated housing need would only exacerbate this critical issue.\nThe presence of greenbelt land within the area is acknowledged. However, the National Planning Policy Framework (NPPF) itself recognises the need to balance greenbelt protection with development requirements (paragraphs 142- 6 156). Of relevance is NPPF Paragraph 149, which allows for the controlled release of greenbelt land in 'exceptional circumstances'. We believe that the need to deliver new homes and the significant benefits they bring to the community can constitute such exceptional circumstances. These benefits include meeting housing needs, stimulating economic growth, and fostering vibrant communities.\nWe are committed to working collaboratively with the councils to explore all viable options for achieving the housing targets. This includes identifying suitable and deliverable sites that meet the area's needs while respecting important environmental considerations. A robust assessment process would be crucial to determine if exceptional circumstances, as defined by the NPPF, justify the controlled release of any greenbelt land. Furthermore, we acknowledge the recent update to the NPPF, particularly paragraph 147. When considering potential greenbelt release, we believe it's crucial to prioritise sustainable development patterns, and measures to offset any impact through environmental improvements to remaining greenbelt land.\nWe believe a strong case can be made for exceeding the calculated housing need and exploring all options within the framework set by the NPPF. This includes considering potential greenbelt release in demonstrably exceptional circumstances, where the wider societal benefits of new homes clearly outweigh the impact on the protected greenbelt. We are committed to working collaboratively to achieve sustainable development that meets housing needs while respecting environmental considerations.","","","","","","","","Hannick believes the Strategic and Local Plan can play a pivotal role in strengthening the rural economy by enabling housing development that directly supports employment opportunities. Allocating carefully planned housing sites 7 within rural areas fosters sustainable growth and helps to create vibrant communities where workers can live in proximity to their place of employment.\nRural businesses often struggle to attract and retain workers due to the lack of nearby housing options. Well-located housing within rural areas can directly address this workforce shortage, supporting business growth and resilience. Furthermore, enabling workers to live closer to rural jobs reduces the need for long, unsustainable commutes, alleviating pressure on transport networks and lowering carbon emissions. The availability of suitable housing in rural areas can attract skilled workers and young families, diversifying the rural economy and supporting its long-term vibrancy. Strategically planned rural housing developments, accompanied by essential services and amenities, create balanced and sustainable communities with both jobs and homes.\nWe recommend conducting a comprehensive assessment of housing needs specifically linked to rural employment sectors, such as agriculture, tourism, and rural businesses. This should be followed by a focus on smaller-scale housing developments designed to integrate sensitively within the existing rural landscape and respect local character. It's crucial to include a provision for affordable housing to ensure rural workers and their families have access to suitable homes within their community.\nWe believe a balanced approach to rural housing, aligned with employment needs, is crucial for the Strategic and Local Plan's success. This strategy helps support economic growth and vibrant communities across the entire area. We are committed to working actively with the council to identify suitable sites for rural housing development that will meet identified employment needs and contribute towards a sustainable rural future.","","Hannick believes that incorporating strategic housing development within the Strategic and Local Plan can play a vital role in revitalising rural areas and safeguarding essential shops, services, and facilities. Well-planned housing developments within rural areas directly increase the local population. This expanded customer base supports existing businesses and creates opportunities for new services to flourish, especially those catering to everyday needs. Rural shops, community centres, post offices, and other essential facilities often face the threat of closure due to dwindling patronage. Increased housing provides a sustainable lifeline to secure their long-term viability.\nAdditionally, thriving local shops and services are the heart of vibrant rural communities. Housing development that supports these businesses and facilities contributes to a more attractive and thriving rural environment. Careful planning of housing within existing villages or well-connected settlements can help residents access essential services without relying solely on private vehicles, fostering more sustainable living patterns\nWe recommend prioritising housing developments integrated with existing rural settlements to ensure residents have easy access to shops, services, and facilities. Smaller-scale housing developments aligned with a village's character help retain their rural identity and support the viability of existing services without overwhelming them. Furthermore, a comprehensive assessment of essential services should be conducted alongside a housing market analysis. This will ensure that new developments effectively meet community needs and support the growth of necessary services and facilities.\nWe strongly believe that a strategic approach to housing can directly contribute to the protection and expansion of essential services and facilities within rural areas. New housing should be a catalyst for reinvigorating rural communities, 9 rather than a threat to existing businesses and services.","","","","","","","","","Scenario 1: Urban concentration; Scenario 2: Urban extensions","","","[Q1] Hannick strongly advocates a 15-year timeframe for local plan coverage. This extended planning horizon offers crucial advantages for effective community development and aligns with best practices in strategic planning. \nFirstly, the 15-year period fosters predictability and facilitates long-term decision-making. It provides residents, businesses, and investors with a clear understanding of the area's developmental trajectory. This stability encourages investment aligned with the community's overarching vision, promoting sustainable economic growth. \nSecondly, this timeframe is essential for integrating major infrastructure projects, which often possess lengthy planning and construction phases. Aligning the local plan with the timelines of such projects ensures that vital infrastructure develops in harmony with broader growth strategies, preventing potential bottlenecks and inefficiencies. \nThirdly, a long-term perspective is indispensable for addressing complex environmental challenges such as climate change, biodiversity loss, and resource depletion. Local plans spanning 15 years enable the incorporation of robust policies that promote renewable energy, ecological conservation, and transitions towards a low-carbon economy. \nImportantly, the 15-year framework does not imply inflexibility. Regular reviews, mandated at least every five years, allow for the necessary adaptation of local plans in response to changing demographics, economic trends, and emerging priorities. This built-in adaptability ensures that plans remain relevant and responsive to dynamic environments. \n In conclusion, the current 15-year planning period for local plans represents a well-considered and balanced approach. It facilitates long-term strategic vision while retaining the flexibility required for effective community development in an ever-changing world.\n\n[Q8] Hannick is committed to sustainable development. However, we believe that increasing biodiversity net gain requirements beyond the mandatory 10% minimum would place an excessive burden on development sites and could jeopardise the deliverability of much-needed housing projects. \nWhile we fully acknowledge the importance of biodiversity and support efforts to enhance natural environments, we believe that requiring significantly higher biodiversity net gain targets could have negative implications. Increased development costs associated with greater biodiversity targets could threaten 4 the financial viability of projects, especially on smaller or more challenging sites. This risk of undeliverable projects could stifle housing supply, directly undermining the goal of addressing the housing shortage and meeting community needs. Additionally, the complex calculations and lengthy process of acquiring offsetting biodiversity credits for higher net gain targets can lead to significant project delays, further impacting housing availability. Instead of mandating higher percentages, we suggest a more balanced approach. This could include case-by-case assessments to determine achievable biodiversity net gain levels without jeopardising project feasibility, prioritising onsite biodiversity enhancement measures before resorting to external offsetting, and promoting collaborative working between developers, councils, and environmental organisations to identify creative solutions, potentially with targeted incentives. \nHannick is dedicated to working responsibly within the planning system to achieve balanced outcomes. We believe that a more nuanced approach to biodiversity net gain, focused on realistic targets and innovative solutions, will better support both housing delivery and environmental protection in the long term.\n\n[Q29] - Hannick believes the Strategic and Local Plan's focus should be on Urban Concentration (Scenario 1). This approach, alongside targeted and justified Green Belt release, offers the best strategy to meet housing needs while respecting essential environmental considerations.\nGreen Belt Release: Prestbury Site\nWe advocate for the release of our landholding, located south of Shaw Green Lane and north of Prestbury centre (see site location Appendix 1), from the current Green Belt designation. We strongly believe this site aligns with the NPPF's guidance on exceptional circumstances meriting Green Belt adjustment. Extensive assessments, including the Cheltenham Green Belt Review (AERC, 2007), demonstrate that our site makes minimal contributions to the Green Belt's core purposes. Surrounded on three sides by existing development, further residential use would not increase sprawl or erode the essential separation between Cheltenham and Bishop's Cleeve. This earlier assessment aligns with the findings of the JCS Inspector, who recognised the strategic-level nature of the subsequent AMEC review.\nThe Green Belt Assessment (AMEC, 2011) classifies our site as part of a larger parcel (NE22) deemed to have 'significant contribution.' We firmly disagree. Our site, unlike most of NE22 which encompasses the open expanse of Cheltenham Racecourse, is enclosed by development, and lacks the open countryside characteristics vital to Green Belt function. Accompanying studies (MHP Design, Orion Heritage) demonstrate that a carefully designed development informed by our Framework Plan can be integrated with minimal visual or heritage impact. The site's landscape features offer limited 10 contribution to the AONB's setting or the character of surrounding settlements. Importantly, the Framework Plan preserves key elements within the site, ensuring effects to designated heritage assets, such as The Hayes, are minimised.\nOur site is not subject to flood constraint, available for immediate development, and can accommodate approximately 140 homes within a deliverable timeframe. This directly addresses the area's housing shortage and provides significant societal benefits, including supporting local businesses, creating a more vibrant community, and potentially attracting vital skilled workers to the area.\nGreen Belt Modification with Offsetting Measures\nWe recognise the importance of the Green Belt. Should our Prestbury site be released, we fully support implementing measures, as outlined in NPPF paragraph 147, to offset the impact through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. This could potentially include enhancing existing green spaces within the surrounding area or creating new ones.\nHannick strongly believes that a balanced approach involving urban concentration and carefully considered, localised Green Belt release offers the best solution for the Strategic and Local Plan. Our Prestbury site presents a strong case where exceptional circumstances exist, justifying its removal from the Green Belt to deliver much-needed housing in a sustainable manner. As a land promoter and housebuilder with a proven track record, we are committed to working collaboratively with the council to bring this site forward, contributing to the development of high-quality homes, respecting the community's character, and supporting the area's long-term prosperity.\n\n[General] - Hannick Developments, a land promoter and SME housebuilder, strongly advocates for a strategic approach that balances urban concentration with targeted Green Belt release to address the area's critical housing needs. We believe this approach offers the most effective way to deliver sustainable development, create vibrant communities, and respect environmental considerations.\nWe firmly believe the Strategic and Local Plan should adopt a 15-year timeframe to foster predictability, align with infrastructure planning, and support long-term sustainable growth. It should also set ambitious housing targets reflecting true market demand to tackle the housing shortage effectively. The plan must prioritise sustainable development, focusing on urban concentration while carefully considering exceptional circumstances for localised Green Belt release where wider societal benefits outweigh the impact. Additionally, biodiversity targets should be balanced to achieve gains without jeopardising project viability by using case-by-case assessments, prioritising on-site enhancements, and promoting collaboration. Finally, the plan needs to support rural economies through strategically planned rural housing that can protect essential services, attract a skilled workforce, and strengthen rural communities.\nOur site south of Shaw Green Lane, Prestbury, exemplifies where exceptional circumstances warrant Green Belt modification. It has limited Green Belt contribution, is enclosed by development, and offers an opportunity for sustainable, integrated housing development. We are committed to delivering high-quality homes, contributing to the local community, and working with the council to offset any Green Belt impact through compensatory environmental improvements.\n\n[See also original submission including site location and draft framework plans, Landscape and Visual Sensitivity Assessment (by mhp) and Heritage Contraints Appraisal (by Orion)"]
["","",5,"Should also cover:\n\n•\tPlans for existing A46 changes and the potential re-routing of said road, based on Gloucestershire County Council (GCC), and Western Gateway (WG) current/upcoming submission. \n\n•\tAs well as the aspirations of Midland Connect (MC) plans for a route from the North East Ports through to Avonmouth, via the M5 at Junction 9. It is clear to see that there is a lack of joined up thinking. \n\n•\tWhat needs to happen first, infrastructure or housing, to my mind, facilities should come first, with ‘Active Transport’ at the forefront.\n\n•\tAttention should also be given to existing infrastructure, including current pollution levels and the schools close to Junction 9 of the M5.\n\n•\tAll development should not increase any form of pollution and actively seek to decrease in line with the Paris Agreement, if not better.\n\n•\tDevelopments anywhere near the Green Belt, ANOB, Special Landscape Areas and all forms of land preservation must be avoided.\n\nTewkesbury and surrounding areas are proven to have inadequate flood protection schemes, how are upcoming schemes going to overcome this?","Excellent aspirations, hopefully they can be carried out before too much land is taken up by builders’ creating housing estates that mainly cater for car owners.\n\nOngoing settlement creep must not be permitted.","","","","","Avoiding any development that increases car use.","Limited parking and apartments/flats enable more public green space and a closer-packed community.\n\nPlace-making around sustainable transport and green spaces.\n\nBuilt around walkable streets.\n\nMany civic facilities built early on and at a walkable distance from homes.\n\nAbut existing urban area for easy walking/ wheeling in and out of development.\n\nMixed use development around streets.\n\nFrequent electric bus services in operation early on.\n\nBus stop locations and infrastructure factored in early in planning the layout.\n\nMetro/Mass transport station open and up and running to serve new area with interchange to buses. Frequent ‘turn up and go’ services, including evenings.","Should follow Development Scenario 1 as well as looking again at the plans for the centre of Tewkesbury. \n\nConversion of empty premises to housing and facilities, closure of the High Street to traffic, etc.","Yes","","","Stores, cafés, health facilities, recreational, social venues, schools etc.","Yes","Solar panels in areas where it would be impossible to build on, for example flood plain.","No","I think not based on Councils' expectation of a steady increase in population and the popularity of the area. Everything slows, continued growth is not guaranteed. ","Yes","If the number of housing developments continues in and around Tewkesbury, at the current rate, then one would think the numbers quoted will be high.\n","","","","","","Should look to support the Town/City centres as shopping habits are changing fast. Discourage large out-of-town shopping developments, as they only encourage car travel and take business away from existing suppliers.","","","Should look to support the Town/City centres as shopping habits are changing fast. Discourage large out-of-town shopping developments, as they only encourage car travel and take business away from existing suppliers.","Should look to support the Town/City centres as shopping habits are changing fast. Discourage large out-of-town shopping developments, as they only encourage car travel and take business away from existing suppliers.","Avoiding any development that increases car use.\n\nLimited parking and apartments/flats enable more public green space and a closer-packed community.\n\nPlace-making around sustainable transport and green spaces.\n\nBuilt around walkable streets.\n\nMany civic facilities built early on and at a walkable distance from homes.\n\nAbut existing urban area for easy walking/ wheeling in and out of development.\n\nMixed use development around streets.\n\nFrequent electric bus services in operation early on.\n\nBus stop locations and infrastructure factored in early in planning the layout.\n\nMetro/Mass transport station open and up and running to serve new area with interchange to buses. Frequent ‘turn up and go’ services, including evenings.","As mentioned above 23 10 6 and 7.","Provide ‘Active’ transport and discourage car use.","","Yes","As mentioned before, repurposing of town centres and empty premises should be considered. \n\nIn Tewkesbury’s case, thought should be given pedestrianisation, which can bring additional social benefits to urban centres as well as boosting economic activity. Studies around the UK found an increase in trading of up to 40% across a number of pedestrianised sites.","No","It is clear that the Cons for Scenario 5 far outweigh the Pros and should not be considered at all.\n\nScenario 6 mentions the Local Transport Plan which has now been submitted once by Western Gateway and GCC is now way out of date. A proposed consultation on an update to the plan has now been cancelled twice in the last 18 months. How can the SLP gain ground if there appears to be little consultation between all parties or the ability of Western Gateway to move things forward?","Scenario 1: Urban concentration; Scenario 6: Sustainable transport scenario","","","[Q1] Five years with aspirations for the following five years. It is clear that Tewkesbury Borough Council (TBC) is working to an ever-increasing population without any fall off in future years. As such, 15 years at this time is too long.\n[Q8] Definitely more than 10% and should also take account of the loss of biodiversity over the last 30 years. It is also imperative that newly planted trees are cared for, as many die in the early stages of growth through lack of care.\n[Q15] Only if it can be guaranteed that they are well run and not located close to existing communities. \n\n[Q26] If the infrastructure for any new development is designed well, then any future building could be added easily with little disruption or duplication.\n\n[General] Whilst Councils are planning the future, it is imperative that all ongoing planning applications follow the aims and objectives of the SLP, any appeals should be fought, and local needs should not be dictated to by central government.\n\nAll new homes, as of now, should be fitted with solar panels and batteries, before planning is granted."]
["Planning agent or developer","Chuchill Retirement Living","","","","Yes","","","","","The Council’s commitment to meeting both its and the UK Government’s target of net zero carbon emissions by 2050 is commendable. \nWe consider that the wording of any forthcoming policy should encourage developers to maximise opportunities to reduce greenhouse gas emissions, but not mandate enhanced standards above those in Part F and Part L of the Building Standards.  \n\nThere is considerable momentum from Government in preparing enhanced sustainability standards through The Future Homes Standards and it is clear the energy efficiency requirements for domestic and non-domestic buildings will increase sharply in the coming years.  Realistically by the time a new Local Plan is adopted, the Building Regulations will require all new housing to be ‘net zero ready’.\n\nThis will be a considerable challenge for the house-building industry who will require time to develop the materials and the skills necessary to build zero carbon homes in the volumes required to meet housing need.  \n\nOn a more practical level we note that many Local Plan policies that stipulate technical requirements for carbon reduction technologies or measures tend to date badly. In most cases these requirements are superseded by the Building Regulations, but in some cases, they contradict it. \n\nAligning the Council’s requirement for carbon neutral development with those of Government would therefore be welcomed.","","","","","","","","","","","","Yes","Churchill Retirement Living is an independent, privately owned housebuilder specialising in sheltered housing for older people. \n\nParagraph 1 of the PPG Housing for Older and Disabled people states:  \n\n“The need to provide housing for older people is critical. People are living longer lives and the proportion of older people in the population is increasing. ……. Offering older people, a better choice of accommodation to suit their changing needs can help them live independently for longer, feel more connected to their communities and help reduce costs to the social care and health systems. Therefore, an understanding of how the ageing population affects housing needs is something to be considered from the early stages of plan-making through to decision-taking”.\nParagraph: 001 Reference ID: 63-001-20190626\nIt is well documented that the UK faces an ageing population. Life expectancy is greater than it used to be and as set out above by 2032 the number of people in the UK aged over 80 is set to increase from 3.2 million to five million (ONS mid 2018 population estimates).\nThe Homes for Later Living Report notes the need to deliver 30,000 retirement and extra care houses a year in the UK to keep pace with demand (September 2019).\nThe age profile of the population can be drawn from the most recent Census (2021). This advises that the total population size across all three Authorities 2021 was 346,130 of which 66,110 persons were aged 65 and over, comprising 19.3% of the total population. The population aged 80 and over, who are generally more likely to be frail and in need of long-term assistance comprises 18,776 persons or 5.4% of the population. \nThe 2018 population projections from the Office for National Statistics advises that the population aged 65 and over is projected to increase to 98,319 by 2043, accounting for 25.3% of the total population. The number of individuals aged 80 and over is expected to increase more sharply with an increase to 35,626 persons (9.2% of the total population) over the same period. \nIt is therefore clear there will be a significant increase in older people over the Plan Period and the provision of suitable housing and care to meet the needs of this demographic should be a priority of the emerging Local Plan. ","","","","","","","","","","","","","","","","","","","",""]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I am at a loss to understand the thinking behind the questions posed in the SLP consultation. It represents top-down strategic thinking and is a far away from local involvement as you could get.\nIn all honesty, the JCS was an unmitigated disaster, placed into review from the outset and spectacularly failed to accomplish anything and is now redundant.\nTewkesbury Borough Council were at an immediate disadvantage given the paucity of development land in either Cheltenham or Gloucester.\nNow you plan to reinvent the wheel with another evidence base (the HELLA) which no doubt will identify again all the green fields round Twyning.\nI see that in the Rural Dispersal section of the Plan you intend to dump more housing on Services villages and in desperation, extend that out to the smallest hamlets and villages.\nAfter protracted insistence that TBC had a 5-year land supply, they finally had to accept that double accounting was not allowed and conceded formally that they do not have a 5-year land supply.\nDespite Twyning having a Neighbourhood Plan ( and yes it is over 5 years old) we found ourselves together with all the other Service Villages inundated with speculative planning applications for housing.\nFor Tywning this was not all - we have just lost an appeal against a 9 year Sand & Gravel quarry haul road, processing and concrete batching plant in our parish, likely to be detrimental to two nearby businesses that employs well over 200 people.\nWe have lost on appeal on an extension to a local business park and are facing a similar application, this time for a massive (Distribution sized) extension to Brockeridge business park.\nAdd in a number of further housing developments and a very large solar farm, you wonder why I am extremely sceptical of the new SLP.\nAs it will (eventually) do away with the newly adopted Tewkesbury Local Plan, it will no doubt also put further into question the relevance of our NDP I simply can’t understand why TBC are falling for the same plot, even more so given that they will loose their recently adopted Local Plan.\nParish level communities have been badly let down by this misguided top down strategic thinking.\nTewksbury are ill advised to sign up again to this new SLP. In these uncertain political times with a prospective Labour Government on the horizon, this could be kicked it into the long grass well before adoption."]
["Resident","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","It's probably too late but I forgot to mention something on the survey consultation. \n  \nI want to add that despite developers arguing that they will make sustainable travel routes for the Whaddon Plans in Gloucester, site allocation G2, this is unrealistic as people will not give up their cars. The road infrastructure is not suitable for the increases in traffic and could never be made suitable. "]
["","",15,"","","No","On the whole, there is agreement with the draft Vision. It is recognised that people’s housing needs must be met through the provision of sustainable, high-quality and affordable housing in sustainable locations. It is also recognised that, in part, this will be through comprehensively planned new development, which takes into consideration the facilities and infrastructure required to accommodate new growth without overwhelming services present in existing settlements. The draft Vision recognises that “Growth will have been supported by the provision of a range of essential digital, transport, community and other infrastructure” – it is therefore essential that new development takes a holistic approach and is directed towards settlements that have the sustainable infrastructure readily in place (which can also be improved where necessary) as well as good local facilities nearby. This is reinforced in the draft Vision in terms of travel – “Growth in sustainable locations will have enabled the provision of healthy, accessible and walkable neighbourhoods, the promotion of active travel and sustainable travel, and provision of new transport systems that work for local people” – therefore new developments should be located in locations where sustainable transport infrastructure can be best utilised, i.e. Cheltenham Road East/Gloucester Road, which is the subject of recent major highway/cycle/pedestrian improvements providing links to existing services and facilities, through a range of transport modes.","Yes","","","","","","","","","","","Yes","Using the Standard Method, Gloucestershire’s identified need is 35,700 new homes over a 20-year period – 1,785 annually. The Strategic and Local Plan should use the local annual housing need calculation from the Standard Method in order to provide fully for the housing need of the combined area. ","No"," the housing requirement should reflect the calculated housing need, in order to meet the full need of the area","","","","","","","","","","","","","","","","","Yes","","Scenario 1: Urban concentration; Scenario 2: Urban extensions","","","[Response to Q1 - It is really positive that the three councils are adopting a strategic approach to development and working together in preparing the joint plan. As set out in the document, the intended plan period of 15 years should be considered a minimum, ideally a longer time period should be considered, especially for strategic level growth, which it is acknowledged does take a significant period of time to deliver. This long time horizon is important to provide the certainty that is required, for the development industry, stakeholders and the community in enabling investment and ensuring that long term patterns of development are clearly understood and accepted]. [Additional info to accompany Q5: The strategic objectives outlined take a positive approach in terms of the direction/location of new growth and reflects the overall approach taken in the draft Vision. For example, there is great emphasis on “integrating new development with existing networks and enhancing wherever possible”, as well as ensuring growth takes place in locations with “sustainable transport and active travel options”. The strategic objectives also recognise the need to deliver housing of the right size, type and tenure, including “market and affordable, specialist homes, Gypsy, Travellers and Travelling Showpeople and self and custom build homes”. It is reinforced that these homes should be built in “sustainable locations, and with good access to shops, services and facilities”. It is positive to see that there is repeated mention within the objectives to integrate new development into existing, sustainable travel networks. The final set of objectives are also beneficial to sustainable growth and you can see that there is a desire to implement sustainable travel in tandem with essential local infrastructure to “maximise wellbeing and active travel opportunities”. It is recognised that new developments be “supported by the necessary social and community infrastructure, including schools, open space, playing fields, community facilities and green and blue infrastructure”]. [Additional response to Q13 - No – the housing requirement should reflect the calculated housing need, in order to meet the full need of the area]. [Additional response to Q28 - The pros and cons of this scenario are generally fair and accurate.]. [Additional response to Q29 - It is accepted that redevelopment of brownfield land within settlements (Scenario 1) is a sustainable approach and is supported. However, as set out in the Cons for this scenario, this will not deliver sufficient levels of development to meet need. As a result, it is proposed that a combinations of development options will need to be explored and this should include Development Scenario #2 (Urban Extensions). In this way, growth can be directed towards settlements with good existing facilities and integrate and improve on existing transport infrastructure within these areas. In order to deliver this growth the plan will need to consider the release of Green Belt land. By definition this includes land on the edge of settlements where growth can be best managed and integrate well with existing infrastructure and local facilities. Where there are exceptional circumstances, release of Green Belt land to meet the housing need will result in delivery in sustainable locations. One of the suitable locations for sustainable urban extension, is the land north of Churchdown which was previously identified as a draft allocation in the JCS and remains available for development]. "]
["Local Councillor","Alderton Parish Council",30,"","Flood policy topics are most important and predominantly unique to the Tewkesbury area. Similarly local policy topics dealing with the rural villages are most relevant to the Tewkesbury area where many of the villages are located. Those wide leisure and tourist economy areas of the Cotswolds and open countryside which attracts visitors are also based mainly within the Tewkesbury area – as are countryside tourism policies, open space , natural environment policies are more local to Tewkesbury areas.","","Strongly agree to a truly sustainable location based plan for the provision of the identified housing need. Important to id sustainable criteria – accessible to the right jobs, leisure, retail, public transport facilities. Brownfield reuse. Identifying specific local rural need vs borough city wide housing need. The draft vision is excessively long and cumbersome , trying to cover all areas. There needs to be a more succinct vision based around providing the identified needs of housing and employment in the most sustainable locations – to reflect the key objective of addressing/reducing the causes and effects of climate change. ","","","By ensuring the plan is truly a sustainable location based plan for the provision of housing and employment needs. By making sure everyone has access to jobs, housing, leisure, retail, education via other modes of transport than the car. Whilst it is acknowledged that home working has increased since the pandemic – there is a shift towards a mixed hybrid type of working with part office and part home based. So Public transport and sustainable urban locations remain the two most important factors in effectively tackling climate change. Need to have a clear understanding of what is a sustainable location on a housing scheme. Limiting reliance on car – facilities such as a small shop in a village cannot represent or address retail need, a village pub which employes one or two casual bar staff does not address an employment need, a primary school does not address overall education need.","In terms of constructing new buildings – design policies to ensure quality design are required – but in terms of housing design this must reflect local identity particularly of rural villages and their unique character – not simply homogenous housing estates . Whilst there are minimum internal space standards for housing this should be coupled with maximum space standards for private housing to ensure effective and efficient use of land for family housing. Example – recent developments in Alderton village “complied “ with the identified housing mix in terms of the correct % of 2, 3 , 4 and five bed houses. While this remained the case of Affordable units which just about met the minimum space standards – the private sector housing was excessively larger than the space standards. Although pointed out at the time – it was argued they showed only a three bed unit. Once approved amended plans showing internal changes and therefore not needing any further permissions changed the units to four bed units , thus not then complying with the housing needs in terms of mix – but nothing could be done to resist such changes. Increased profit for developers but not then meeting the identified needs . If there were adopted maximum space standards such changes could not happen . This would then ensure efficient use of land and future compliance with identified mix and sizes.","In terms of retention and reuse there should be policies resisting the loss of family housing by subdivision. It can be anticipated that there will be an increase in smaller units in urban areas during the next plan period , which means importance of retaining existing larger house units. Houses should also have inbuilt flexibility to accommodate multi generational families. Agree to encouraging farm diversification and enabling provision of effective home working but not taking away the need to interact with other businesses, facilities, leisure, retail . Whilst Covid resulted in many working 100% from home – this has changed to a more broad based hybrid type of work with some days in the office and some home working .","","","","Key services must include reasonable access to a minimum retail floorspace identified – not just a very small shop with no supporting bathroom facilities or storage facilities. Similarly employment facilities as an identified key service must be identified as a variety of available employment jobs in a locality not just a couple of casual bar staff roles in a village pub. Key services must also include ready access to varied education, leisure, and health facilities by means other than a car – not just by a once a day bus service and no safe cycle facilities. Ie housing and key services need to be in sustainable transport locations. This is fundamentally important , but clarity is needed on identifying what “key Services” are – such services are generally very limited in rural villages which can therefore only accommodate a much smaller local need based level of development .","","","","","Yes","There may be some argument to seek a lower housing figure for Tewksbury than identified via the standard methodology given the areas of flood , sensitive landscapes and unsustainable locations for the majority of scatter villages within the Borough that have virtually no public transport facilities to access appropriate scale key services.","Yes","In rural communities, there is a need to provide affordable smaller less executive homes to directly cater for a young population wanting to stay local – although this conflicts with the need to have easy access to the job market, education, health, leisure and retail facilities without the need to rely on the car. In reality most younger generation wish to access a greater range of such facilities rather than being isolated in a rural community. At the other end, an aging rural population have more direct needs such as close health support, a strong community identity and a need to be able to down size, and have homes which are adaptable to future mobility restrictions such as bungalows . What rural communities do not need are significant numbers of executive 4 and 5 bed houses where all occupants need car usage to access all necessary facilities and services. Teenagers to secondary schools and further education and leisure entertainment needs, parents who hold down full time jobs increasingly at job locations although acknowledging some home/hybrid working continues. Such executive size homes should be located in the urban expansion areas and new strategic settlements where such needs are accessible locally without a 100% reliance on cars.","","","","","By ensuring employment areas are highly accessible to the working population and the supply and delivery needs of the business. As such located within sustainable transport locations and corridors.","Allowing for farm diversification/ by maintaining the rural landscape rather than allowing large swathes of greenfield areas to be ad hoc developed for housing. Protecting the most important agricultural areas.","Allowing more change of use of upper floors within centres for residential, increased density for residential within centres and walking distance of centres, allowing greater flexibility of ground floor spaces to change as needs change , by introducing employment zones close to centres to increase footfall, encouraging central student accommodation to retain a vibrant nightlife and leisure environment. Encouraging independent retailers, keeping rents lowers to attract opportunities,","Having policies to prevent loss of village facilities unless alternative facilities secured in locality. Policies requiring marketing periods of say two years before loss allowed. .","Road infrastructure improved to allow traffic flows. Public transport facilities and intertransport hubs to allow realistic alternatives to car modes. Improved safer cycle routes.","Given the scale of new settlements created – education facilities ie secondary schools are required together with sports/leisure facilities., minimum floorspace retail and employment hubs to provide varied job opportunities.","Key services should start with accessibility via modes other than car to larger centres where realistic opportunities for education, leisure retail and employment choices are available . With the very limited facilities available in small rural villages , any development should be very limited in nature and only of a scale that directly relates to the needs of that community. And not accommodating the needs of the whole borough as currently taking place. There is also a need to fully understand community cohesion – rapid expansion of rural villages with limited supporting infrastructure and the ability for communities to absorb large new estates must be understood. Again – identifying specific rural needs vs the larger wider plan wide housing need must be differentiated clearly within the Plan .","","Yes","It is considered that a combination of options could provide the most sustainable development opportunities for achieving the needs of the area. The Parish Council believe a combination of increased density and concentration in urban areas, with \nurban extensions allowing for some Green Belt releases to protect the wider natural landscape areas of the Borough , and focused within a clearly defined sustainable transport corridor, together with allowing for one or two new strategic settlements for later housing provision would achieve the overall housing targets identified. In respect of rural areas, with none or limited services and facilities which cater for very limited local need, a review of very local housing need options need to be formulated and once identified , kept to and not allowed to be exceeded, rather than allowing any future uncontrolled expansion which fundamentally undermines the whole concept of Planning for future need and growth within an overall Plan area.","","1 Urban concentration; we strongly agree there is scope for some of this (in combination with other scenarios below) in highly sustainable locations – where all facilities and infrastructure is accessible to all – especially those requiring affordable accommodation and therefore more need for easier access to a range of services/facilities – such as range of jobs, retail, education, without reliance of expensive motor car. 2 Urban extensions; we support this continued strategy which allows for concurrent infrastructure provision such as \nMass Rapid Transit Scheme, and provides for housing numbers in areas which are identified as having the greatest housing need – and in the most sustainable locations . Previous safeguarded sites have already been through a Local Plan Inquiry so should remain. There are significant pros associated with this ongoing strategy, in particular the economies of scale in terms of developing and providing well used public transport structures. A combination of this and the urban concentration would provide a wide range of types, tenures and sizes to cater for all needs, whilst benefiting from comprehensive planned infrastructure needs to support the communities. 3 urban extensions avoiding Green Belts; there is less support for this option . Clearly some removal of land from Green Belt has previously \nbeen accepted at the LP Inquiry and those sites should remain safeguarded. Urban expansion close to city and town centres has the significant benefits of being able to support the necessary transport infrastructure and benefits from the economies of growth which can then support necessary and connected services . Once again this proposal results in housing in sustainable locations where the greatest need is found. The loss of some green belt land is seen as preferable from expansive development of wider green field land which supports the rural economy and the leisure economy of the Cotswolds’ and better retains the wider natural environment. 4 New Strategic settlements; Tewkesbury Garden Town – Is identified, and subject to the strategic highway improvements \nenvisaged could provide, in a longer time frame a sustainable comprehensively designed settlement, and is supported in principle. Similarly, sites around Boddington and on the edge of Forest of Dean should be similarly explored –\nbut it is acknowledged that such stand alone settlements do take considerable time and up front infrastructure costs to be effectively well designed and comprehensive. As such a longer term Local Plan period would enable such strategic settlements to be developed and provide the longer term housing and employment needs of the joint region. 5 Rural Dispersal; this option is regarded as the least sustainable scenario which does not reflect any of the draft Vision – achieving carbon reductions and addressing the causes and effects of climate change. Scattering development throughout the rural areas will have significant damaging effects on climate change, the natural environment , leaving communities fractured with adverse impact on community cohesion, abandoning disadvantaged parts of the community struggling to access even the most basic services and needs. The previous JCS Settlement Hierarchy of Rural Service Centres and Service villages needs to be removed or rethought in light of the future vision for sustainable development which should be more \nintrinsically linked to accessibility to meaningful infrastructure and facilities. A more robust assessment of individual housing needs for rural settlements must be undertaken and adhered to rather than the current planning by appeal scenario we find ourselves in given that greenfield sites are easy development – but destroy the rural character of the area and provides none of the aspiring sustainable characteristics envisaged by the draft vision or indeed Current government thinking. 6 Sustainable Transport; once again it is clear that a sustainable location is paramount to achieving access to all services, facilities and jobs through non car modes of transport and thus achieve the vision of reducing carbon emissions. Focusing on a sustainable transport corridor means a logical concentration of \nresources to achieve a collective and varied transport network of non car modes. We support the prioritizing of new housing sites in locations where this increased choice of travel is to be focused. ","","","","[Q1] Given that the Local Plan is highly likely to have a minimum of one (Tewkesbury Garden Settlement) and up to three large strategic settlement sites included within the Plan – it would be appropriate to extend the Local Plan period to include the important contributions these settlements will play in providing large scale housing numbers in the latter periods of the Plan. Also given the length of time it takes to review/refresh a Local Plan , we believe the current minimum period of 15 years is too short to achieve the long term aims and development numbers required. A more realistic 25/30 year plan period should be sought so that longer term certainty is inbuilt into the plan for all within the plan area. Housing and Economic Land Availability Assessment. ALD 010 and ALD017 – both now have permission and so will be deliverable and will be included in overall housing sites in new plan and id numbers. \nALD018 – assessed as potentially developable for housing . quoted as being adjacent to village, not in AONB, and not identified as Local Green Space 9Allotment site). Methodology for assessing sites in HELAA. Stage 2 – broad location assessment and density assessments give site numbers. For Tewkesbury this continues to be identified as 30 dph – but given need for higher numbers increased density figures could easily be accommodated in the city centres – currently 40 for Cheltenham and 40-50 in Gloucester city – these figues could be raised. \nWe also support Need to update landscape character assessments, including landscape sensitivity – noting this review is to be undertaken . \nThis stage 2 assessment doesn’t take into account services available re sustainable locations at this stage. The criteria for identifying rural service centres and villages needs to be redone. Whilst below headings part of site assessment criteria they do not appear as headings in the site assessments tabs themselves. Other headings could be taken into account which Could include:\n• Site in Neighbourhood Plan\n• Proximity to archaeological sites [included in Methodology paper but not in site \nassessments]\n• Landscape sensitivity, including within setting of Cotswold National Landscape [ in \nMethodology but not assessments]\n• Public Rights of Way to be Proximity to PROW\n• Subject to previous Inspector Appeal Transport. Strongly support integration of a Sustainable Transport Strategy into the HELAA site assessments. \nMissing for too long. \nThe Broad Site Assessment centred around four objectives and eight sub-objectives. Broadly support Objectives except for Objective 1 – Reduce Travel Need and Journey Distances. In Objective 1 \nThe first metric relating to walking to key services . But this bears no relationship to size of the key service. Alderton is recorded as having access to 3 services which presumably includes schools [ \nagreed a primary school but not secondary or further education facilities], employment [ not agreed – employment of one or two casual bar jobs and a cook at the local pub does not count as available \nemployment opportunities . There are no other employment opportunities in the village of Alderton of any substance], healthcare [ obviously not – nearest Healthcare is in Winchcombe] and retail [ \nAlderton has a very little shop with no storage or toilet facilities and only open in mornings] The third metric measures access by bus but excludes frequency of service. This gives a wholly false \nposition on the practicality of using buses for employment, healthcare and retail. It also results in the overall assessment for Rural dispersal being Medium to High on par with all other development \nscenarios except Urban Concentration. This is wrong and is unrealistic of actual on the ground lack of Public transport capabilities for the village of Alderton. Suggest delete Objective 1. Key issues are covered in other objectives.\nSupport Objective 2 – a more realistic assessment of key issues, viable facilities and genuine alternatives to the private car. Support Objective 3 – Delivering inclusive community health and wellbeing. Objective 4 – focussing on the nearest SRN junction and the MRN seems a bit narrow. Inclusion of local traffic conditions eg volume of traffic, traffic hotspots and width of roads are all important. The transport section provides for some assessment of infrastructure but it is rather limited and specifically in relation to transport. The section could become Transport and Infrastructure and be a more detailed assessment applying to all settlements eg.Transport criteria [ see above]. Also including access to rail services and to Cheltenham and Gloucester Retail, but with a quantification of size, opening hours and type of provision; Community hall, with indication of size and parking; School, primary and secondary Pre school with indication of type of provision; Playground, with indication of size and provision; Allotments, with size; GP provision; Chemist; Public house\nEmployment with some detail of local employment and distance not just from nearest employment but from Cheltenham and Gloucester; Broadband; Library; Sustainability Appraisal. Obviously some repetition with other categories but support the inclusion of these wider factors and note that generally it is not Rural Areas that are best performing. Integrating these different categories is obviously key.\n"]
["","",20,"","","","","","","","","","","","","","","","","Please can you advise why we need all these additional houses? The birth rate is down the only reason appears to be huge immigration forecast over the next 10 years which is very likely to be reduced significantly? What are the sustainable drivers for this housing development who is demanding it? On what logic and facts do you base the need for all this development? I say again the birth rate is down, immigration will reduce we are told, so why so many houses. ","","","","","","","","","","","","","","","","","","","","","","","","[Q1] 20 Years but as with any plan should have annual and three-year review and report against SMART Objectives"]
["Local Councillor","Local Councillor","","","","","","","","","","","","Yes","I’m keen for us to designate Priors Farm Playground (has multiple local names, but for a google maps reference) and the adjacent green space currently used for attenuation as a green space in the upcoming plan. I’m confident it meets the criteria, though I know it has been cut off of the list at the last hurdle in previous discussions. It’s not greenbelt, it’s not continuous/expansive land (will be enclosed on all sides pending the completion of existing planning applications) and is a very well used local green space with children’s sports and a sports pavilion with new leaseholders keen to renovate it on-site. Close to multiple communities, particularly priors estate residents who are included in some indexes of multiple deprivation and have it as their walking distance green space site. With Oakley Farm being where it is now in planning terms it seems worthy of review in this round of local planning. ","","","","","","","","","","","","","","","","","","","","","","","","","","","","",""]
["Statutory/Specific Consultee","NHS Property","","There is a well-established connection between planning and health, and the planning system has an important role in creating healthy communities. The planning system is critical not only to the provision of improved health services and infrastructure by enabling health providers to meet changing healthcare needs, but also to addressing the wider determinants of health. Identifying and addressing the health requirements of existing and new development is a critical way of ensuring the delivery of healthy, safe, and inclusive communities. On this basis, we would welcome the inclusion of a comprehensive policy on health and wellbeing in the Local Plan and encourage the Councils to engage with the NHS on this matter ahead of the Regulation 19 document being prepared. Specific policy requirements to promote healthy developments should include: • Proposals should consider local health outcomes, and where appropriate to the local context and/or size of the scheme include a Health Impact Assessment. • Design of schemes should encourage active travel, including through providing safe and attractive walking and cycling routes, and ensuring developments are connected by these routes to local services, employment, leisure, and existing walking and cycling routes. • Provide access to healthy foods, including through access to shops and food growing opportunities (allotments and/or providing sufficient garden space). • Design schemes in a way that encourages social interaction, including through providing front gardens, and informal meeting spaces including street benches and neighbourhood squares and green spaces. • Design schemes to be resilient and adaptable to climate change, including through SUDs, rainwater collection, and efficient design. • Consider the impacts of pollution and microclimates, and design schemes to reduce any potential negative outcomes. • Ensure development embraces and respects the context and heritage of the surrounding area. • Provide the necessary mix of housing types and affordable housing, reflecting local needs. • Provide sufficient and high quality green and blue spaces within developments","","","","","","NHSPS fully support policies that promote carbon neutral development, and the securing of financial contributions where on-site carbon mitigation requirements cannot be met. In considering the implementation of policies related to net zero, we would highlight that NHS property could benefit from cardon offset funds. This would support the NHS to reach the goal of becoming the world’s first net zero healthcare provider.","","","","","","General Comments on Health Infrastructure to Support Housing Growth The delivery of new and improved healthcare infrastructure is significantly resource intensive. The NHS as a whole is facing significant constraints in terms of the funding needed to deliver healthcare services, and population growth from new housing development adds further pressure to the system. New development should make a proportionate contribution to funding the healthcare needs arising from new development. Health provision is an integral component of sustainable development – access to essential healthcare services promotes good health outcomes and supports the overall social and economic wellbeing of an area. Residential developments often have very significant impacts in terms of the need for additional primary healthcare provision for future residents. Given health infrastructure’s strategic importance to supporting housing growth and sustainable development, it should be considered at the forefront of priorities for infrastructure delivery. The ability to continually review the healthcare estate, optimise land use, and deliver health services from modern facilities is crucial. The health estate must be supported to develop, modernise, or be protected in line with integrated NHS strategies. Planning policies should enable the delivery of essential healthcare infrastructure and be prepared in consultation with the NHS to ensure they help deliver estate transformation. ","","","","","","","Yes","In undertaking further work on local housing needs, we suggest the Councils consider the need for affordable housing for NHS staff and those employed by other health and care providers in the local authority area. The sustainability of the NHS is largely dependent on the recruitment and retention of its workforce. Most NHS staff need to be anchored at a specific workplace or within a specific geography to carry out their role. When staff cannot afford to rent or purchase suitable accommodation within reasonable proximity to their workplace, this has an impact on the ability of the NHS to recruit and retain staff. Housing affordability and availability can play a significant role in determining people’s choices about where they work, and even the career paths they choose to follow. As the population grows in areas of new housing development, additional health services are required, meaning the NHS must grow its workforce to adequately serve population growth. Ensuring that NHS staff have access to suitable housing at an affordable price within reasonable commuting distance of the communities they serve is an important factor in supporting the delivery of high-quality local healthcare services. We recommend that the Councils: • Engage with local NHS partners such as the local Integrated Care Board (ICB), NHS Trusts and other relevant Integrated Care System (ICS) partners. • Ensure that the local need for affordable housing for NHS staff is factored into housing needs assessments, and any other relevant evidence base studies that inform the local plan (for example employment or other economic policies). • Consider site selection and site allocation policies in relation to any identified need for affordable housing for NHS staff, particularly where sites are near large healthcare employers.","","","","","","","","","As set out above, given health infrastructure’s strategic importance to supporting housing growth and sustainable development, it should be at the forefront of priorities for infrastructure delivery. Health infrastructure should be clearly identified in the Local Plan as essential infrastructure, with an expectation that development proposals will make provision to meet the cost of healthcare infrastructure made necessary by the development. In areas of significant housing growth, appropriate funding must be consistently leveraged through developer contributions for health and care services to mitigate the direct impact of growing demand from new housing. Additionally, the significant cumulative impact of smaller housing growth and the need for mitigation must also be considered by the Plan. We also emphasise the importance of effective implementation mechanisms so that healthcare infrastructure is delivered alongside new development, especially for primary healthcare services as these are the most directly impacted by population growth associated with new development. The NHS, Council and other partners must work together to forecast the health infrastructure and related delivery costs required to support the projected growth across the Local Plan area. NHSPS recommend that the Local Plan have a specific section in the document that sets out the process to determine the appropriate form of developer contributions to health infrastructure. This would ensure that the assessment of existing healthcare infrastructure is robust, and that mitigation options secured align with NHS requirements. The Local Plan should emphasise that the NHS and its partners will need to work with the Councils in the formulation of appropriate mitigation measures. NHSPS recommends that the Councils engage with the relevant Integrated Care Board (ICB) to add further detail within the Local Plan and supporting evidence base (Infrastructure Delivery Plan) regarding the process for determining the appropriate form of contribution towards the provision of healthcare infrastructure where this is justified. As a starting point, we suggest the following process: • Assess the level and type of demand generated by the proposal. • Work with the ICB to understand the capacity of existing healthcare infrastructure and the likely impact of the proposals on healthcare infrastructure capacity in the locality. • Identify appropriate options to increase capacity to accommodate the additional service requirements and the associated capital costs of delivery. • Identify the appropriate form of developer contributions. Healthcare providers should have flexibility in determining the most appropriate means of meeting the relevant healthcare needs arising from a new development. Where new development creates a demand for health services that cannot be supported by incremental extension or internal modification of existing facilities, this means the provision of new purpose-built healthcare infrastructure will be required to provide sustainable health services. Options should enable financial contributions, new-on-site healthcare infrastructure, free land/ infrastructure /property, or a combination of these.","","","","","","","","","","","NHS Property Services NHS Property Services (NHSPS) manages, maintains and improves NHS properties and facilities, working in partnership with NHS organisations to create safe, efficient, sustainable and modern healthcare environments. We partner with local NHS Integrated Care Boards (ICBs) and wider NHS organisations to help them plan and manage their estates to unlock greater value and ensure every patient can get the care they need in the right place and space for them. NHSPS is part of the NHS and is wholly owned by the Department of Health and Social Care (DHSC) – all surplus funds are reinvested directly into the NHS to tackle the biggest estates challenges including space utilisation, quality, and access, with the core objective to enable excellent patient care. At this early stage of the consultation process, our comments are focused on highlighting NHSPS priority areas important to embedding the needs of the health services into the Local Plan in a way that supports sustainable growth. \n\nNHSPS supports the provision of sufficient, quality community facilities. However, where healthcare facilities are included within the Local’s Plan definition of community facilities, policies aimed at preventing the loss or change of use of community facilities and assets can potentially have a harmful impact on the NHS’s ability to ensure the delivery of essential facilities and services for the community. The NHS requires flexibility with regards to the use of its estate to deliver its core objective of enabling excellent patient care and support key healthcare strategies such as the NHS Long Term Plan. In particular, the disposal of redundant or no longer healthcare suitable sites and properties for best value (open market value) is a critical component in helping to fund new or improved services within a local area. Requiring NHS disposal sites to explore the potential for alternative community uses and/or to retain a substantial proportion of community facility provision adds unjustified delay to vital reinvestment in facilities and services for the community. All NHS land disposals must follow a rigorous process to ensure that levels of healthcare service provision in the locality of disposals are maintained or enhanced, and proceeds from land sales are re-invested in the provision of healthcare services locally and nationally. The decision about whether a property is surplus to NHS requirements is made by local health commissioners and NHS England. Sites can only be disposed of once the operational health requirement has ceased. This does not mean that the healthcare services are no longer needed in the area, rather it means that there are alternative provisions that are being invested in to modernise services. Where it can be demonstrated that health facilities are surplus to requirements or will be changed as part of wider NHS estate reorganisation and service transformation programmes, it should be accepted that a facility is neither needed nor viable for its current use, and policies within the Local Plan should support the principle of alternative uses for NHS sites with no requirement for retention of a community facility use on the land. To ensure the principle of alternative uses for NHS land and property is supported, NHSPS request the following wording is included within relevant policies in the Local Plan:\nWhere healthcare facilities are formally declared surplus to the operational healthcare requirements of the NHS or identified as surplus as part of a published estates strategy or service transformation plan, there will be no requirement to retain any part of the site in an alternative community use."]
["Resident","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I have read the local plan (December 2023 For Public Consultation) and would like to provide feedback for consideration. I support many of the stated guiding principles, in particular: protection of endangered and vulnerable species and habitats, protecting greenfield land and sensitive areas, and the Draft Vision of \"ensuring valuable green spaces are preserved\". I am therefore very concerned to hear that the area around the Chargrove Lane and Oak Farm are under consideration again for inclusion as a proposed development site. This goes very much against the above principles and vision and goes against many of the measures listed in the Planning for Climate Change and Nature Recovery. The area, particularly around Oak Farm, is a rich habit for a wide variety of wildlife and to destroy such a habit goes very much against 'protecting important habitats and supporting nature to recover' and such a development would further contribute to the decline in wildlife rather than reversing the decline. The stated aim is that Local Plans should promote the conservation, restoration and enhancement of priority habitats - this does not seem to be the case here. The Chargrove area Greenbelt should remain unchanged at all costs - it is for nature and recreation and removing this, has a serious effect on nature and quality of life for current residents. Surely there are many other suitable Brownfield areas that could be considered first e.g. almost derelict business parks, unused business areas, such as the former Endsleigh Insurance Campus where road infrastructure is already in place and development would have a minimal impact as it's already developed with Office Space."]
["Resident",null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I understand the consultation concludes tomorrow I have tried to log in to the site but without success in order to be kept informed of developments The green belt land should be protected to provide a gap for nature to thrive I understand the government is providing some money to enable development in rural areas to provide affordable houses for those in the countryside and therefore enable village schools and the community to thrive Therefore I suggest development should focus on rural areas rather than tagging onto towns such as Cheltenham which already has a significant traffic problem on the Shurdington Rd which will only increase with further development "]
["Planning agent or developer","L&Q Estates / Savills","","","","No","","No","","","","","","No","","","No","","No","The consultation document is clear on Page 2 that, “The population of the area is growing; it is forecast that an additional 23,000 families will form and make the area their home over the next 20 years. Our area is also an attractive and desirable place for people to move to for lifestyle reasons.” \n\nPage 2 continues, “Housing is becoming increasingly unaffordable for people – both to rent and to buy with challenges and concerns around security of tenure. It is widely acknowledged that the nation is facing a housing crisis. In large part, this is due to a shortage in the number of new homes being built and the right type of housing to rent that is affordable or being able to buy at a price they can afford… In June 2023 the Office for National Statistics reported that the average UK house price was £288,000, well beyond the reach of many.” \n\nThe consultation document provides the current housing need figure for each Council. However, Paragraph 61 of the NPPF (2023) is clear, stating, “To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance. The outcome of the standard method is an advisory starting-point for establishing a housing requirement for the area.” (Emphasis added). \n\nParagraph 61 continues, “There may be exceptional circumstances, including relating to the particular demographic characteristics of an area which justify an alternative approach to assessing housing need; in which case the alternative approach should also reflect current and future demographic trends and market signals.” \n\nParagraph 5.18 of the consultation document is clear that exceptional circumstances, “may be where an area has such significant plans for economic growth that would attract more people to its area, requiring more homes.” Nonetheless, paragraph 5.18 concludes that, “…our current evidence exploring economic growth forecasts and their relationship to the need for new homes have concluded there is currently no justification for amending the needs figures, this evidence is required to be kept under review.” \n\nGiven the amount of economic development already planned for in the Plan area, including the tech industry clustering around GCHQ, Corinthian Park and the Golden Valley Development, our Client agrees the relationship between economic growth and housing need should be carefully monitored. It is possible that a lack of housing availability could frustrate potential economic growth due to future employees not being able to relocate to a commutable distance from their workplace. \n\nThis consultation document relies on the Gloucestershire Economic Needs Assessment’ (GENA) (2020) to determine the likely employment land needs for the Plan period. However, Paragraph 5.32 states that, \n\n“It is acknowledged that the evidence in the GENA was prepared at a time when the implications of Brexit and Covid-19 were not fully known, and it in intended this evidence will be reviewed later in the SLP process. There will also be a need to take account of changing working practices, particularly since Covid-19 with more people working from home or hybrid working and increased online shopping.” \n\nOur Clients are concerned that any plan progressed on the 2020 GENA has under-estimated the demand for employment land given the unusual circumstances of the pandemic. In this eventuality, under-providing employment land would simply exacerbate the national housing and local affordability crises highlighted in the consultation document. \n\nAs such, our view is that the SLP needs to be more ambitious given the very significant demands and pressures the consultation document itself highlights. It would be counterintuitive to recognise the challenges for people 4 being able to afford a home where they live and then simply settle on the housing target offered by the standard method, which is clearly designed to be a starting point, not the end point. \n\nOur view is that a post-pandemic Housing and Economic Need Assessment (HENA) should be commissioned This work should provide the exceptional circumstances needed in national policy to justify a higher local need that will properly tackle the housing crisis in the area.","No","","No","","","","","","","","","","","","","","","","","It is likely inevitable that a combination of the development scenarios will be needed to deliver the level of housing growth that Our Client considers is needed for the Plan period. To bring forward an appropriate range of sites that would allow the full housing needs of the area to be met a combination of “Scenario 2 – Urban Extension” and “Scenario 6 - Sustainable Transport” is needed. This approach would allow development to be delivered close to where the need arises, reducing the likelihood of unnecessary travel into and out of the area. \n\nThe benefits of Scenario 2 – “Urban Extension” are correctly listed as “Pros” in the consultation document. The Pros of Scenario 6 – “Sustainable Transport are also supported by Our Client. The accompanying map used to illustrate this scenario shows a “large-scale development option” on the land between the A40, M5 and the railway. The associated HEELA maps demonstrate Our Clients must be the option being considered in the Scenario. \n\nOur Client considers by the development of land west of Badgeworth Road would provide all of the Pro’s highlighted as a positive in the consultation document. \n\nThe main “Con” listed at Paragraph 6.20 is “Loss of some Green Belt land and potentially reducing the gap between Gloucester, Cheltenham, and Bishop’s Cleeve.” \n\nThe HELAA analysis (December 2023) used to assess the site (BADG015) concludes that the site is “Potentially Developable” for housing and “Not Developable” for employment adding that this is because the site was not promoted for employment uses. The appraisal confirms that the site is relatively unconstrained noting that it is located within the zone of influence for Cotswolds Commons and Beechwoods Special Area of Conservation (SAC). The proposed Country Park would be designed so as to mitigate any identified impacts on the SAC. \n\nThe HELAA analysis notes that the site is available, potentially suitable and potentially achievable for housing. \n\nThe Vision Document contains a detailed site-specific Green Belt Assessment against the five purposes of Green Belt outlined in national policy and demonstrates how the Concept Masterplan has evolved to limit the harm to the Green Belt. \n\nIt is important to note that the site is contained on three sides by infrastructure, the remaining boundary is formed of suburban Cheltenham. Where development is proposed, the site is associated with the suburbs of Cheltenham. \n\nSome reduction in the gap between Cheltenham and Gloucester would be inevitable, but the Concept Masterplan has evolved to provide a new defensible Green Belt boundary, which will retain a gap. The proposals have responded to the site’s inherent sensitivities by limiting build development to the eastern portion of the site, below the ridge that characterises the site. The proposals ensure both that intervisibility and the 5 risk of coalescence is limited, preserving the identity of the different settlements. The development relates to the existing context of The Reddings and the western edge of Cheltenham. \n\nOur view is that for the SLP to deliver for the full housing need, it will need to take a more nuanced approach to sites in the Green Belt and reconsider the manner in which it balances the need to preserve the Green Belt against the need to fully provide the identified housing need as required by the NPPF, Paragraph 60 is clear, “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.” \n\nIt is important to highlight that Scenario 2 is the only one that would deliver the minimum housing number prescribed as a starting point by the Standard Method in full. \n\nWhilst a combination of the Development Scenarios is likely to be required, Scenario 2 should be the cornerstone of the new SLP spatial strategy and appropriate Green Belt release in sustainable locations is needed to deliver sufficient housing. This should be combined with Scenario 6 to ensure that housing is delivered with easy access to sustainable travel options. \n\nThe development of land west of Badgeworth Road is available, achievable and deliverable in the Plan period and should be reassessed as a potential sustainable urban extension that will assist in realising the preferred Development Scenarios.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","I refer to the current local plan consultation and write to formally submit local plan representations on behalf of L&Q Estates, hereafter “Our Client”. I previously wrote to promote this site in response to Call for Sites in 2022. This representation is accompanied by the Vision Document prepared by EDP for that submission as the contents remain relevant to our views on the issues raised in this Regulation 18 consultation. \n\nLand west of Badgeworth Road, Cheltenham \n\nThis site has clear potential to be a strategic urban extension (SUE) to Cheltenham. The proposals provide for up to 350 homes and a local mixed use centre with sustainable transport connectivity. Over 60% of the site is proposed to be allocated as a country park to be enjoyed by new and existing local residents, creating new woodlands and wetland areas that will form an attractive backdrop to the development, deliver a net gain in biodiversity and benefit the local environment. \n\nThe site is located to the west of Badgeworth Road, which leads directly off the Arle Court Roundabout and access to the A40 and M5 at junction 11. Both Cheltenham and Gloucester are accessible via bus or bike, with many services, facilities and employment opportunities such as GCHQ, Corinthian Park and Gloucestershire Airport within easy reach. \n\nThe site measures 30.35 hectares on the western edge of Cheltenham. The site is currently used for grazing and growing arable crops. The fields are bounded by hedgerows and mature hedgerow trees. The Cross Country railway line linking Bristol to Birmingham bounds the site to the south and the M5 lies immediately west. The A40 bounds the site to the north with Junction 11, which connects the two roads to the immediate northeast. \n\nThe site is positioned in close proximity to a selection of local facilities and services, allowing for sustainable modes of travel for regular journeys to and from the site. Two existing bus stops lie within 400m of the centre of the site and are located on The Reddings. These bus stops are served by the 97 / 98 service which provide regular connections to the town centres of Cheltenham and Gloucester. There is the opportunity for the bus service to be diverted through and stop within the site. \n\nCheltenham Railway Station is approximately 20 minutes away, with a connection from the 97 bus to the town. NCN 41 provides access to the station via bike in just 13 minutes. National Cycle Network route 41 passes very near to the north of the site and provides an east to west connection between Cheltenham and Gloucester. \n\nThe West Cheltenham Transport Improvement Scheme focuses on highway infrastructure improvements along the A40, including the Junction 11 slip road and the M5/A40 junction. \n\nThe site does not lie within any nationally designated landscapes such as National Parks or Areas of Outstanding Natural Beauty (AONB). The site falls within Landscape Character Type 18 (LCT 18)-SettledUnwooded- Vale, comprising a broad swathe of lower lying land. Within this area, and across the site and its immediate context, constant traffic noise is audible and the A40 is both visible and appreciable as an elevated feature to the north of the site. \n\nThe Council has previously assessed the land parcel of which this site forms part, to have a “Medium-low” sensitivity in landscape terms. This area is readily associated with and fragmented by infrastructure (M5, railway, and A40 - the latter two of which are elevated by earth embankments), and consists of large, intensively farmed fields. \n\nTo the north of the A40 the number of boundary trees increases, the intensively farmed land is surrounded by smaller fields and treed boundaries, and associations with large urban development are limited due to topography. South of the A40 the elevated landscape offers clearer views towards the town, but is also strongly associated with Chosen Hill and the AONB. \n\nThe topography of the site is characterised by the ridgeline that runs north-west to south-east of two mounds connected by high ground. The low point of the site is in the northeast of the site adjacent to Badgeworth Road, and the high point is in the northeast, adjacent to the roundabout. The site slopes to the east and west from the middle of the site uniformly from the ridge at a relatively shallow gradient of less than 1 in 12. The ridgeline forms what could be seen as a natural boundary to The Reddings and the wider Cheltenham area and would act as a natural noise buffer to the M5. \n\nThe Site does not contain any designated heritage assets and there are none in the immediate surrounding area. The closest such assets are located within Badgeworth over 1.2 kilometres to the south. \n\nThe site is largely within Flood Zone 1, except for a small area in the southeast. \n\nThe 2011 Joint Core Strategy Green Belt Assessment (JCSGBA) concluded that this site formed part of a land parcel that made a significant contribution to the purpose of the Green Belt, namely the restricting of coalescence of Cheltenham and Gloucester. As discussed later in this response, Our view is that this particular site does not make a significant contribution to the Green Belt and the SLP needs to look again at the approach to Green Belt. \n\nThe Concept Masterplan of the Vision Document confirms that over 60% of the site will be green spaces whilst the 350 new homes will include affordable, market and elderly living homes, community uses and a mobility hub at the centre of the proposed development. \n\nThe green infrastructure strategy is a landscape structure that underpins the masterplan, with various functions of the green infrastructure that will combine to deliver both ecology and community value. The scheme would deliver well over the 10% biodiversity net gain required by national policy. An area of at least 4.6ha is set aside for woodland planting, with additional parkland planting and street trees proposed. \n\nThe proposed development would be in a location that is accessible to Cheltenham and the local schools, shops, services and facilities, connected by walking, cycling and bus with easy access to the railway station. The abundant open space and a large variety of landscape functions would echo the distinctive local landscape, with new development will be set within an attractive landscape setting with high quality, net zero carbon and characterful new homes.\n\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nIt is likely inevitable that a combination of the development scenarios will be needed to deliver the level of housing growth that Our Client considers is needed for the Plan period. To bring forward an appropriate range of sites that would allow the full housing needs of the area to be met a combination of “Scenario 2 – Urban Extension” and “Scenario 6 - Sustainable Transport” is needed. This approach would allow development to be delivered close to where the need arises, reducing the likelihood of unnecessary travel into and out of the area. \n\nThe benefits of Scenario 2 – “Urban Extension” are correctly listed as “Pros” in the consultation document. The Pros of Scenario 6 – “Sustainable Transport are also supported by Our Client. The accompanying map used to illustrate this scenario shows a “large-scale development option” on the land between the A40, M5 and the railway. The associated HEELA maps demonstrate Our Clients must be the option being considered in the Scenario. \n\nOur Client considers by the development of land west of Badgeworth Road would provide all of the Pro’s highlighted as a positive in the consultation document. \n\nThe main “Con” listed at Paragraph 6.20 is “Loss of some Green Belt land and potentially reducing the gap between Gloucester, Cheltenham, and Bishop’s Cleeve.” \n\nThe HELAA analysis (December 2023) used to assess the site (BADG015) concludes that the site is “Potentially Developable” for housing and “Not Developable” for employment adding that this is because the site was not promoted for employment uses. The appraisal confirms that the site is relatively unconstrained noting that it is located within the zone of influence for Cotswolds Commons and Beechwoods Special Area of Conservation (SAC). The proposed Country Park would be designed so as to mitigate any identified impacts on the SAC. \n\nThe HELAA analysis notes that the site is available, potentially suitable and potentially achievable for housing. \n\nThe Vision Document contains a detailed site-specific Green Belt Assessment against the five purposes of Green Belt outlined in national policy and demonstrates how the Concept Masterplan has evolved to limit the harm to the Green Belt. \n\nIt is important to note that the site is contained on three sides by infrastructure, the remaining boundary is formed of suburban Cheltenham. Where development is proposed, the site is associated with the suburbs of Cheltenham. \n\nSome reduction in the gap between Cheltenham and Gloucester would be inevitable, but the Concept Masterplan has evolved to provide a new defensible Green Belt boundary, which will retain a gap. The proposals have responded to the site’s inherent sensitivities by limiting build development to the eastern portion of the site, below the ridge that characterises the site. The proposals ensure both that intervisibility and the 5 risk of coalescence is limited, preserving the identity of the different settlements. The development relates to the existing context of The Reddings and the western edge of Cheltenham. \n\nOur view is that for the SLP to deliver for the full housing need, it will need to take a more nuanced approach to sites in the Green Belt and reconsider the manner in which it balances the need to preserve the Green Belt against the need to fully provide the identified housing need as required by the NPPF, Paragraph 60 is clear, “To support the Government’s objective of significantly boosting the supply of homes, it is important that a sufficient amount and variety of land can come forward where it is needed.” \n\nIt is important to highlight that Scenario 2 is the only one that would deliver the minimum housing number prescribed as a starting point by the Standard Method in full. Whilst a combination of the Development Scenarios is likely to be required, Scenario 2 should be the cornerstone of the new SLP spatial strategy and appropriate Green Belt release in sustainable locations is needed to deliver sufficient housing. This should be combined with Scenario 6 to ensure that housing is delivered with easy access to sustainable travel options. \n\nThe development of land west of Badgeworth Road is available, achievable and deliverable in the Plan period and should be reassessed as a potential sustainable urban extension that will assist in realising the preferred Development Scenarios."]
["Planning agent or developer","Land Owner","","","","Yes","1. The overall vision and objectives set out within the document are deemed to be acceptable. These are considered to represent an appropriate set of priorities for the area and will help to address wider objectives relating to the climate and ecological emergencies. \n\n2. However, as part of the draft vision (page 13) it is noted “the focus of new housing will have been on making best possible use of brownfield sites in built up areas and largescale, comprehensively planned new development to ensure valuable green spaces and highest quality farmland are preserved”. \n\n3. We consider this to be an unduly restrictive and unrealistic approach, as there is clearly inadequate brownfield land available, at a large-scale, to meet the substantial need for housing growth over the plan period. The current JCS and local plan policies include for developments outside these designations; it should be noted that development within the confines of the established tightly drawn settlement boundaries has already been maximised which is evident by the developments being approved on edge of settlement sites outside the designated development boundary. \n\n4. The draft vision is too focused on urban concentration of development, and it therefore ought to be re-worded, to better reflect the mixture of housing scenarios incorporated within the plan in due course. This includes adequate and proportionate disbursement of housing at the Service Villages and other rural locations, which have a reasonable degree of sustainability and access to facilities.","No","","","","","","No","","","No","","No","","No","","No","","","","","","","","","","","","","","","","","7. Our comments on the range of options put forward are as follows: \n\n• Urban Concentration – this would be an intense option and would result in high rise developments that would be completely uncharacteristic of Gloucestershire. It is our viewpoint this option would not contribute towards providing the level of housing required across the county and would provide for a limited range of development styles and tenures. It would also be highly likely to result in delays with development coming forward, as the Authorities would be reliant on these sites coming forward. The inevitable delays in delivery would leave the Councils incredibly vulnerable. For these reasons, this option ought to be discounted, as it is high risk, it would be likely to result in poor and overly dense forms of development, and would be prone to significant delays. \n\n• Urban Extensions (with and without Green Belt) – this option would provide for a more varied range of sites which are in sustainable locations on the edge of the built-up urban areas. The removal of land from Green Belt is not resisted and could provide for sites to be comprehensively allocated and planned for sustainable development. However, urban extensions will not in themselves bring forward development at the required rate. For the same reasons as the ‘urban concentration’ option above, delivery would be subject to inevitable delays and would provide for high densities, which would not necessarily been within keeping with the character of settlements. \n\n• New Strategic settlements – the creation of new strategic settlements may assist in contributing towards the housing need and is worthy of further consideration. However, this would need to be done alongside the allocation of other small to medium scale sites at Service Villages and other rural settlements, that are readily available for development and can come forward at a speedier rate. Large scale strategic settlements inevitably take long periods of time before construction is commenced on site; therefore, although they provide an area for large scale planned growth, the actual deliverability of new settlement sites is very slow. \n\n• Rural Dispersal – It is considered that rural dispersal should be incorporated as part of the new development plan and we consider this to be the most suitable option. Rural dispersal is necessary in the vitality of communities, affordability, retaining newer generations in the area as well as positively and significantly contributing to housing supply. Small to medium scale sites which can be provided through rural dispersal will be built out under a quicker 4 Zesta Planning Ltd The Site, Chosen View Road Cheltenham, GL51 9LT www.zestaplanning.co.uk t: 01242 335 567 timescale than larger urban extensions and strategic allocations such as new settlements. They therefore play an essential role in maintining a rolling 5 year supply \n\n• Sustainable Development – this would be a sustainable option presented with a range of pros and cons. The inclusion of this with other strategic scenarios would result in sustainable allocations. It would provide development close to existing settlements in which services and facilities could be easily reached.\n\nConcluding Points on the Consultation Strategy\n\n8. We consider it essential that rural dispersal form part of any development strategy. Large \nscale strategic settlements are positive and do significantly contribute towards plan period \nhousing supply, however given the long timescales associated with the planning and \nimplementation of these and significant infrastructure requirements, urban expansion and \nrural dispersal would also be needed to help maintain a rolling housing supply and \ndeliverability of housing at a steady rate throughout the plan period. ","","","5. The spatial options provided as part of the consultation are a positive format in deciding how to develop the strategy for the future. It is considered the current settlement hierarchy should be incorporated into the new system, however there are an array of other settlements such as Ashleworth and Twigworth which are of ‘Service Village’ level but not included as a such designation under the current development plan. This ought to be revisited, as we consider that a great number of Service Villages will need to be designated in order to meet the needs over the plan period. \n\n6. Furthermore, the existing Service Villages should be strengthened through policy to allow them to positively provide additional much needed housing in these areas. We consider that none of the scenarios presented under the consultation would, on their own, deliver sustainable development, a mixture of these would be required to produce a final strategy.",""]
["Planning agent or developer","Nexus Planning","","N/A","N/A","No","At this stage of the consultation exercise the Vision and Strategic Objectives that support realisation of the Vision should be treated as work in progress, to be refined and developed as the chosen development strategy is clarified. As a starting point for honing a spatially specific and measurable touchstone for the Plan the Vision and Objectives as currently expressed offer adequate components for finalising this document-defining section of the Plan. The plan-making authorities must ensure that they re-visit and iterate the Vision and Objectives (V&O) as the Plan develops and avoid the temptation to settle for a generic and otiose set of criteria that could be applied to any location. To be effective and meaningful the V&O should be specific to the particular challenges that are facing the districts and be more locationally tailored and distinctive, such that it would be clear to anyone reading the Vision separate from the remainder of the document that it is particular to Cheltenham, Gloucester, and Tewkesbury. \n\nThe policies of the SLP should be clearly informed by the Vision and should manifest themselves as the conduit via which the outcomes sought by the Vision will be achieved. Therefore, the Vision should be completely clear that if the policies are successfully applied, the future state of the district described by the Vision is the natural conclusion. Consequently, the key development proposals that will in due course be subject to policy provisions within the SLP should form part of the described outcomes, expressed in specific terms such that there can be no mistake that this Vision relates to Cheltenham, Gloucester and Tewkesbury, the realisation of which is the product of an effective Local Plan. \n\nAs drafted currently (understandably), the V&O are too generic and could arguably apply to anywhere. At the moment because of the stage the Plan has reached the V&O are not capable of being measured effectively or meaningfully. Further work is required to ensure that the V&O will act as clear signposts to the policy framework that will underpin them. \n\nThe Vision should be framed on the basis that the SLP is firstly a strategic land use document, with a clear spatial remit at its heart. This should inform everything that the plan seeks to manage and influence. \n\nThe spatial ambition of the plan, and all of the attendant outcomes that flow therefrom, should be the fundamental building block for all of the policies that the emerging Local Plan contains. As the spatial strategy is further defined through the plan preparation process, which remains at a relatively early stage, the Vision should be made more locationally specific and clear in the spatial outcomes that it seeks to achieve. \n\nIn support of this contention, the consultation document currently refers, by way of illustrating what a successful outcome may look like, to the Golden Valley development allocated within the Joint Core Strategy (JCS) 2017. This is used to show what the effective implementation of a Plan can help to achieve: \n\n“Plan-making is central to delivering change. By way of example, this can be seen through the progress of the Golden Valley Development. Starting from a strategic allocation in the Gloucester, Cheltenham, and Tewkesbury Joint Core Strategy in 2017, this scheme is now progressing on its planning journey to create a vibrant, pioneering Garden Community integrating hi-tech business, residential and leisure uses, and creating a destination of global significance. By understanding our economy and facilitating the jobs and skills for local people, we can build a resilient and sustainable long-term strategy for growth.” \n\nThis is precisely the type of locationally specific aspiration that should be incorporated into the Vision to demonstrate what an effective SLP could achieve. While at this point there will be a lack of clarity regarding most of the core components of the Plan this should not result in the V&O being drafted and set to one side while the policies of the Plan are formulated. It should be an ongoing iterative process that takes place, with the V&O shaped and made more specific as the more detailed aspects of the Plan comprising areas such as the housing and employment requirements and spatial strategy are defined. \n\nCommenting specifically on the text as drafted the Vision should avoid the use of vague terms such as ‘green-growth’ unless these are defined, and terms such as ‘the highest quality of life for all’, which are essentially meaningless and will rely on matters far beyond the remit of land use planning. The temptation to incorporate far-reaching, nebulous aspirations should be resisted in favour of concentration on matters that the implementation of a land use planning framework can realistically achieve. The Vision should therefore be founded on a set of outcomes that can be realised, the achievement of which will create the necessary conditions to support/encourage/facilitate outcomes such as increased inward investment. Successful implementation of policy cannot guarantee outcomes, it can create the conditions that support the achievement of desired outcomes. It is important that this distinction is made. \n\nThe V&O should also be drafted to address directly the key challenges identified at the start of the consultation document and be ordered in a way that is consistent with the three objectives underlying the realisation of sustainable development: Economic, Social, and Environmental. It is important to maintain the emphasis articulated in the NPPF, given that a strong, competitive, and resilient economy will create the necessary conditions to support strong, healthy communities, which in turn will help to foster and support a valued and enhanced natural environment. The interdependency of the three components of sustainable development is acknowledged but at the heart of the planning system is the obligation to plan sustainably for development, this necessarily should focus on the delivery of new homes, employment, and physical and social infrastructure in a manner that is sustainable. Meeting the housing needs of the whole of the population in ways that are accessible and affordable and providing the means via which the population can be sustained through the creation of employment opportunities that will retain and foster a vibrant workforce should be at the heart of the V&O. \n\nThe objectives should be ordered to properly reflect the points made above and be rationalised to ensure that they are focussed and clear. There are currently 34 objectives, which are both too generic and wide ranging, while also being concerned with inappropriate levels of detail. For example: \n• Delivering new developments that are supported by the necessary social and community infrastructure, including schools, open space, playing fields, community facilities and green and blue infrastructure and promote community cohesion. \n• Ensuring a network of city and town centres that meet the needs of communities, including supporting cultural uses and events, and that are able to respond and evolve as the role and function of centres changes. \n\nThese are spatial policies that are locationally specific in their subject nature yet provide no insight as to how they will be applied to the local context. They could be sourced from any document in the country. \n\nThere is inappropriate focus within the objectives on matters of detail that should not be a core objective of the Plan: there is no commentary on how the core settlements of Gloucester, Cheltenham, and Tewkesbury will develop and change, yet there is a requirement to ensure that homes have covered external space to dry washing. \n\n• Ensure people can make carbon friendly choices at home by providing easy to use cycle storage, covered space to dry washing outside, space to grow food and compost. \n\nThere is currently a confusion of purpose that will need to be addressed as the Plan is further developed. Further to the above, and reflecting the overall approach to the spatial strategy, the strategic priorities should make clear that Gloucester city and Cheltenham and Tewkesbury towns will remain the focus for development of a sustainable nature and the articulation of the spatial strategy of the SLP. The emerging SLP should be more spatially focussed and locationally specific, with particular outcomes sought for each key location. The Vision could be made more succinct and focussed but retain a specific and measurable set of outcomes against which the effectiveness of the Plan can be judged.","No","","Lands Improvement Holdings recognise fully the importance of delivering development that is truly sustainable and appreciate the role that the development industry must play in this respect. It will be important to ensure that the policies and ambitions that are set out within the Plan are in step with the national agenda and can be fully justified through the examination process. This will necessarily require a full and thorough assessment of the potential impacts on delivery of the Local Plan strategy, the viability of which will be affected by any application of locally specific standards. The recent Written Ministerial Statement (referred to further below) advises that considerations relating to building fabric and matters that should be addressed more appropriately via the Building Regulations should not be incorporated into planning policies without a robust justification. The remit of planning policies in this regard should be considered carefully to ensure that there is real purpose, effectiveness and focus to planning policies that seek to introduce measures that can help to tackle climate change. Ensuring that such policies are properly concerned with land use planning considerations will be vital to inspire confidence. \n\nThe NPPF makes clear that Local Plans should take a proactive approach to mitigating and adapting to climate change, and should address implications for habitat, biodiversity, and landscape matters through the formulation of policies that recognise that the principal function of a development plan is to plan for development. The development plan has a vital and effective role to play in addressing climate change and the delivery of carbon neutral development, but this is often most appropriately addressed via the spatial expression of planning policies, i.e. where development is located relative to jobs, services, facilities and other travel demand generators, for instance. \n\nThe development plan should make provision to accommodate levels of growth that meet the ‘societal’ (social and economic) aspects of sustainable development in a manner consistent with environmental objectives and the move towards a carbon neutral economy. The purpose of the development plan in this respect is therefore to determine a spatial strategy that is consistent with the objective of reducing carbon emissions, but which is not defined solely in these terms. With this principle to the fore, the SLP should encourage development in locations that support and enable sustainable lifestyles to be realised. All other considerations are secondary to this defining principle because the main function of the Plan is to propose a spatial strategy that supports this outcome. \n\nTherefore, one of the most effective ways for the planning system to address the challenges of climate change is through adherence to the objectives set out at paragraphs 108 and 109 of the Framework, which advocate early consideration of the transport implications of spatial planning, because carbon emissions associated with travel are a significant cause of climate change. \n\nThe Department for Transport’s ‘Transport and Environment Statistics’ states that transport is the largest emitting sector of greenhouse gas emissions and was responsible for 24% of the UK’s total emissions in 2020. Transport clearly has a significantly greater impact on climate change locally. Ensuring that housing and employment land is located in places where motorised travel demands can be minimised and opportunities for public transport usage and active travel maximised should be the principal policy consideration in responding positively to the climate emergency that the Council has declared. In pursuit of such outcomes the SLP should ensure that sites that are able to respond positively to this agenda should be allocated for development and made subject to provisions that facilitate sustainable travel behaviours. Such considerations should be to the fore of the spatial strategy. \n\nIt is important also to acknowledge and make clear to all participants that the Local Plan has a defined remit, which is planning for growth. The planning system cannot directly reduce the consumption of fossil fuels per se, or limit greenhouse gas emissions through specific policy measures, this falls to other legislative regimes. However, it can support development that helps to reduce the demand for consumption of fossil fuels through the promulgation of a spatial development strategy that plans for the right amount of growth in the right places, with this in mind. \n\nSpatial planning is the most effective lever that can be used to influence travel demand, which is one of the key contributing sectors to carbon emissions. A soundly based spatial development strategy, in terms of quantum of development planned for and its distribution, is a key requirement of a development plan that wishes to promote a lower carbon future. Associated measures should be incorporated into the strategy comprising the location of homes and jobs in close proximity, encouraging active travel, and convenient access to public transport. These are the key objectives that the SLP should aim to pursue. \n\nGrowth in this manner is in line with draft strategic objectives 2 and 4 of ‘meeting the challenges of climate change’ and draft strategic objectives 1-4 of ‘prioritising sustainable transport and active travel’. Development in sustainable locations minimises the need to travel by creating accessible and walkable neighbourhoods. Genuine sustainable and active travel choices can be provided, integrating new development into existing and planned networks, and enhancing these wherever possible. \n\nIn addressing the role of a Local Plan in this respect, the consultation document includes a table at paragraph 4.15 that identifies categories in respect of which ‘policy actions’ may be considered. Having regard to comments outlined above and the need to ensure a focussed and effective response it is contended that the following ‘topics’ have little direct relevance to planning policies that aim to tackle climate change, or should more appropriately be dealt with via the Building Regulations/FHS and should therefore be removed from further consideration as part of this subject: \n\n• Built Environment: Energy efficient homes, materials, heating and cooling, insulation (BR) \n• Natural Environment: Beautiful places (relevance?), SuDS (included twice) \n• Movement: Low emission vehicles (relevance – unless specifically infrastructure-related) \n• Renewable Energy: ASHP, GSHP, phasing out gas (BR/FHS)","There is limited justification for transposing requirements relating to technical building standards into planning policies where these are consistent and merely reflect provisions that will otherwise be required to be achieved through compliance with the Building Regulations. \n\nThe Written Ministerial Statement dated 13 December 2023 sets out situations where emerging local plans seek to impose standards beyond national regulations (our emphasis): \n\n“The improvement in standards already in force, alongside the ones which are due in 2025, demonstrates the Government’s commitment to ensuring new properties have a much lower impact on the environment in the future. In this context, the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale that ensures: \n\n• That development remains viable, and the impact on housing supply and affordability is considered in accordance with the National Planning Policy Framework. \n• The additional requirement is expressed as a percentage uplift of a dwelling’s Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP). \n\nWhere plan policies go beyond current or planned building regulations, those polices should be applied flexibly to decisions on planning applications and appeals where the applicant can demonstrate that meeting the higher standards is not technically feasible, in relation to the availability of appropriate local energy infrastructure (for example adequate existing and planned grid connections) and access to adequate supply chains.”","There is limited justification for transposing requirements relating to technical building standards into planning policies where these are consistent and merely reflect provisions that will otherwise be required to be achieved through compliance with the Building Regulations. \n\nThe Written Ministerial Statement dated 13 December 2023 sets out situations where emerging local plans seek to impose standards beyond national regulations (our emphasis): \n\n“The improvement in standards already in force, alongside the ones which are due in 2025, demonstrates the Government’s commitment to ensuring new properties have a much lower impact on the environment in the future. In this context, the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. The proliferation of multiple, local standards by local authority area can add further costs to building new homes by adding complexity and undermining economies of scale. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale that ensures: \n\n• That development remains viable, and the impact on housing supply and affordability is considered in accordance with the National Planning Policy Framework. \n• The additional requirement is expressed as a percentage uplift of a dwelling’s Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP). \n\nWhere plan policies go beyond current or planned building regulations, those polices should be applied flexibly to decisions on planning applications and appeals where the applicant can demonstrate that meeting the higher standards is not technically feasible, in relation to the availability of appropriate local energy infrastructure (for example adequate existing and planned grid connections) and access to adequate supply chains.”","","No","","It is essential to consider the key services and facilities that should be easily accessible, ideally via public transport or active travel options, from new developments. This provides social and environmental benefits, contributing to overall well-being and quality of life in a community, while reducing the need for commuting. \n\n• Sustainable transport options: providing connections to efficient public transport networks, including buses and trains, is crucial. Encouraging active travel modes such as walking and cycling further enhances accessibility and reduces the reliance on travel by private car. To the west of Cheltenham adjacent to the A40 Golden Valley roundabout the Arle Court Park and Ride improvements will shortly be completed, providing a strategically located 1,000 space sustainable transport hub with frequent (5-6 services per hour) bus links into the centre of Cheltenham, with journey times of approximately 18 minutes. \n• Employment: Access to employment areas via sustainable travel modes should be a key determinant of any spatial strategy. The SLP should consider opportunities for co-locating residential growth with exiting and expanding employment areas. The consultation document highlights the Golden Valley allocation within the JCS as an example of successful placemaking occurring through the integration of business, residential, and leisure uses. This is a good example of sustainable synergies achieved through proximity, which the spatial strategy should aim to build upon. However, there will also be examples of locations that offer sustainable growth options through ready access to key employment locations via sustainable and active travel modes. \n• Education: having nearby primary and secondary schools, as well as nurseries, benefits the local community by allowing students to walk to school, while also minimising parents’ commuting distances. \n• Community services: village halls, community centres and libraries offer a gathering space for events, meetings, and social activities. \n• Healthcare: ensuring there are sufficient GP surgeries, pharmacies and dentists means that residents have the necessary medical care nearby and existing facilities are not oversubscribed. \n• Recreation and leisure: playgrounds offer safe spaces for children to play, while sports clubs and pitches provides facilities for various sports and physical activities, promoting a healthy lifestyle. \n• Retail: grocery stores and supermarkets, clothing shops and other retail outlets allow people to buy the daily necessities. \n\nSustainable development aims to balance growth with environmental, social, and economic considerations. It involves directing development toward areas that already offer these key services and facilities or have the potential to provide them. By strategically locating residential and employment developments near existing amenities, the need to commute is reduced, which results in reduced greenhouse gas emissions. It also helps to build strong communities, as people spend more time in their local areas. This helps to meet the draft strategic objective 2 of ‘meeting the challenges of climate change’, draft strategic objective 1 of ‘prioritising sustainable transport and active travel’ and draft strategic objective 1 of ‘promoting healthy and resilient communities’. \n\nThe land controlled by LIH at Bamfurlong to the west of Cheltenham is in a sustainable location, with strong sustainable and active travel connections. \n\nThe Arle Court Park and Ride is located less than 500m from the Site. The land is in close proximity to the allocated Golden Valley employment area (JCS) and Cyber Central (comprising over 90,000 sqm of new employment space) and is situated adjacent to the enhanced active travel connections recently provided under the ‘B4063 Cheltenham Road East/Gloucester Road Major Projects Cycleway Improvements Scheme Phase 3’. The active travel route located alongside the B4063 provides dedicated walking and cycling connections to the Bamfurlong Industrial Park, Gloucestershire Airport, and the Meteor Business Park, all of which are located a short distance to the west. This provides high quality, sustainable travel options that will encourage more journeys to be made on foot and by wheeled modes. \n\nA frequent bus service (Number 94) also runs along the B4063 between Gloucester and Cheltenham (past the site). The 94 service begins at 05.10 hrs, offering 5 services until to 07.20, and then operating at 15-minute frequency throughout the day until 17.50, with a 20–30-minute frequency service thereafter until 23.10hrs. Journey times from the centre of Gloucester to the centre of Cheltenham vary from 30 minutes at off-peak times to 47 minutes during peak hour travel. \n\nAn ASDA superstore lies approximately 1 mile from the Site, close to which are a range of other facilities and services located around Hatherley Lane comprising Cotswold BMW, B&Q, Home Bargains, Nuffield Health Hospital, Travelodge Cheltenham, Real Life Fitness Gym, ASDA PFS, Cheltenham Film Studios, and a KFC takeaway. There are also existing schools within walking distance of the Site and a new primary school is planned to serve the Cyber Central scheme. The quality and proximity of the active travel links that are adjacent to the site and the range of services and facilities that are in easy walking and cycling distance, allied to the high frequency and rapid public transport service connecting the sit to the centres of Cheltenham and Gloucester, combine to demonstrate that the land controlled by LIH at Bamfurlong is extremely well-located to encourage the adoption of sustainable behaviours","No","Cheltenham, Gloucester, and Tewkesbury have declared a climate emergency. A move towards decarbonisation (draft strategic objectives 1 and 5 of ‘meeting the challenges of climate change’) will help to combat this. By allocating sites for renewable energy generation, the Councils can not only provide a secure, renewable energy source but also potentially encourage investment and create new jobs. The SLP should consider all options to accommodate renewable energy generation and should tailor these to locations where the maximum generating benefit can be realised. Alongside technologies that harness wind and solar power, consideration could also be given to energy from waste facilities at a smaller generating scale where potential locational synergies may exist. \n\nThe Hayden Wastewater Treatment Works lies in close proximity to the Golden Valley allocation, while the JCS identifies the land surrounding the works, and the treatment works itself, as a safeguarded area with future development potential in support of Policy A7, there is no currently published evidence that supports the likelihood that the facility will be relocated (see Section 7 – Scenario 2 below). If the treatment plant remains in situ there may be potential to explore a future energy from waste scheme as part of an odour amelioration strategy that could be implemented. Nexus Planning is aware from previous association with the operators of the site that anaerobic digestion technologies could potentially be applied to the existing treatment infrastructure to generate electricity from the wastewater treatment process, also offering the potential for cogeneration of combined heat and power from this process. \n\nTherefore, it is suggested that the Councils should proactively consider renewable energy options and strategically allocate sites for sustainable energy generation and storage, considering the Hayden Sewage Treatment Works as a potential option.","Yes","The SLP notes that the planning system has an important role in addressing housing pressures and particularly the affordability of housing. In respect of the latter the document highlights that housing is becoming increasingly unaffordable to much of the population in the SLP area and that the country as a whole is facing significant housing challenges. The document also notes correctly that the Government provides a formula (the Standard Methodology – SM) which is to be used to establish the starting point for determining how much new housing should be planned for. Paragraph 60 of the Framework outlines the Government’s objective of significantly boosting the supply of homes and ensuring that a sufficient amount and variety of land can come forward where it is needed. \n\nThe approach to determining the minimum number of homes that are needed is outlined at paragraph 61 of the Framework, which states: \n\n“To determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance. The outcome of the standard method is an advisory starting-point for establishing a housing requirement for the area (see paragraph 67 below). There may be exceptional circumstances, including relating to the particular demographic characteristics of an area25 which justify an alternative approach to assessing housing need; in which case the alternative approach should also reflect current and future demographic trends and market signals. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for”. \n\nThe Document notes that LHN for the Cheltenham, Gloucester, and Tewkesbury area, calculated using the SM, is 1,785 dwellings per year. Over the currently proposed 20-year period, this equates to 35,700 dwellings (table within paragraph 5.16). \n\nParagraph 61 of the Framework (above) allows Councils to demonstrate that ‘exceptional circumstances’ exist to justify an alternative approach to assessing housing need, but it is important to stress that the ‘exceptional circumstances’ threshold would require the Council to demonstrate that there is something unusual or atypical affecting the plan area to justify departing from use of the SM. The Framework now provides an illustration of such a demographically exceptional circumstance at footnote 25: (25) Such particular demographic characteristics could, for example, include areas that are islands with no land bridge that have a significant proportion of elderly residents. \n\nThe example is clearly of an exceptional nature and in accordance with the term, would not be expected to arise under most circumstances. Furthermore, the PPG states that: \n\n“Where an alternative approach results in a lower housing need figure than that identified using the standard method, the strategic policy-making authority will need to demonstrate, using robust evidence, that the figure is based on realistic assumptions of demographic growth and that there are exceptional local circumstances that justify deviating from the standard method. This will be tested at examination.\" \n\nThe SLP plan-making area is not subject to any such exceptionality that would justify a figure that is any lower than the starting point generated by the SM. Moreover, because the consultation document explicitly acknowledges the very significant housing pressures that are manifest across the area, and the very particular challenges relating to affordability it would be counter- intuitive to pursue a strategy that sought to suppress housing supply. \n\nIn this context it is also important to recognise that adopting the minimum local housing need figure generated by the SM as a proxy for a housing requirement will not directly address the pressures on the housing market that exist locally. The National Practice Guidance refers to the affordability adjustment applied to the SM at paragraph 6 (2a-006-20190220) noting: \n\nThe affordability adjustment is applied in order to ensure that the standard method for assessing local housing need responds to price signals and is consistent with the policy objective of significantly boosting the supply of homes. The specific adjustment in this guidance is set at a level to ensure that minimum annual housing need starts to address the affordability of homes. \n\nThe emphasis applied makes clear that a housing requirement based on the SM generated LHN figure will only ‘start’ to address affordability; it will not deal with such challenges in ways that move meaningfully towards solving them. In an area where affordability is highlighted as a particular concern there should be a policy imperative to actively tackle this market failure by adopting a housing strategy that aims to genuinely tackle affordability through positive supply-side interventions. Put simply, the LHN figure should be increased in recognition of a policy objective to pro-actively address poor and declining affordability across the plan-area. \n\nPlanning only for the minimum LHN figure, or indeed any figure lower than this, would ignore one of the main challenges faced across the plan area, which in turn would have concomitant adverse effects on the quality of life of the population, economic stability, and the economic growth potential of the area. House prices would continue to rise, constraining accessibility and perpetuating the acknowledged drift away from the area by younger sections of the population, contributing to an increasingly older/less economically active demographic profile. Far from preserving the character of the plan-area, the suppression of housing supply, or an ambition that aims only to respond to a minimum threshold of provision, would make the area less dynamic and responsive to the changing economy and a less attractive place in which to live and work. \n\nThe SLP should use the LHN figure generated by application of the standard methodology as the starting baseline for setting the housing requirement, and in doing so acknowledge that this figure will begin to respond to declining affordability in the area, but will not arrest it. Reference to the Median Affordability Ratios for the three authorities (averaged) shows that over the last ten years (2012-2022) the multiplier between median house price and median earnings has risen from 6.59 to 8.44, illustrating that housing is becoming generally less affordable within the plan-area. The evidence in this regard supporting the consultation provided by Opinion Research Services is out of date and will need to be reviewed in due course, but the operating principle at this stage should be an aspiration to plan proactively to achieve a housing requirement figure within the SLP that exceeds the minimum LHN figure as a means of positively addressing the declining affordability of housing across the plan area.","No","Exceptional local factors can justify a housing requirement above the SM. The policy imperative to address declining affordability is referenced in response to Question 12 and applies equally to this question. The requirement for housing set by the SLP should treat the LHN figure generated by the SM as a baseline minimum to be exceeded in recognition of the affordability challenges acknowledged at the start of this document, and other factors that will support adoption of a higher/more bespoke figure. Factors such as a significant trend towards an ageing population may mean that any ‘simple’ adoption of a figure informed only by use of the SM/LHN underestimates the need for specialist types of housing. The LHNA forecasts a significant increase in the population aged 75+ over the 20-year period (from 68,131 to 120,363 people) indicating (as referenced at the start of the consultation document) a likely requirement for specialist housing to respond to this noted demographic factor. Furthermore, once this evidence is brought up to date the trend indications are that this factor will have become more pronounced, supporting a more purposeful policy response. \n\nPositive economic development strategies, as typified by the proposals at Golden Valley, designed to create new business sectors and specialisms will justify a more positive approach to housing growth to create the conditions to support growth. This will inevitably lead to increased demand for housing and further justifies the need to exceed the baseline LHN/SM calculation, to support the objective of accommodating growth in a sustainable manner. \n\nA General Election is scheduled in 2024; polling currently suggests that there will be a new Government that will most likely be a Labour administration. Labour has stated repeatedly that if elected it will encourage positive planning with an emphasis placed on driving growth as the most effective path towards economic recovery. Labour is pledging to deliver 1.5 million new homes during a first term (300,000 pa). Such a commitment cannot be achieved if the minimum SM generated LHN figures are followed. \n\nWhen the SM was first introduced, and subsequently when scheduled for reform during 2020 (September 2020), it was generally accepted by Government that the SM generated outputs for the country would not achieve the 300,000 new homes pa target. An incoming Labour administration would, it is assumed, act swiftly to ensure that house building requirements set by planning authorities in development plans will achieve the manifesto pledge. Accordingly, the SLP should be planning to exceed the minimum quoted in the table at paragraph 5.16 of the consultation document.","Yes","As noted in responses above, the ORS Gloucestershire Local Housing Needs Assessment 2019 (Final Report and Summary September 2020) is now out of date and should be refreshed as part of the evidence gathering and plan preparation exercise. The data contained within should not be relied upon to inform the emerging plan. In absence of up to date evidence it is not possible to draw firm conclusions at this stage. However, as indicated above and reflected in the consultation document there is a significant need for affordable housing, and a recognised ageing demographic profile that is likely to demand tailored policy responses targeting these specific sectors, within an overall strategy that seeks to drive housing delivery across the plan area.","","N/A","N/A","The adopted JCS includes a commitment, through the allocation of site A7 (West Cheltenham), to create a globally significant cyber security centre (CSC), building upon the presence of GCHQ at Cheltenham. Cheltenham Borough Council has committed to this vision by helping to create the policy framework; by purchasing land; and by further investing in the delivery of new homes, creating the right environment to further support economic growth and inward investment. The Golden Valley Development Information Memorandum (May 2020), and the subsequent SPD, each outline the depth of the commitment. It is especially important to high value/high-tech industry and services, that integrated living environments are created by co-locating homes and business spaces in attractive integrated communities with ready and convenient access to social infrastructure and sustainable travel choices. The land at Bamfurlong would help to ensure that there is sufficient land available to support sustainable and comprehensive masterplanning of future complementary development phases. Such placemaking will help to attract the younger, technically able, economically active population of highly skilled workers that will be required to establish and sustain the hi-tech clustering that that Golden Valley project aspires to achieve. \n\nImportant in this respect will be a sufficient quantum and range of housing types and tenures to meet the specific needs of this sector, which will likely include general needs housing, affordable housing of all types, and private rented sector provision. There will be a need to ensure that the housing market is well served and that the range of opportunities offered is accessible and highly sustainable. This is likely to be important in attracting and retaining the skills base that will be necessary to secure status as a globally significant CSC. The JCS allocation creates the kernel around which to build, and it will be important to ensure that the SLP cements a policy framework that secures the growth that is already committed and builds upon this to ensure that West Cheltenham attains the international recognition which it aspires to achieve as a CSC.","The Golden Valley Supplementary Planning Document (‘SPD’) sets out a vision for the development of a Garden Community that supports an internationally recognised Cyber Security Centre that is to be created at Cyber Central UK, focussed on GCHQ, to the west of Cheltenham. The Golden Valley site is allocated within the JCS (Site A7) and comprises approximately 132 hectares for mixed-use development, including commercial, residential and community uses. This will create an integrated and connected extension to West Cheltenham. \n\nThe SLP should build upon this allocation, supporting additional development that will contribute to making this an area of sustainable growth. It is crucial that sufficient housing is delivered alongside the employment development, to ensure that there is sufficient accommodation for the working population available nearby, that is conveniently located, and which can reduce the need for people to commute long distances. This will help to meet employment needs, while ensuring sustainable growth, creating an attractive environment for future investment. \n\nThe Golden Valley Information Memorandum (May 2020) describes the long-term vision for the western edge of Cheltenham, which is well-founded and ambitious and represents the scale of project for which a long-term vision and plan horizon will be required (see response to Question 1). Aside from any greater ambition within the SLP, this objective alone would support extension of the plan period to 2050 to establish the necessary conditions for long-term investment and confidence. The Memorandum describes that scale of the opportunity, which is not repeated herein . However, it is important to note, in the context of the plan period that should be considered and the opportunities that will exist in the period to 2050, the scale of the ambition and the means by which this could be achieved. Pages 19 and 20 of the Memorandum explain the Vision and the key components of it: \n\nCheltenham Borough Council has made a significant commitment to the delivery of high-quality housing. £100M has been made available for private housing initiatives. The potential also exists for this commitment to be matched by funds of up to £80M from the Housing Revenue Account (HRA) for the delivery of affordable and social housing. These funds could be used to support the delivery of the Golden Valley Development, forming part of the wider partnering arrangements. In making this commitment the Council is looking to create strong balanced and resilient communities that support and connect with the established parts of Cheltenham adjacent to the site. We are looking to achieve the highest standards of design, sustainability – looking at emerging technologies in energy generation and carbon reduction – whilst also looking at how these homes are accessible and affordable particularly to younger people who will be looking to work in the area. Our intention is that many of these homes will be an attractor to talent, instead of being something that is beyond their reach (May 2020) \n\nWhile this document was published around four years ago the message it contains remains live and relevant to this process. Critical for the current plan-making exercise is the graphical representation of the opportunity for ‘Future Growth’ depicted on page 20. This plan shows the A7 allocation and the adjacent safeguarded land, including the Hayden Wastewater Treatment Works (HWwTW), as the site of the Garden Community. A wider area incorporating land extending up to the A4019 to the north, west to the M5, and south to the line of the A40 is shaded as having mid-term growth potential, to be examined through the review of the JCS. \n\nThe area is characterised as: \n\nBeing a highly sustainable option offering expansion for employment and housing growth close to key transport nodes and cyber central. This area could extend to between 300 to 400ha and would represent a natural progression for the wider Golden Valley. \n\nThe document also notes, in commenting on the longer-term potential, that as part of the 2050 Vision for Gloucestershire the area between Gloucester and Cheltenham is one of the few sustainable options for longer term growth in the area. The A40/M5 corridor is highlighted as the ideal location for growth that could form part of the wider Golden Valley project. \n\nThe land interests held by LIH fall within the mid-term growth potential area in close proximity to the new Garden Community and CSC, adjacent to the A40/M5 corridor and the potential rapid mass transit solutions that could be realised in this broad location. The land is available to support the realisation of the long-term growth ambitions for West Cheltenham generally and represents a highly sustainable and deliverable growth option. There are additional compelling reasons that support the identification of this land as a core component of the future growth plans for West Cheltenham that are expanded upon under the response to Development Scenario 2.","N/A","Draft strategic objective 1 of ‘ensuring strong and vibrant city and town centres’ aims to establish a network of centres that cater to the needs of local communities and can dynamically respond to changing roles and functions. As the role of centres evolves, it is crucial for these spaces to adapt to retain their vitality and viability. Draft strategic objective 2 aims to create an active city and town centre community by offering a diverse range of uses, including new housing. An influx of residents could enhance the vitality and vibrancy of these areas. However, a strategy that focuses on converting commercial premises and town centre uses to residential use at scale may also have a potentially adverse impact on the commercial attractiveness of town centres and should be avoided. It will be important to ensure that any strategy is carefully balanced. \n\nIn Development Scenario 1: Urban Concentration, directing growth towards centres would encourage more people to live there. However, this approach may inadvertently increase pressure on existing retail and employment spaces, causing their loss, and leading to diminution of the functions and uses that make centres dynamic and attractive places. Development Scenario 2: Urban Extensions could help to support town and city centres if the sites that are allocated have dedicated, convenient, and safe active travel connections into the centres and are well-served by frequent public transport services. Directing growth to the principal centres and ensuring that residents can easily access the range of services and facilities that exist via sustainable travel modes will help to drive footfall and support the vitality and viability of urban centres.","N/A","N/A","A housing strategy that includes the provision of a new settlement as a core component of housing supply should be founded only upon a multi-focussed growth strategy because new settlements are characterised by very long lead times and are exceedingly reliant on the provision of significant amounts of up-front infrastructure. This is usually expensive and necessarily precedes the provision of housing, meaning that supply is often constrained in the early years of a plan-period when new settlements form a core component of the delivery strategy. The requirement for early delivery of infrastructure to ‘pump-prime’ such sites often means that the viability of new settlement provision is challenging. Any commitment to the provision of a new settlement as part of a development plan housing strategy should recognise this and commit to the delivery of housing during the early-mid years of the plan period from other sources that are less reliant on significant preparatory infrastructure works, to ensure that the supply trajectory is even and secure. The inclusion of a new settlement would normally justify a plan period extending out for around 30 years. To provide a suitable example, the township of Hampton (Peterborough) is a new settlement based on four broad areas and comprising around 8,500 homes, construction of which began in 1996 and is ongoing. \n\nThe short answer to the question is that a new settlement would require the provision of all types of infrastructure – grey, green, and blue, with much being required before the first house is occupied. In this regard if a site similar to one of those indicated by the diagram accompanying Scenario 4 is pursued the road network would very likely need to be substantially upgraded to facilitate access; public transport infrastructure would need to be provided to support sustainable travel (most likely in the form of a railway station/halt to drive sustainable travel behaviours); utilities would need to be significantly upgraded/supplied – water supply, waste water treatment, power supplies re-routed. A new settlement would need primary and secondary school provision, health-infrastructure, sports and recreational facilities, shops, supermarkets, leisure facilities, and other services, employment opportunities and community facilities all provided to support the establishing of a new community. Unlike urban extensions, which will have ready access to existing infrastructure within the urban areas to which they relate, new settlements are starting from a base where there is unlikely to be any meaningful level of provision to support sustainable living. As a consequence, any decision to include a new settlement should be informed by an appreciation that such a project is likely to have a horizon that extends out around 25-30 years from inception. \n\nAny strategy decision that includes a new settlement should be made only if there is a range of other housing supply components that will collectively provide for a balanced and multi-focussed growth strategy. In this regard the inclusion of a new settlement should be pursued only as a policy component that is additional to, rather than in place of urban extensions, that might be perceived as more politically challenging. Given the complexities of delivery it is also important to acknowledge that external public funding may also be required to help secure deliverability.","N/A","","","","","The pros and cons for the six development scenarios present a fair assessment of their potential and provide clear insight into which options are credible to be carried forward as components of a balanced and deliverable housing strategy. The method of presentation of each of the six options is an effective means of conveying the cost-benefit analysis and reveals quickly, which may be ruled out as unrealistic core components. Further commentary on each of the options is provided below, with further expansion in respect of Option 2, which is considered to be the most appropriate core housing supply scenario. \n\nScenario 1: Urban concentration. The analysis presented provides a thorough assessment of the option. It would not provide a realistic core component of a growth strategy for the following reasons (drawn from the table at paragraph 6.16: \n\n• Would not provide sufficient numbers of homes or jobs • Limited range of housing types and therefore constrained choice \n• Loss of employment and commercial space to residential use denuding town centre vitality/function \n• Harm to heritage assets and character • Limited opportunities to deliver supporting infrastructure – grey/green/blue \n• Risk of over development and over burdening of existing infrastructure with limited opportunity to provide new infrastructure. \n\nAdded to the above is the potentially challenging nature of remediation and site preparation that may be associated with the conversion of previously developed land (PDL) to residential use. If, for example, the policy supported the reclassification of commercial and industrial land to residential use there may significant costs associated with remediation measures that could constrain site viability, therefore limiting the provision of supporting infrastructure and affordable housing, for example. Historically, the delivery of brownfield land within the Canal Corridor at Gloucester has been adversely affected by such issues. The Gloucester Heritage Urban Regeneration Company (GHURC) sought, during the early 2000s and beyond, to pump prime and promote the delivery of new housing on contaminated brownfield sites across Gloucester with limited success. A number of these sites remain undeveloped around 20 years later. Reliance on this as the primary source of housing delivery is unlikely to be feasible. \n\nA housing strategy should include a presumption in favour of supporting housing delivery from such sites but should include this as a complementary component to supplement and bolster supply rather than as the core component designed to meet housing need. \n\nScenario 2: Urban Extensions. The consultation material as presented is clear that this is the most favoured and appropriate option to consider as the core delivery component of a housing strategy for the SLP. The ‘Pros’ that are listed demonstrate the multiple benefits that would be realised through pursuit of this strategy. While the loss of Green Belt/green field land is an inevitable consequence given the characteristics of the area, this should not preclude favouring this option as the most appropriate long-term response to meeting the housing and employment needs that will arise across the plan area in the most sustainable way. Careful selection of sites from the range of options that are available would enable the most important objectives of Green Belt notation to be preserved, and some loss of green field land is justified having regard to the economic and social benefits that are highlighted. With regard to agricultural land classification there is ample opportunity to avoid using land of the highest grades (BMV land 1-3a) to deliver the housing and jobs that will be needed. \n\nThe consultation document notes that urban extensions may be one of the most effective ways of delivering high quality public transport infrastructure (including the Mass Rapid Transit Scheme in the LTP) along key transport routes (the A40 corridor) (see also Scenario 6). It is also noted that this option will consider the future role that sites ‘safeguarded’ within the JCS might play in delivering this option. A number of factors should be considered in determining whether these sites retain their development potential, as envisaged when the JCS was examined. For the purpose of these representations focus is placed only on the two areas of safeguarded land at Cheltenham adjacent to site A4 – Northwest Cheltenham, and adjacent to site A7 – West Cheltenham. Different considerations apply to each. \n\nIn the case of the safeguarded land adjoining site A4 the objective when the land was removed from the Green Belt was to provide a safeguarded area that could provide subsequent development phases relating to the NW Cheltenham strategic allocation (4,285 new homes and 23 ha of employment land). It was assumed when the JCS was adopted that the site would have delivered around 1,500 dwellings by then end of March 2024 and would be complete by March 2031. At the time of writing development is yet to commence and it is clear to any reasonable observer that the annual rates of housing completions that were built into the site trajectory are completely unrealistic. These range from 135 dwellings in 2018/19 up to 480 dwellings a year between 2025/26 and 2027/28. Sites such as this typically provide at most around 200-220 dwelling per annum, on which basis (using the most generous of assumptions) it will take at least 20 years to build out the main allocation, before any consideration might be given to the role of the safeguarded land. While the strategic location of site A4 remains sensible and clearly justified in the context of any future strategy for growth across the SLP area it is unlikely that the safeguarded land would need to be called upon to provide future development phases during this next plan period, even if projected forward to 2050. \n\nMore closely related to the interests held by LIH is the safeguarded land adjacent to site A7. While the main allocation for 1,100 homes has also yet to commence delivery, it was assumed by the JCS that the site would have delivered only around 500 homes by the end of March 2024, having adopted more realistic rates of delivery when the JCS was adopted (building from 25 per annum initially to 100 dwellings per annum after four years of completions). Having regard to the above it is not unreasonable to assume that A7 could commence during the early years of the SLP period and achieve higher rates of delivery such that completion of the residential phases of the allocated land may realistically be achieved in 7-10 years, mid-way through the plan period. Consequently, supplementing the existing allocation and continuing the strategic direction of growth to the west by utilising some of the safeguarded land would be prudent. The likelihood that the safeguarded land could be brought forward in the manner anticipated when the JCS was examined is questioned. \n\nThe land adjacent to site A7 was safeguarded on the basis that Severn Trent Water, who manage the Hayden Wastewater Treatment Works, were willing to consider the feasibility of relocating the works if the land was removed from the Green Belt and identified as having future development potential. Such was contingent upon it being economically and operationally viable to do so. In the event the Inspector was willing to preserve this future possibility by safeguarding the land. \n\nAs set out elsewhere in these submissions there is no published evidence to suggest, almost seven years after the JCS was adopted, that there is any ongoing feasibility testing or intention to re-site the works. At the time the JCS was examined it was estimated by the consultants advising Severn Trent that the cost of relocating the facility would be in the region of £80mn and would be subject to an operationally efficient location being found. Colloquially, it is understood that the existing site is the optimum location for a facility of this size and scale serving the population it does. The evidence pertaining to the feasibility exercise associating with the JCS is now between 8 and 9 years old, the consequence of which is that the cost of relocating the works will inevitably have risen. A figure of £100mn is now likely to be a more realistic estimate. Put simply, it is unlikely to be economically sustainable to consider relocation of the treatment works as part of the West Cheltenham project. Accordingly, the safeguarded land should be considered now in the context of its development potential with the works retained in situ, and therefore assessed in terms of the range of uses that could realistically be accommodated on the safeguarded land in support of the Golden Valley scheme. \n\nWork undertaken on behalf of Severn Trent at the time of the JCS examination presented in evidence, noted that with mitigation carried out to all aspects of the treatment process that would contribute to the odour plume surrounding the works it would be possible to reduce the odourpleth (in extent and intensity) to a level that would allow for commercial development to take place within the allocated land (site A7) and for development comprising a mix of commercial and residential uses on around 30% of the safeguarded land. However only a very small component of the safeguarded land would be suitable for residential use with the works retained in situ. \n\nThe firm likelihood now, therefore, is that while the safeguarded land may continue to perform a role in support of the expansion of the Golden Valley development this support will realistically comprise only of further commercial development opportunity. Future phases of residential growth would need to occur on land outside of the mitigated odour plume. The land controlled by LIH (HELAA site S161 – assessed as being developable for both residential and employment use) would support continuation of the Garden Community ethos and would provide a logical and sensible future phase of growth complementing the residential neighbourhoods that are allocated to the north adjoining Hester’s Way. The LIH land could provide new homes and supporting community facilities, including a primary school, on land unaffected by odour constraints associated with the works and in close proximity to sustainable transport opportunities. \n\nThe land at Bamfurlong controlled by LIH is a highly sustainable, compatible urban extension option that is both available and deliverable, and which could readily support the strategic expansion of the west Cheltenham project. It would also locate strategic growth in close proximity to the main strategic transport corridor between Cheltenham and Gloucester that is key to realising future sustainable mass transit opportunities in the plan area. \n\nScenario 3: Urban extensions avoiding the Green Belt. The common theme with this and a number of the other options is that it would be unable to meet the minimum housing requirement identified within the consultation document, which for reasons expanded upon in responding to earlier questions would represent an obvious abdication of responsibility on the part of the plan-making authorities to address the pronounced housing challenges faced across the plan area. The document highlights importantly that Green Belt is not a statutory designation in the way, for example that National Landscapes (AONB) are, these being identified for their particular environmental qualities that warrant protection. It is a spatial planning policy tool implemented to achieve certain spatial objectives. It is only recent political pressure and a generally misunderstood purpose that has enforced the popular misconception that Green Belt land is somehow sacrosanct and should be safeguarded at all costs. Far more important is the imperative to encourage sustainable patterns of growth and to locate development where opportunities to reduce travel demands and build upon existing infrastructure provision are manifest. Such opportunities will often arise adjoining the edge of urban areas that are subject to historic Green Belt notations. The SLP review is the process via which these boundaries should be redefined in pursuit of sustainable growth. Avoiding the use of Green Belt land, per se, is not a well-informed or proportionate response to the challenge of accommodating sustainable growth requirements in the most responsible way. It should be rejected. \n\nScenario 4: New strategic Settlements As set out in response to earlier questions relating to infrastructure provision a strategy relying on the provision of new settlements is unlikely to be tenable where acute challenges arise relating to the delivery of affordable housing and housing supply generally. New settlements are slow in their development and require significant infrastructure investment to precede the delivery of housing and employment growth. The SLP area comprises three main centres of population, with Cheltenham and Gloucester offering great potential for synergistic growth and the delivery of highly sustainable transport and travel options between the two centres via the A40 corridor. Growth should be focussed at these settlements and major infrastructure investment directed to the centres to improve movement options and sustainable access to employment and services that are already concentrated in the existing urban areas. A strategy either relying upon, or incorporating new settlements would be counterproductive and would undermine more sustainable growth and regenerative strategies focussed on the existing main settlements. \n\nScenario 5: Rural dispersal. The notion of rural dispersal is unrealistic and unsustainable and should be rejected. It is a makeweight option that is entirely contrary to any notion of encouraging sustainable growth. \n\nScenario 6: Sustainable transport. The location of growth where the opportunity exists to encourage the adoption of sustainable travel behaviours should be actively pursued as a key component of the spatial strategy. Emissions associated with transport and movement are key contributors to climate change and the spatial strategy should therefore be focussed on encouraging non-polluting and mass transit public transport opportunities. In practice this option is complementary to/consistent with an urban extension strategy. Development allocations should be sought where the opportunity exists to maximise/enhance the use of existing movement infrastructure in locations that are proximate to existing services and facilities.","Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","","","How far into the future should the Strategic and Local Plan cover?\n\nAs noted at paragraph 2.8 the NPPF advises that strategic policies should cover a minimum of 15 years to allow for consideration of long-term trends, demographic shifts, and economic cycles. It is recognised that where appropriate, to support the long-term planning of new settlements/major developments and significant new infrastructure, it may be useful to look ahead towards a 30-year horizon. The Gloucestershire authorities have countenanced such a long-term approach recently in the form of the 2050 Vision for the County. While the consultation does not propose a set timeframe, referring variously to a 15–20-year period, an end date of 2041, and the 30-year horizon referred to in the NPPF, it maintains a flexible position, which at this stage is considered pragmatic. \n\nRecognising the positive stance taken to long-term planning and the intention that this document will function as the development plan that will set both the strategic framework and the locally specific detailed policies for growth across the three areas, it would be prudent to adopt a hybrid approach. In the context of an emerging 2050 Vision that has been considered previously and the challenge of managing long term strategic growth, environmental protection, and nature recovery in a plan area with a significant area of Green Belt it would be prudent to look ahead to a 2050 horizon in respect of strategic policies. Such a long-term approach would create a defined framework within which growth could be planned for and comprehensively managed with certainty and suitable foresight. More detailed local implementation policies would be subject to ongoing and regular review in accordance with the Local Plan Regulations, but the strategic framework could realistically be established via this plan to provide a long-term strategy to accommodate growth in the most sustainable way. Such an approach would create certainty from the perspective of growth planning and with regard to environmental enhancement and nature recovery.\n\nShould the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nBiodiversity Net Gain (‘BNG’) became mandatory as on 12th February 2024, under the Environment Act 2021. It sets out a 10% BNG for all development (referenced in the Act as ‘the relevant percentage’). Any requirements above the mandatory 10% would need to be set out in policy in the Local Plan and for the plan to be deemed sound. This means that the BNG target must be checked against other policies in the plan, to ensure there is no conflict and that other policy aspirations, such as the delivery of affordable housing (the level of provision of which is not mandated), are not compromised. \n\nThere must also be supporting evidence or documentation, including a justification of the local need for a higher percentage, and the incidence of realistic local opportunities for the provision of a higher percentage. Consideration must also be given to how the policy will be implemented. \n\nA viability assessment will be required to determine the financial implications of any additional BNG. The consultation document highlights that viability is already a challenge in parts of the SLP area; it is therefore essential to consider whether higher targets are practically achievable without compromising the viability of development projects. \n\nBy seeking delivery of the mandatory 10% BNG, the Councils are able to meet their draft strategic objective 1 of ‘meeting the challenges of climate change’, by ensuring that growth contributes to the achievement of biodiversity net gain. In circumstances where it is financially viable, development may be able to deliver above the agreed 10%. However, planning policies should only seek levels of BNG that exceed 10%, both across whole plan areas and in respect of individual site allocations where clear justification can be provided.\n\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nThe spatial strategy to be pursued should be a combination of Scenario 2 and Scenario 6. Development Scenario 2: Urban Extensions is the most appropriate strategic policy response to the challenge of meeting housing needs across the plan area. It is the only scenario that allows the housing needs to be met in full. It provides a range of sites that can allow both housing and economic needs to be met in full. Moreover, it does not exacerbate unsustainable travel patterns because people are able to live and work in the local area. In combination with enhanced public transport infrastructure that will encourage sustainable travel choices, it will support modal shift away from private car use helping to reduce greenhouse gas emissions. \n\nA wider range of housing types, sizes, and tenures can also be delivered to meet identified local needs. This will help to improve the affordability of housing in the wider area and make the area more desirable to potential new residents and inward investors. Supplementing existing urban populations through the provision of managed and well-planned sustainable expansion at the settlement edge, in locations that support sustainable travel behaviours, would help to support existing shops and services within town/city centres, improving vitality and viability. The incorporation of Scenario 6 into the strategy, which is compatible with the approach advocated by Scenario 2 given that the options share common characteristics/objectives, would help to ensure that urban extensions are chosen in locations well-served by sustainable transport opportunities. \n\nThe notion of urban concentration (Scenario 1) should be recognised as a supporting component part of any housing strategy that is chosen and expressed by means of support for the principle of development within existing urban areas that is consistent with placemaking and preserving the character and vitality of existing centres. It should be an ‘acceptable in-principle’ component of a growth strategy but should not form part of the core delivery vehicle for meeting housing and employment needs."]
["Statutory/Specific Consultee","Winchcombe Town Council","","None to add.","Unsure.","Yes","","Yes","","Lands designations are respected, and building regulations are introduced to ensure adherence to the Strategic objectives.","Local authorities to be given resource and capacity to follow up and ensure strategic objectives are met, delivered and upheld.","Local authorities to be given resource and capacity to follow up and ensure strategic objectives are met, delivered and upheld.","No","No","","Shops, schools, health services, public transport, financial services.","Yes","Wind turbines on high ground, solar farms and battery storage – disused car parks etc.","Yes","","Yes","In instances where the calculated need is out of date.","Yes","The needs assessment should be identifying these points, which should be conducted more frequently.","Yes","See above.","Should recognise that the requirements for a travelling show person and a traveller gypsy are very different, when considering sites.","To ensure that local and regional business hubs and resources are funded and supported.","The Plan should bring together all the elements/objectives of employment, housing and environment, as one will succeed without the others.","To ensure that nearby development is not likely to adversely effect local businesses (eg a large supermarket causing the closure of local grocery stores)","In the coming Strategic and Local Plan one aim should be to create places where most of people’s daily needs can be met in a short walk or cycle. The benefits of this approach are multiple:people become more active, improving their mental and physical health; traffic is reduced, and air quality improved; local shops and businesses thrive; and people see more of their neighbours, strengthening community bonds.\n\nThe idea of ’20 minute neighbourhoods’ – sometimes called by other names, such as ’15 minute cities’ – has been gaining momentum for several years and is already being implemented in places round the world. Interest in the idea has grown further as the COVID-19 pandemic lockdowns put a spotlight on the importance of the liveability of neighbourhoods.  The goal is for people able to spend more time locally, working at home if possible, using public green space, cycling and walking instead of using cars and connecting with neighbours.  In a community of many older people, that walking with a purpose will deliver health business through increased fitness.\n\nIn Winchcombe there are examples of this development layout approach in the west of the town - several cut throughs enable residents of Delavale Road to reach Gretton Road quickly, and from there  to access on foot to the community hall, shops and the primary school.  The latest development under way on the West of Winchcombe does not offer the same options, but following a public inquiry, the latest Bromford scheme does at least provide one mid development route for people on foot or cycle to the schools, community facilities and shops.\n\nIf the new Strategic and Local Plan aims for this approach, it will be important to explore potential smaller scale development, rather than large more distant less walkable sites towards Greet.","Policies within the Plan should ensure flexibility in consideration of applications for business growth and support and encourage rural employment.","Shops, health services, financial services, educational services, transport and leisure – eg access to green space.","Employment, green travel networks and transport.","Shops, education, green space, community centre/hub, allotments, public transport.","Yes","No","","Yes","","Scenario 4: New strategic settlement; Scenario 6: Sustainable transport scenario","","For all urban and rural growth a policy needs to be introduced to prevent any negative impact upon traffic management and existing road and transport networks.","How far into the future should the Strategic and Local Plan cover?\n\n15 - 20 years.\n\nShould the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nNo, with the exception of those developments requiring mitigating natural space creation.\n\n\nShould sites for traveller communities be provided as part of large developments for housing and/or employment?\n\nYes, but not necessarily within the development site. Developers should contribute towards the identification and costs of suitable traveller sites in suitable locations.\n\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nNew Strategic Settlements and Sustainable Transport."]
["Statutory/Specific Consultee","Brockworth Parish Council ","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","",""," Planning Policy Issues \nBrockworth has undergone major planning development in recent years, according to the 2021 census our population has already doubled in ten years from 9884 in 2011 to 20439 in 2021 an increase of 107% with the population expected to increase\neven more following completion of the Perrybrook development in the coming years. This ongoing development adversely impacts Green Spaces and the AONB, contravening Section 40 of the Natural Environment and Rural Communities Act 2006, as updated by Section 102 of the Environment Act 2021. Concerns also exist \nabout potential visual and light detriments, as well as flooding issues on the Cotswold Escarpment.\nTo preserve remaining green belt land, the council urges measures preventing further development and seeks assurance against changes from agricultural to residential use. Additionally, the Council opposes changing commercial areas to residential.\nHighways\nWorsened by large-scale developments, local highways infrastructure, including A417, A40, A46, and the Coopers Edge development's main road, requires urgent attention. The Council advocates for prioritized measures to address these concerns, \nimproved road safety, increased cycle track facilities, and additional public car parks in the Parish. Concern about increased pollution levels, due to over development and suggests these levels be monitored.\nTransportation\nThe Council calls for a review of bus routes, especially addressing the absence of a bus service in the new Perrybrook development despite existing bus stops. Progression on public EV charging points, a Community Bus scheme, and adherence to the Parish Council’s adopted Sustainable Transport Plan are also \nemphasised.\nHealth and Social Care\nThe Council is expresses immediate concern about the lack of availability in its primary care surgery, preventing new patient registrations from the Perrybrook development. Urgent action is needed to address this issue, including timely rollout of the surgery for Perrybrook.\nSchools\nConcerns centre around the limited availability of Special Educational Needs (SEN) at the primary level in the Parish and the challenges in securing local placements for children within their catchment area. \nYouth Provisions\nAs the Parish Council currently funds oversubscribed Youth Provisions, there is an urgent need for increased funding from the Borough and County Council to accommodate the growing population, ensuring a positive impact on local youth provisions"]
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["Planning agent or developer","SF Planning","","","","","","","","By incentivising schemes which can demonstrate measures to combat climate change or future proof developments. This may include schemes to encourage walking and cycling, net zero homes.","","","No","","","Policy could be drafted to support developments which meet certain criteria such as being within a specified travelling time of at least 3 services on foot or public transport. Note that this shouldn’t mean development outside of settlements offering the level of services outlined in the policy would be refused. The policy should be permissive.\n\nSome of the criteria could include;\n•\temployment area(s) offering 500+ jobs;\n•\tsecondary school\n•\tAllotment\n•\tBank\n•\tCafé / other food outlet\n•\tCommunity hall\n•\tDentist\n•\tFurther education\n•\tGP surgery or pharmacy\n•\tHospital\n•\tLeisure centre\n•\tLibrary\n•\tNursery / pre-school\n•\tPlace of worship\n•\tPlay area or sports field\n•\tPost office\n•\tPrimary school\n•\tPub\n•\tPublic open space\n•\tTown centre, supermarket or convenience store selling fresh food.\n\nThis means that as settlements grow and evolve and bring with them new developments (and potentially new services as a result) the policy can still be applicable rather than becoming out of date. This avoids the potential issue created by designating specific villages as service villages as was done with the JCS and means that a similar policy can apply consistently across the SLP area to any location which perhaps does not have a\nlong list of services in the immediate location, but which has a good regular public transport service to a location which does.","","The Councils could consider a range of different technologies sited across the area and should give some thought to a renewable energy generation target. Sites which are available and have been put forward in the call for sites but perhaps could not be used to meet housing or employment/commercial need due to site constraints could be considered. Although renewable generation isn’t a HEELA criteria, at the same time an assessment as to the suitability of the site for renewable energy generation could be undertaken and included with the findings.","Yes","there do not appear to be any reasons not to use the standard method.","","","","","","","","The councils could be flexible about where employment and commercial development is located and recognise the value of mixed use development in meeting employment need.\n\nAn approach to employment land which considers uses beyond B2 and B8 and encompasses more Class E uses could assist with that flexibility and also with bringing more vibrancy and vitality to employment areas.\n\nProactive policies which incentivise or support conversion of traditional employment sites to a more flexible range of commercial uses could also assist.\n\nPlease also see the response to Q22 below as a well-managed expansion of rural settlements and edge of centre locations should enable businesses to thrive in these locations, thus increasing the number of staff needed.","The councils could be flexible about where employment and commercial development is located and recognise the value of mixed use development in meeting employment need.\n\nAn approach to employment land which considers uses beyond B2 and B8 and encompasses more Class E uses could assist with that flexibility and also with bringing more vibrancy and vitality to employment areas.\n\nProactive policies which incentivise or support conversion of traditional employment sites to a more flexible range of commercial uses could also assist.\n\nPlease also see the response to Q22 below as a well-managed expansion of rural settlements and edge of centre locations should enable businesses to thrive in these locations, thus increasing the number of staff needed.","The councils could be flexible about where employment and commercial development is located and recognise the value of mixed use development in meeting employment need.\n\nAn approach to employment land which considers uses beyond B2 and B8 and encompasses more Class E uses could assist with that flexibility and also with bringing more vibrancy and vitality to employment areas.\n\nProactive policies which incentivise or support conversion of traditional employment sites to a more flexible range of commercial uses could also assist.\n\nPlease also see the response to Q22 below as a well-managed expansion of rural settlements and edge of centre locations should enable businesses to thrive in these locations, thus increasing the number of staff needed.","","By ensuring that there are enough people living in the villages (and surrounding smaller settlements) to utilise the services and facilities.\n\nA flexible approach to the location of development assists with this. Although this does not apply specifically to the site, the removal of settlement boundaries, or boundaries which are deliberately drawn to allow expansion of a settlement will also ensure that a business can grow rather than experiencing stagnation in profits as prices rise and the economic climate becomes more challenging. Settlement boundaries are often drawn relatively tight to existing settlements which does not allow for the additional customers these businesses and services need.\n\n\nPolicy criteria could apply in place of settlement boundaries. See response to Q10 for potential ideas about some of the criteria which could be applied.\n\nDevelopment which accords with the criteria should be supported, other development should not necessarily be refused but material considerations will need to come into play to support such development.","","","See response to Q10. The question isn’t as simple as just looking at how many services a rural settlement has. Account should be taken of the ability to easily access services via footpaths, cycle\npaths and public transport too. A settlement could have no services whatsoever but could be on an excellent public transport route with a relatively short journey time to a larger settlement. This\nshould still be considered acceptable.","","","","","In its capacity as landowner, Gloucestershire County Council considers the following growth scenarios can be acceptable ;\na) Urban extensions (scenario 2)\nb) Rural Dispersal (scenario 5)\nc) Sustainable transport scenario (scenario 6) – but with some caveats\n\nEach of these is considered in turn. \n\na) urban extensions (scenario 2) - The strategy of allocating urban extensions around the existing towns can be an ideal and sustainable approach to distributing housing, particularly in terms of meeting local housing need.\n\nb) In its capacity as landowner, Gloucestershire County Council considers the Rural Dispersal scenario (5) can be appropriate. However, this scenario advocates for development at the smallest of hamlets. \n\nThere does not appear to be a scenario which directs growth to locations which have access to a base level of facilities such as those outlined in\nresponse to Q10 above (whether or not that is a small village with good transport links or a larger villages with more services in the village itself). \n\nWe agree that scenario 5 can help to support thriving communities by supporting shops services and facilities and with the other pros identified in\nrelation to this scenario.\n\nIn terms of the cons for scenario 5, much will depend on the scale and size of the development and, more critically, how it is designed.\n\nAlso, policies which incentivise certain types of housing which are needed could overcome some of the more significant impacts of the reduced ability\nto provide a full range of housing sizes, types and tenures. \n\nc) Scenario 6 – sustainable transport \nThe approach makes sense from a carbon emissions perspective but is limited as some focus on development around proposed road network enhancements would be acceptable. ","","","As indicated above (see response to Q10) a hierarchy of settlements is not necessarily the most appropriate way to ensure that policies remain applicable and relevant (i.e. up to date) across the whole plan period. Instead, each application could be considered with reference to accessibility to different services. This ensures that the situation at the time the decision is made can be taken into account rather than being based on information which, at some stage, could become 10 years out of date.","[Q8 - No because it can be very difficult to meet this target on constrained sites, but there could be positively worded policies to incentivise providing more than 10% BNG.]\n\n[Q9 - Gloucestershire County Council has submitted several sites to the call for sites. Of these, Odessa Farm could easily incorporate some element of wildlife, green space or biodiversity net gain to the call for sites. Church Farm at Twigworth is also able to incorporate green infrastructure.]\n\n1.\tThis regulation 18 Strategic and Local Plan consultation response is prepared by SF Planning Limited on behalf of GCC. Please note that SF Planning Limited are only instructed by GCC strictly in their capacity as landowner and not in respect of any of GCC’s executive or regulatory functions such as Highway Authority. Any representations from GCC in their capacity as County Council will be submitted separately by GCC or their agents/representatives and not by SF Planning Limited.\n\n2.\tGCC has separately submitted several sites to the call for sites. This document is intended to set out their response to the questions within the regulation 18 consultation document for the Strategic and Local Plan. The relevant questions and responses to those are set out in the table below.\n\n3.\tPlease contact me should you find it helpful to discuss the information included in this submission.\n\n[Q.29] In its capacity as landowner, Gloucestershire County Council considers the following growth scenarios can be acceptable ;\na) Urban extensions (scenario 2)\nb) Rural Dispersal (scenario 5)\nc) Sustainable transport scenario (scenario 6) – but with some caveats\n\nEach of these is considered in turn. \n\na) urban extensions (scenario 2) - The strategy of allocating urban extensions around the existing towns can be an ideal and sustainable approach to distributing housing, particularly in terms of meeting local housing need.\n\nb) In its capacity as landowner, Gloucestershire County Council considers the Rural Dispersal scenario (5) can be appropriate. However, this scenario advocates for development at the smallest of hamlets. \n\nThere does not appear to be a scenario which directs growth to locations which have access to a base level of facilities such as those outlined in\nresponse to Q10 above (whether or not that is a small village with good transport links or a larger villages with more services in the village itself). \n\nWe agree that scenario 5 can help to support thriving communities by supporting shops services and facilities and with the other pros identified in\nrelation to this scenario.\n\nIn terms of the cons for scenario 5, much will depend on the scale and size of the development and, more critically, how it is designed.\n\nAlso, policies which incentivise certain types of housing which are needed could overcome some of the more significant impacts of the reduced ability\nto provide a full range of housing sizes, types and tenures. \n\nc) Scenario 6 – sustainable transport \nThe approach makes sense from a carbon emissions perspective but is limited as some focus on development around proposed road network enhancements would be acceptable. \n"]
["Resident",null,20,"\nThe physical and mental well-being of local people also needs to be considered including factors such as air quality, access to green areas for walking and cycling. It’s not just about providing housing, but making it a pleasant and safe area where people enjoy living. \n","It is important to restrict urban sprawl and infringement of greenbelt land. Over the past few years many of our town centres, including Cheltenham, have deteriorated with empty shops/buildings, whilst large areas of development have been carried out of countryside such as around Churchdown affecting traffic, pressure on services, flooding and using up countryside . Building on green belt land should be an absolute last resort. By investing in attractive, characterful, quality housing in empty buildings and on brown field sites close to the town centre and ensuring it is a safe, low crime/crime free area, people will be attracted to living there and in turn will give a much needed boost to the local economy.","","\nWhilst we agree with the “vision”, the reality is much removed from this. You cannot build housing and retain the natural environment in the same area. Aspects of the vision are not appropriate for some semi-rural areas and are more relevant to already established urban areas. \n","Yes","","Preserving the greenbelt should be a priority and planting areas of trees could be considered. Community orchards would not only act as carbon sinks and storage, but would also mitigate flooding and improve air quality and noise pollution whilst adding to the general aesthetic. Regeneration of town centres and cities would allow people to commute in a sustainable way (walk/cycle/public transport) rather than by using private cars so reducing the use of fossil fuels and pollution. Plants could be utilised on roofs and in urban spaces to remove pollution, sound proof, provide shade and reduce temperatures in areas of high concrete density. Use of existing buildings and roads would reduce the use of environmentally damaging building materials such as concrete. Therefore brownfield sites and existing buildings should be always seriously considered in the first instance. Any new housing should have climate protective measures as an integral part of the design.","Greenbelt areas, such as those around Churchdown/Chosen Hill area should be protected and preferably planted with trees to reduce flooding and take up carbon dioxide and pollutants. These areas should not be used for housing development. As aforementioned brownfield sites and existing buildings should be used. Any new housing should meet stringent sustainability criteria and have an integral eco-friendly design and materials.","Greenbelt areas, such as those around Churchdown/Chosen Hill area should be protected and preferably planted with trees to reduce flooding and take up carbon dioxide and pollutants. These areas should not be used for housing development. As aforementioned brownfield sites and existing buildings should be used. Any new housing should meet stringent sustainability criteria and have an integral eco-friendly design and materials.","Yes","","","","","","","","","","","Possibly one level or adapted housing for older/disabled residents. Attractive flats for younger people in the town centres close to work and amenities/entertainment.","","","","","","More land retained for agriculture and not built on requiring farm workers. Allow farmers to convert buildings in a sustainable way to use for holiday accommodation. Green leisure areas such as in Forest of Dean, which require people to work in and maintain the areas. ","","","","","","","","The focus should be on housing in existing towns and cities. By regeneration of these areas private vehicle use is reduced. The local economy is stimulated and there is reduced usage of construction materials as people would be using public transport to travel on existing roadways.","","Yes, scenario 1) appears most appropriate and building should be in keeping with the character of the existing heritage/conservation area.\nScenario2) is most undesirable as it damages the natural environment, exacerbates climate change and potential flooding. Will lead to increased use of private vehicles, more building of roadways and the negative environmental impact associated with that; increased pollution and reduced air quality\nScenario 3) will result in loss of valuable agricultural land; a factor that as a country we need to be self-sufficient and protect food security.\nScenario 4) Last resort\nScenario 5) destroys character of historical and often picturesque villages/hamlets. Only replacement of existing individual homes in these areas should be considered or very small numbers of affordable housing.","Scenario 1: Urban concentration","","","[Q1] 15 – 20 years\n\n[Q8] Yes, the Environment act 2021 has a mandatory requirement for 10% BNG. We should definitely be aiming to exceed this and building on the greenbelt is not conducive to meeting this target. Local plans should promote conservation, especially where the existing area is countryside/greenbelt. \nMeeting the BNG should not be carried out offsite and used as a “loophole” to permit building on the greenbelt\n\n[Q9] - The land near Brookfield road, Churchdown and Oldbury orchard already has rich biodiversity in terms of amphibians, birds, reptiles and larger mammals such as deer, foxes and badgers. It is well-used by local residents as there are a number of existing public rights of way on this land. By enhancing the local natural environment for example tree planting, this area would fulfil a number of environmental purposes, such as reducing flood risk, reducing noise and traffic pollution from the nearby M5, increasing take up of carbon by vegetation and increasing BNG. It used to have an orchard in this area so for example a community orchard would fulfil all of the above with the added merit of improving the health and wellbeing of people using it and providing local produce.\n\nIt is pertinent to note that a recent appeal to build on land on Parton  Road, Churchdown has been dismissed by the planning inspectorate on the grounds that it would result in “harm to the openness of the greenbelt and would lead to encroachment into the countryside”. \nAs mentioned in the other sections, by regenerating town centres, many of the aspects of the strategic “vision” could be fulfilled. Not only would developing these urban areas help to mitigate climate change and provide a range of housing for a variety of ages close to facilities, but natural environments/greenbelt could be preserved and indeed enhanced that would provide much needed green spaces to positively impact the physical and mental well-being of local people."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Answers to Stategic Review.  \nThe number of new homes should be proportionate to the health education and draininage capacity.  Please do not allow development until services are established. "]
["Statutory/Specific Consultee","Police and Crime Commissioner for Gloucestershire","","Yes. Under the strategic policy topic of infrastructure, emergency services infrastructure should be \nspecifically mentioned and addressed in the emerging SLP.","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","In reply to Questions 23 and 24, it is an indisputable fact that everyone, no matter the development \nscheme they are in, its size or where it is, expect and require the fire and rescue, ambulance and \npolice services to be available at all times when emergencies happen affecting them, their families or \ntheir friends. Whilst the emergency services will always endeavour to deliver help to those who need \nit when called upon, such provision must be planned and provided for in advance, as is the case with\nany other essential infrastructure type. Failure to plan for this would put peoples’ lives and property \nat a constantly higher risk of danger than would otherwise be the case.\nThe infrastructure needed takes the form of new on or off-site provision or improvements to the \ncapacity of existing emergency and rescue services infrastructure either on or off-site. \nIt is this context that explains why the Government has made it abundantly clear that it is entirely \nreasonable and proper for emergency services infrastructure to be delivered alongside new \ndevelopment. This is demonstrated by the following:\n5\n• The Levelling-up and Regeneration Act 2023 states in its definition of ‘infrastructure’ for \nthe new Infrastructure Levy ‘facilities and equipment for emergency and rescue services’ \n(see Schedule 12 – Part 1 – Section 204N (3)).\n• The National Planning Policy Framework (December 2023) makes clear at paragraphs \n8(b), 16 (c), 20(b), 96 (b), 97, 101, 116(d) and 135 (f) that crime reduction, safety and the \ninfrastructure to deliver these are material considerations that should be fully accounted \nfor by planning policies and decisions.\n• Statutory Planning Practice Guidance states the following in relation to the current \nlegislative context and the spending of CIL receipts:\n“The Levy can be used to fund a wide range of infrastructure, including transport, flood \ndefences, schools, hospitals, and other health and social care facilities (for further details, \nsee section 216(2) of the Planning Act 2008 and regulation 59, as amended by the 2012 \nand 2013 Regulations). This definition allows the Levy to be used to fund a very broad \nrange of facilities such as play areas, open spaces, parks and green spaces, cultural and \nsports facilities, healthcare facilities, academies and free schools, district heating schemes \nand police stations and other community safety facilities. This flexibility gives local areas \nthe opportunity to choose what infrastructure they need to deliver their relevant plan (the \nDevelopment Plan and the London Plan in London). Charging authorities may not use the \nlevy to fund affordable housing. (our emphasis)\nLocal authorities must spend the levy on infrastructure needed to support the \ndevelopment of their area, and they will decide what infrastructure is needed.\nThe Levy can be used to increase the capacity of existing infrastructure or to repair \nfailing existing infrastructure, if that is necessary to support development. (our \nemphasis)\nIn London, the regulations restrict spending by the Mayor to funding roads or other \ntransport facilities, including Crossrail, to ensure a balance between the spending \npriorities of the London boroughs and the Mayor.”\nParagraph 144 Reference ID: 25-144-20190901\nRevision date: 01 09 2019\n• Although there is no statutory definition of ‘infrastructure’ for the purposes of Section \n106 agreements, there are 43 planning appeal decisions (see Appendix 1B) that support \nSection 106 contributions for police infrastructure of all kinds. Twelve of these decisions \nwere made by the Secretary of State. There are also 5 appeal decisions (see Appendix 2)\nthat support Section 106 contributions for fire and rescue infrastructure of all kinds, of \nwhich one of these decisions was made by the Secretary of State. There is clearly no \ndoubt from the sheer volume of these decisions that planning obligations to deliver \nemergency services infrastructure are compliant with the relevant statutory tests.\n6\nIn view of the above, we recommend that paragraph 5.53 be amended as below (blue text):\n“New homes and employment will need to have new infrastructure, for example schools, \nroads, public transport, health services, emergency and rescue services and recreation \nprovision. This will need to be funded through central and local government funding streams \nand contributions from developers.”\n","","","","","","","","","","et out below are the Office of the Police & Crime Commissioner for Gloucestershire’s (OPCC’s) \nresponses to the questions set out in the consultation document that are relevant to police and \nemergency services infrastructure provision within Cheltenham, Gloucester and Tewkesbury in the \nStrategic Local Plan (SLP) period. A total of 6 of the 31 consultation questions are responded to \nbelow, preceded by a summary of statutory and national planning context as relevant to these \nrepresentations. \nStatutory context:\nPart 1 of the Police Reform and Social Responsibility Act 2011 states that a Police and Crime \nCommissioner (PCC) must secure the maintenance of the police force for their area, whilst ensuring \nthat it is efficient and effective under the direction and control of the Chief Constable. \nUnder the Policing Protocol Order 2023 the PCC has a specific responsibility for the delivery of \ncommunity safety and crime reduction. \nSection 17 of the Crime and Disorder Act 1998 (as amended by the Police and Justice Act 2006) \nrequires local authorities to do all that they reasonably can to prevent crime and disorder including \nanti-social and other behaviour adversely affecting the local environment in the exercise of their \nvarious functions. \nThe Levelling-up and Regeneration Act 2023, in its definition of ‘infrastructure’ for the new \nInfrastructure Levy, includes ‘facilities and equipment for emergency and rescue services’ (see \nSchedule 12 – Part 1 – Section 204N (3)).\nNational planning context:\nIn line with NPPF (revised December 2023) guidance, emergency services are a crucial part of service \ndelivery to sustainable communities. Paragraph 101 requires that “Planning policies and decisions \nshould promote public safety and take into account wider security and defence requirements…”\nNPPF paragraph 135 f) states that:\n“Planning policies and decisions should ensure that developments……….create places that are safe, \ninclusive and accessible and which promote health and well-being, with a high standard of \namenity for existing and future users; and where crime and disorder, and the fear of crime, do not \nundermine the quality of life or community cohesion and resilience.”\n2\nWith regard to promoting healthy communities, paragraph 96 of the NPPF guides that “Planning \npolicies and decisions should aim to achieve healthy, inclusive and safe places which…… are safe \nand accessible, so that crime and disorder, and the fear of crime, do not undermine the quality of \nlife or community cohesion.”\nNPPF paragraph 100 states that: “To ensure faster delivery of other public service infrastructure \nsuch as further education colleges, hospitals and criminal justice accommodation, local planning \nauthorities should also work proactively and positively with promoters, delivery partners and \nstatutory bodies to plan for required facilities and resolve key planning issues before applications \nare submitted.”\nThe NPPF references at Paragraph 57 the three tests for planning obligations as set out in Regulation \n122(2) of the Community Infrastructure Levy Regulations 2010 (as amended).\nDeveloper contributions to policing infrastructure have been scrutinised by the High Court, Secretary \nof State and the Planning Inspectorate and found to be wholly in accordance with the statutory tests \nincluding the Community Infrastructure Levy Regulations 2010 (as amended), please see summary at \nAppendix 1A. Recent planning appeal case law nationally has confirmed that developer \ncontributions towards policing infrastructure accord with the NPPF (please see summary at\nAppendix 1B). \n3\nOPCC consultation question responses:\n2. Are there any strategic policy topics, not identified above (paragraph 2.4), which should also be \nconsidered? \nYes. Under the strategic policy topic of infrastructure, emergency services infrastructure should be \nspecifically mentioned and addressed in the emerging SLP.\n4. Do you agree with the draft Vision? a. If not, what changes would you like to see? \nParagraph 3.3 sub paragraph j) rightly identifies as a key issue that will shape the Vision the need for:\n“Identifying and facilitating infrastructure needed to support development, including (but not \nlimited to) education; transport, e.g. mass rapid transit routes; health; e.g. GP surgeries; green \ninfrastructure, and digital infrastructure, that are needed to support growth and our \ncommunities.“\nAlthough this is not an exclusive list, it should include emergency services and rescue infrastructure, \ngiven the statutory and NPPF context described in the introduction to these representations. The \nfirst sentence of the fifth paragraph of the vision should be amended as follows (blue text):\nGrowth will have been supported by the provision of a range of essential digital, transport, \ncommunity, emergency and rescue services and other infrastructure. \nIn addition, paragraph 3.3 should reference the definition of infrastructure set out in the Levellingup and Regeneration Act 2023.\n5. Do you agree with the draft Strategic Objectives? a. If not, what changes would you like to see? \nAs above, paragraph 3.3 sub paragraph j) rightly identifies as a key issue that will shape the Vision \nthe need for:\n“Identifying and facilitating infrastructure needed to support development, \nincluding (but not limited to) education; transport, e.g. mass rapid transit routes; \nhealth; e.g. GP surgeries; green infrastructure, and digital infrastructure, that are \nneeded to support growth and our communities.“\nAgain, although this is not an exclusive list, it should include emergency services and rescue \ninfrastructure and reference the definition of infrastructure set out in the Levelling-up and \nRegeneration Act 2023.\nUnder the strategic objective of “Delivering well designed, beautiful and safe places”, point 1. should \nbe amended as follows (blue text):\n1. Supporting the creation of high quality, beautiful and sustainable buildings and places through \ngood design, incorporating secured by design principles. \nIncluding this amendment would have the significant benefit of aligning the strategic objective much \nmore closely with paragraphs 96 (b) and 135(f) of the NPPF and the following content of Planning \nPractice Guidance:\n4\n“Planning provides an important opportunity to consider the security of the built \nenvironment, those that live and work in it and the servicesit provides. (our emphasis)\nSection 17 of the Crime and Disorder Act 1998 (as amended) requires all local, joint and \ncombined authorities (as well as National Parks, the Broads Authority and the Greater \nLondon Authority) to exercise their functions with due regard to their likely effect on \ncrime and disorder, and to do all they reasonably can to prevent crime and disorder. \nCrime for these purposes includes terrorism.”\nParagraph: 009 Reference ID: 53-009-20190722\nRevision date: 22 07 2019\nPoint 2 under strategic objective “Delivering well designed, beautiful and safe places” should be \namended as follows (blue text) in view of the statutory and NPPF context stated in the introduction \nto these representations.\n2. Ensuring that new development is integrated well with existing communities and providing welllocated infrastructure, including emergency services and rescue infrastructure, which meets the \nneeds of communities; \nUnder the strategic objective of “Promoting healthy and resilient communities, point 1 should be \namended as follows (blue text) given the statutory and NPPF context described in the introduction to \nthese representations. \n“1. Delivering new developments that are supported by the necessary social and community \ninfrastructure, including schools, emergency and rescue services, open space, playing fields, \ncommunity facilities and green and blue infrastructure and promote community cohesion. “\n23. What types of infrastructure do you consider are most critical to be delivered alongside new \ndevelopment? \n24. Given their size, if strategic scale new settlements were to form a part of the Strategic and \nLocal Plan, what accompanying infrastructure would be necessary? \nIn reply to Questions 23 and 24, it is an indisputable fact that everyone, no matter the development \nscheme they are in, its size or where it is, expect and require the fire and rescue, ambulance and \npolice services to be available at all times when emergencies happen affecting them, their families or \ntheir friends. Whilst the emergency services will always endeavour to deliver help to those who need \nit when called upon, such provision must be planned and provided for in advance, as is the case with\nany other essential infrastructure type. Failure to plan for this would put peoples’ lives and property \nat a constantly higher risk of danger than would otherwise be the case.\nThe infrastructure needed takes the form of new on or off-site provision or improvements to the \ncapacity of existing emergency and rescue services infrastructure either on or off-site. \nIt is this context that explains why the Government has made it abundantly clear that it is entirely \nreasonable and proper for emergency services infrastructure to be delivered alongside new \ndevelopment. This is demonstrated by the following:\n5\n• The Levelling-up and Regeneration Act 2023 states in its definition of ‘infrastructure’ for \nthe new Infrastructure Levy ‘facilities and equipment for emergency and rescue services’ \n(see Schedule 12 – Part 1 – Section 204N (3)).\n• The National Planning Policy Framework (December 2023) makes clear at paragraphs \n8(b), 16 (c), 20(b), 96 (b), 97, 101, 116(d) and 135 (f) that crime reduction, safety and the \ninfrastructure to deliver these are material considerations that should be fully accounted \nfor by planning policies and decisions.\n• Statutory Planning Practice Guidance states the following in relation to the current \nlegislative context and the spending of CIL receipts:\n“The Levy can be used to fund a wide range of infrastructure, including transport, flood \ndefences, schools, hospitals, and other health and social care facilities (for further details, \nsee section 216(2) of the Planning Act 2008 and regulation 59, as amended by the 2012 \nand 2013 Regulations). This definition allows the Levy to be used to fund a very broad \nrange of facilities such as play areas, open spaces, parks and green spaces, cultural and \nsports facilities, healthcare facilities, academies and free schools, district heating schemes \nand police stations and other community safety facilities. This flexibility gives local areas \nthe opportunity to choose what infrastructure they need to deliver their relevant plan (the \nDevelopment Plan and the London Plan in London). Charging authorities may not use the \nlevy to fund affordable housing. (our emphasis)\nLocal authorities must spend the levy on infrastructure needed to support the \ndevelopment of their area, and they will decide what infrastructure is needed.\nThe Levy can be used to increase the capacity of existing infrastructure or to repair \nfailing existing infrastructure, if that is necessary to support development. (our \nemphasis)\nIn London, the regulations restrict spending by the Mayor to funding roads or other \ntransport facilities, including Crossrail, to ensure a balance between the spending \npriorities of the London boroughs and the Mayor.”\nParagraph 144 Reference ID: 25-144-20190901\nRevision date: 01 09 2019\n• Although there is no statutory definition of ‘infrastructure’ for the purposes of Section \n106 agreements, there are 43 planning appeal decisions (see Appendix 1B) that support \nSection 106 contributions for police infrastructure of all kinds. Twelve of these decisions \nwere made by the Secretary of State. There are also 5 appeal decisions (see Appendix 2)\nthat support Section 106 contributions for fire and rescue infrastructure of all kinds, of \nwhich one of these decisions was made by the Secretary of State. There is clearly no \ndoubt from the sheer volume of these decisions that planning obligations to deliver \nemergency services infrastructure are compliant with the relevant statutory tests.\n6\nIn view of the above, we recommend that paragraph 5.53 be amended as below (blue text):\n“New homes and employment will need to have new infrastructure, for example schools, \nroads, public transport, health services, emergency and rescue services and recreation \nprovision. This will need to be funded through central and local government funding streams \nand contributions from developers.”\n26. Should the Strategic and Local Plan safeguard sites or routes for longer term infrastructure \nprojects? \nYes. If the SLP does not identify and safeguard land that is necessary for essential longer-term\ninfrastructure, then there will be risk to its future delivery which will be to the detriment on the \nproposed development and communities that will live and work in them. Infrastructure \ndevelopment and provision of land for it comes at a cost in the economics of property development. \nUnderstandably, developers will look to minimise costs were possible in order to maximise \nprofitability. Unless the SLP Authorities safeguard essential infrastructure land then the delivery of \nplanned infrastructure will be at risk.\nA current and very relevant example of what can happen if land for essential supporting \ninfrastructure is not safeguarded is provided by Elms Park (North West Cheltenham Strategic \nallocation planning application reference 16/02000/OUT). In this case, despite the OPCC having \nsubmitted formal requests and JCS representations to Tewkesbury Borough Council and Cheltenham \nBorough Council and the developer for over 10 years seeking provision of on and off-site policing \ninfrastructure, the developer has failed to include any on site provision in the masterplan for this \nscheme. Negotiations are still ongoing. \nAny queries on the above OPCC consultation response should in the first instance be emailed to \nMandy Gibbs of Gloucestershire Constabulary (Mandy.Gibbs@Gloucestershire.pnn.police.uk)."]
["Planning agent or developer","Redcliffe Homes ",20,"","","","","","","","","","","","","","","","No","Redcliffe Homes argue that the draft plan does not provide a strategy which meets the future needs of the SLP area. The National Planning Policy Framework (NPPF) sets out that plans should be prepared positively, in a way that is aspirational but deliverable. It goes on to state that strategic polices should look beyond as a minimum of 15 years from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. The NPPG sets out clearly that the standard method should be seen as a minimum starting point. The guidance goes on to state that the government is: “committed to ensuring that more homes are built and supports ambitious authorities who want to plan for growth”. “The standard method for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore, there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates” Throughout the NPPF and NPPG it is made clear that the standard method is to be seen as a minimum. This point is echoed in the recent ministerial letter from Michael Gove to all Council Leaders and Local Planning Authorities (dated 8th September 2023) whereby he states that: “….we want local authorities to continue adopting ambitious local plans” It is felt that the current SLP, which provides only for the minimal housing need is not ambitious nor positively prepared. Another consideration, which is directly linked with housing need, is employment need. Within Chapter 5, it highlights an under provision of labour supply compared with demand, which would further increase housing need. There is a mention that that the evidence used in the assessments of development needs pre-dated effects of Brexit and the Covid-19 pandemic. As a result, the Councils consider that this evidence base needed to be updated. Nothing is certain regarding the future employment position and the SLP should not take a cautious and conservative view, based on the recent trend of working from home. What is not clear is if this trend will continue, although there are already signs that some people are now returning to the workplace. Given that this plan is aimed to cover the next 15 -20 years, it should be pragmatic and plan for higher growth and employment through the retention and addition of further allocations, to meet demand. It is concluded that housing figures following the standard method as a minimum based on updated employment surveys, which in turn could focus on post Covid-19 working from home is not a sound nor positive strategy. Redcliffe Homes would argue that a truly positive approach would be to allow for increased employment and therefore an increased housing need figure. Particular given the possibility of an additional 36,000 jobs in the SLP area.","","","","","","","","","","","","","In terms of infrastructure, it depends on the size and location of development. For medium sized urban extensions, the key infrastructure relates to public transport and pedestrian links. New towns require significant levels of infrastructure including train access and bus interchanges which can be costly and very time consuming to bring forward. For small scale developments, there is very little infrastructure that is required, however it doesn’t provide the level of benefits that larger developments facilitate. For the reasons above, urban extensions are considered the preferred alternative whereby they can provide a wealth of public benefits, immediately without the need for large, complex and costly infrastructure needed for new towns. They can easily connect to the adjacent facilities, together with financial support for improved bus links/connections enabling development to come forward efficiently and in locations where demand outstrips supply.","","","","Yes","The proposed scenarios rightly have pros and cons, however what is missing is the mix or blend of several. It would not be appropriate to only promote one alone, particularly scenarios 1 urban concentration, 3 urban extensions excluding green belt or 4 new settlements as they are reliant on one or two concentrated locations. ","","","Scenario 2: Urban extensions","","","[Q1.] Redcliffe Homes would recommend a minimum of 20 years in terms of strategic planning, although it’s important that this is regularly reviewed. Given the scale of the current housing crisis and undeliverability there is a need to provide significant levels of housing going forward, which Redcliffe believe will require large scale development. It’s important that any vision covers a longer period of time to allow for these to come forward through comprehensive development.\n[Q8.] Whilst Redcliffe Homes would support ambitious targets for BNG, and in fact many of Redcliffe Homes’ development exceed 20-30%, this is not always the case. Many urban developments, naturally struggle to meet 10% net gain and an increase from the statutory minimum of 10% would have an impact on housing delivery overall, when housing and affordable housing is in short supply versus demand. The BNG legislation undertook significant consultation over several years, which resulted in the 10% minimum, following considerable analysis. The 10% was determined based on a fine balance between environmental enhancement vs housing delivery. Redcliffe Homes would recommend retaining the 10% figure for the next plan period to ensure housing delivery is maximised.\n[Q.29] Notwithstanding the overall housing need figures, which are below where they should be, what is also important is the proposed distribution of housing within the SLP area to ensure deliverability in the areas of need through proportionate growth.Redcliffe Homes are firmly supporters of scenario 2- urban extensions.Redcliffe Homes believe that scenario 2 meets the correct balance. It provides large enough developments to provide the housing numbers desperately needed, close to where the need is required, whilst not providing developments that are too large and in need of significant infrastructure which will take years to come online. The current consultation sets out proposed housing numbers split between the three local authorities, which are split between 10,940 for Cheltenham Borough, 13,620 for Gloucester City and 11,140 for Tewkesbury Borough. The current consultation makes clear that a distribution strategy has not yet been decided but does refer to the existing strategy, which follows a ‘tried and tested’ settlement hierarchy approach. Redcliffe Homes would support this approach, which would concentrate housing where it is most needed, without reliance on one or two very large projects. It is recommended that a proportionate approach be proposed within the Local Plan, with the distribution of housing numbers still heavily weighted towards the top tier principal settlements. However, this should remove the reliance on very large and complex housing allocations, such as in northwest Cheltenham, where it has shown that reliance on one very large development, can prove to be slow and costly. This allocated 4,285 homes and is still pending a decision (16/0200/OUT). Some local authorities and joint strategies have previously tried a new approach to housing distribution, such as Stroud District Council whereby they proposed a new settlement, however that plan is now on hold due to issues raised by Inspectors regarding deliverability for such large infrastructure. Elsewhere the West of England JSP, which focussed on housing, jobs and infrastructure was also scrapped, following serious issues raised by Inspectors in respect of robust evidence to demonstrate SDL’s, which was an integral part of the plans spatial strategy. It is fact that Tewksbury Borough Council cannot currently demonstrate a 5-year supply of housing and much of this is down to the lack of large-scale housing developments coming forward as quick as planned. It is acknowledged that there are benefits to large strategic allocations, however they need to be properly thought out, evidenced, designed, funded and supported by background research together with smaller urban extensions across all settlements. This representation encloses a ‘concept plan’ which has been prepared by Redcliffe Homes to support the allocation of the site. This shows how the whole site could accommodate in the region of 850 homes. Redcliffe Homes have been a key stakeholder to this proposed allocation for over 10 years, having previously submitted an outline planning application for much of the site back in 2017 (ref: 17/00924/OUT) as aforementioned. Redcliffe Homes currently have an option with the landowner that controls the majority of the proposed phase 1, together with Newland Homes. This would enable an instant start on site and bring forward housing towards the Tewkesbury housing allocation numbers for the next plan period. This is even more important as Tewkesbury Borough Council are currently allocated to provide 11,140 homes, but does not contain a principal town. It therefore makes sense to utilise adjacent principal towns for facilities such as this proposal. Tewksbury Town alone cannot provide all of the 11,140 homes. Another key consideration, and one that is clearly known is that the SLP area is heavily constrained. Much of the three council areas are either located within areas at risk of flooding, Areas of Outstanding Natural Beauty (AONB) and Green Belt. These are indicatively shown within the proposed scenarios. What is clear from these constraints, and others is that the SLP cannot sustainably and realistically deliver the homes needed without impact upon one of these constraints. Flood risk and AONB are environmental based designations, which cannot be easily amended or removed and for good reason. However green belt is a purely policy-based designation, contrary to public opinion. It was created as a temporary solution to encourage redevelopment of brownfield sites and to prevent unplanned urban sprawl in the 1960s and again later in the 1980s. From time to time, through plan review, this needs to be relaxed to allow for limited levels of planned development, such as now. Redcliffe homes would highlight that where local authorities such as South Gloucestershire and Bath and Northeast Somerset Councils have taken pragmatic and bold decisions regarding local plans, which include allocating green belt land, those plans have progressed quickly and positively, enabling those local authorities to retain 5-year housing supplies and resist future un-planned development. \n[Q.31] Redcliffe Homes would support a settlement hierarchy modal/scenario for future housing growth to ensure housing provision is deliverable, sustainable and meets the needs of the population and employment demand. It is vital that the SLP is positive, pragmatic and bold in terms of its overall housing numbers but also its housing allocations. Given the current shortage of housing in the region, it is even more important that the housing allocations are deliverable in the short term and brought forward as soon as reasonably possible. The existing struggles to bring forward very large mixed-use allocations elsewhere, such as northwest Cheltenham is a perfect example why allocations need to be proportionate, fully tested and evidenced to ensure they are deliverable in the short and medium term. Redcliffe Homes, together with Newland Homes and others support the inclusion of smaller sustainable urban extensions such as the proposed site at Up Hatherley Way. Redcliffe Homes have been working on this site for over 10 years and have a wealth of evidence and supporting documentation, which accompanied the previous outline planning application. Whilst this application was refused, this was purely on principle policy grounds, particularly green belt. In light of the extremely poor housing supply situation in Tewkesbury BC, the SLP now needs to consider green belt sites for allocation and this site is perfect in terms of size and location. It is large enough that it can provide significant levels of housing in a deliverable manner, but without the need for expensive and complex engineering or infrastructure. By virtue of its location, directly adjacent to the urban settlement of Cheltenham, it can easily link into the existing facilities and jobs in the area. Redcliffe Homes would therefore support the inclusion of an ambitious housing target figure, which relates and matches an ambitious employment figure. I settlement hierarchy appearance is supported which focusses primarily on urban extensions including the proposed sit at Up Hatherley, although it is acknowledged that there will be need for elements of other scenarios. It is considered that this approach will ensure that the SLP will proceed through examination in a quick and smooth fashion, which will also ensure the fast delivery of housing and provide the LPAs with a strong position to resist further un-planned development."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Ten years ago I took part in a campaign to prevent housing development in Chargrove. We had just arrived in Cheltenham. The unanimous decision then by Tewkesbury Council was that the development should not go ahead because of the particular quality of this area. Chargrove is a survivor of pastoral landscape within the encroaching suburbanisation from all sides, Cheltenham, Gloucester and Tewkesbury.   It is sympathetically farmed for livestock, chiefly sheep, and some arable Wild life of all kinds find refuge here. An old pear orchard continues to provide clouds of blossom in spring.   There is a cricket field, long since donated by the then owner of the small estate of South Park.  The farm buildings have recently received planning permission approval for conversion to dwellings. This small area, within the already diminished green belt, is a rare source of spiritual and physical  refreshment for the many people who walk, run or cycle here, picnic in summer, watch birds and look up at the unspoiled view of hills beyond. Human beings and nature alike benefit from it. To suggest, as may be the case in future, that it should be sacrificed for development, would be ecological vandalism."]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","We attended the information meeting today in Churchdown to look at the thoughts for new builds ,we were specifically interested in thoughts/plans that would effect us in the Churchdown area.\nWe would like to make a few points\n1-Churchdown already had an enormous number of new builds and we wonder if the village can support any more\n2-?Can our local surgery take on any more patients,we are aware of the fact that it is already extremely hard to get care in a timely manner,what plans will be put in place tomanage current new builds and proposals for future builds.\n3-The roads in the village are in an appalling state and already suffering from the increased traffic from new builds,I shudder to think how even more traffic will effect them\n4-The schools in churchdown are already at capacity where will children be expected to go if there are any more new builds.\n5-there is talk about building next to the motorway,I am concerned about pollution effecting the homes and knock on potential environment issues.\nWe do appreciate this is the start of a very long plan but would appreciate you considering the above points."]
["Statutory/Specific Consultee","Brookthorpe with Whaddon Parish Council","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","The Brookthorpe-with-Whaddon Parish Council opposes the selection of the Whaddon as a site for either a new settlement or urban extension in the Strategic and Local Plan. The evidence submitted to the Inspectors in the Examination of the Draft Stroud Local Plan and the comments lodged with the planning application 23/2428/OUT show that the site is both unsound in planning terms and received only adverse responses from local residents. \n\nA. Local Opposition - Opposition to the planning application to Stroud District Council by Taylor Wimpey 23/2428/0UT has been almost universal. The comments made to that planning application come mainly from residents in Tuffley who complain about likely traffic congestion caused by the number of houses to be built on the site and also the lack of local facilities  to support up to 3,000 houses there. No comments in support of the application have been made. The application is regarded as being premature as the site does not have adequate infrastructure. Previously, in the cases of similar proposed urban extensions in Abbeymead/Abbeydale and Quedgeley/Hardwick new infrastucture was provided in the form of Metz Way and the new Hempsted route. The Whaddon site has to be accessed from Gloucester by the Stroud Road or minor roads from it and residents in Tuffley and neighbouring areas complain that the road system cannot cope with all the additional traffic that the site would generate. Until proper road infrastructure is built the Whaddon site is not sustainable. As well as those comments to the planning application opposition was also expressed by local residents at a public meeting at St. Barnabas Church on the 26th November when Richard Graham MP and both Tuffley City and County Councillors expressed their decisions to contest the proposal. \n\nB. Accessibility and Infrastructure Evidence was supplied to the Inspection of the emerging Stroud Local Plan that the Whaddon site has the worst accessibility score of any of the 450 + sites within the Stroud District area.  This is caused by the lack of crossings over the railway line, with the distance between the Naas Lane underbridge and the Grange Road underbridge being 1.3 miles approximately. Without solutions to the accessibility issues the site is not sustainable and the transport plans lodged by Taylor Wimpey in their planning application have not been approved by the County Council. The County Highways Manager gave evidence to the Inspectors at the EiP that the only solution to the accessibility issues was one which was not acceptable to mass house builders, namely a low traffic neighbour. Taylor Wimpey, who have options on the majority of the site, will not agree to a scheme which prevent car ownership and cars will be available to every housing unit they build. Their preferred solution for traffic congestion on Stroud Road and St. Barnabas is not supported by the County, Gloucester City, or Active Travel England. \n\nC. St. Barnabas - Although solutions to the traffic congestion at St. Barnabas have been suggested, none have the support of the County Council or offer a solution to the long-term traffic congestion which will be caused by a new Whaddon settlement. The emerging Stroud Local Plan suggested in their Traffic Forecasting Report and Addendum that mitigation at St. Barnabas could be provided by adding extra lanes to each of the four major roads to the roundabout but that is not supported by the County. They say that just providing more capacity is not the solution and neither is the traffic light scheme proposed by Taylor Wimpey. Traffic lights might improve current congestion, but will not mitigate the extra traffic generated by the Whaddon G2 site. There is also evidence in a Statement of Common Ground between the County and Travel Planning Associates that additional provision for pedestrian and cycling priorities at St. Barnabas will only cause the lengthening of queues. The proposal to partially close the entrance to Reservoir Road has resulted in opposition from residence. Therefore, there are no workable proposals to resolve the congestion issues at St. Barnabas and until housing developers accept the need to reduce car use then Whaddon will always create unacceptable levels of congestion on the routes into the City. \n\nD. The SRN and J 12 - The emerging Stroud Local Plan has had its Examination placed on pause, mainly for the reason that the Inspectors are concerned about the impact on the M5 with J12 and J14 being seen as congested and in need of upgrading. The Inspectors have suggested that the Local Plan may have to be withdrawn if solutions for the upgrades of the motorway junctions are not found before the EiP is completed. There is therefore the possibility that the proposed site allocations including Whaddon in the Stroud plan may have to be removed. There is evidence from National Highways, as well as the County Council, that Whaddon G2 impacts J12 and the pending application by Taylor Wimpey will be made subject to a holding declaration by National Highways as in the case of Hardwicke G1 and Grove Lane, Whitminster. The County have estimated the projected cost of junction upgrades at up to £400 million for J12 with a time estimate of about 15 years based on past projects on the M5. This could mean that the Inspectors may decide that the Draft Stroud Local Plan cannot be sound or that the delay in delivering the upgrades will prevent housing allocations being built by the imposition of Grampian conditions by Highways England. Unless Whaddon can be shown to be sound at the emerging Local Plan Inspection it should not be selected as a preferred site. \n\nE. Naas Lane - The Naas Lane underbridge is inadequate to serve a new community at Whaddon , and is regarded by the County Council, Active Travel England, and the Ramblers Association as being unsafe. The underbridge was built as a farm access at the time of the construction of the railway and is unable to safely take pedestrian and cycle traffic while sharing the same road space with other vehicle users on the road. The County Council has said that the existing level crossing should be used in preference to the underbridge. The developers have not agreed to any new crossings over the railway line and insist that the underbridge be used with a virtual pavement. This has been suggested by Taylor Wimpey without carrying out traffic modelling on Naas Lane while at the same time Stagecoach have made written submissions suggesting Naas Lane should be closed to through traffic. \n\nF. Active Travel - Active Travel England have lodged a letter of objection to the planning application by Taylor Wimpey saying that the Masterplan offered by the developers does not contain adequate provision for pedestrian, cycling, and wheeling movements within the site and on the wider road network. The Whaddon G2 site does not lend itself for good active travel access into Gloucester with a lack of safe cycling routes despite current planning policy that it should be a primary consideration in new developments. The existing routes into Gloucester for cycling, wheeling and walking are congested, inadequate, or unsafe. \n\nG. Traffic Impacts - Evidence agreed between the County Council and the developers' consultants have confirmed the extra traffic impacts affecting both the main road and minor roads , including Firwood Drive, Epney Road and Upton Lane within increases in traffic flows of up to 44%. The extra traffic on the A4173 generated by the G2 scheme has been described by the County's Highway Manager as \" phenomenal \" and the likely congestion impacts at St. Barnabas and the wider network as \" severe \". Those impacts are to be felt also in Brookthorpe village, Upton Lane, and Haresfield Lane with Brookthorpe being shown in the Traffic Forecasting Report as been one of the three most congested roads in the Stroud Local Plan near Whaddon even after mitigation. Insufficient or no mitigation has been offered by the proposed developers for Brookthorpe and Whaddon villages and the surrounding road network stretching to Upton St. Leonards and Haresfield. Without proper mitigation, the site is not sustainable. \n\nH. Public Transport - At the moment the Whaddon site is served only by the Stroud 62 and 63 buses with a half hour service in each case. The proposal by the developers is to route those services through the site along with a further new orbital bus service from Kingsway but all three bus services will approach Gloucester along the Stroud Road to St. Barnabas.  It is inevitable that the congestion at St. Barnabas will create delays with those bus services and increase the queueing length stretching back to Whaddon. Although another route has been proposed by Stagecoach in Firwood Drive, the current Masterplan show it will only be used by the existing number 9 service from Tuffley.  There can be no double-decker bus services to the West under the railway line because of the height restrictions in all three under bridges. This will therefore increase the number of orbital buses using Naas Lane and the route through the development. Despite a requirement from Stroud District Council for a bus route to Grange Road through the Tuffley Farm site in G2 no agreement has been reached with the promoters there and at the present time all buses will be using the route through a Modal Hub onto Stroud Road. \n\nI. ​ The Modal Hub - The Whaddon G2 relies on a Modal Hub being provided in order to provide transport alternatives to the car and to improve sustainability. The location for this has been chosen by the developers as being next to St. Margaret's Church which is a Grade II * listed building. That has received an objection from Historic England who say that unacceptable adverse impacts will be caused and the location also offends a draft policy from Stroud District Council in that it should not be within 250 ms of the Church. Further, the whole concept of a park and ride is doubtful in view of the experience at Quedgeley where the 450 space car parking scheme is hardly used and is effectively redundant. People prefer to use their cars and Whaddon G2 could produce over 3,500 cars at a ration of 1.22:1 for 3,000 houses. Until a new planning strategy is applied to reduce car numbers, traffic congestion in and around Whaddon and Tuffley would reach unacceptable levels with a site allocation for mass housing. The public responses to the pending planning application show that this is the main concern with residents."]
["Statutory/Specific Consultee","Environmental Health Cheltenham Borough Council","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","An early comment regarding Air Quality in the SLP: \nNO2 vs PM2.5 \nTraffic is not necessarily the main cause of air pollution.  It depends which pollutant you measure.  If you measure nitrogen dioxide (NO2) it mostly comes out the back of vehicles, and mostly diesels.  (That’s the case in the 3 districts, anyway).  The levels of NO2 are falling across the country for a number of reasons, but basically engines are getting cleaner and vehicles with dirty old engines are getting scrapped.  By the time this plan is finished and adopted there will be no locations in CBC or TBC that breach current legal limits for NO2.  There may still be one or two tiny areas in GCC that breach the limit, so they will have to declare an Air Quality Management Area for each, and do a whole lot of paperwork and planning for DEFRA. \n\nBUT:  If you measure particulates, AKA: airborne dust, smoke, or PM2.5s it’s a different story.  These do come out the back of cars, and the levels produced by road traffic engines are dropping.  But they are also produced by tyre wear, so are still produced by electric vehicles due to brake and tyre wear.  The other main sources of PM2.5 are domestic burning of solid fuels, and agriculture.  We have never had the specific proportions modelled for us here, but it is likely to be in the region of one-third each from road vehicles, domestic combustion and agriculture.  We at CBC are considerably ahead of the rest of the county in monitoring PM2.5 levels, and we are finding that across the town, levels are around the government’s target of 10ug/m3.  Some areas may be worse than that, and “over the limit”.  The situation is likely to be similar in GCC and TBC. \n\nDEFRA, who set national strategy, are starting to focus more on PM2.5 than on NO2.  In due course, local authorities will have to do the same.  That means taking action to reduce PM2.5 emissions from things within our control IE domestic combustion.  We are currently trying to extend our smoke control zone to cover the whole borough, although that is taking some time.  We have also been given new powers to enforce domestic smoke emissions by serving a fixed penalty notice, which we are likely to publicise and start using in time for next winter.  There are other campaigns relating to agricultural use of manures which will be of more relevance to other authorities. \n\nSo, if there is opportunity to build in steps to control PM2.5 emissions in the SLP, we should take the opportunity. "]
["Resident",null,"","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Hello We really don’t know if this is the correct way to reply but we are emailing to give views as requested about the Strategic and Local Plan (SLP). We have given our views as to where we believe future developments should take place i.e. priority should be given to a ‘new garden town’ somewhere in the Cheltenham/Gloucester/Tewkesbury area or more affordable development in rural villages where housing is badly needed, especially for young people in order to keep them in these villages to do the essential work there....or a \"mix\" of these two different scenarios. We emphasise that Leckhampton, South Cheltenham, towards Shurdington and beyond, is alongside one of the busiest and most congested main entrances to Cheltenham.  Now that permission has been given for the 360 Miller Homes development on the A46 Shurdington Road, next to Kidnappers Lane, it would be a disaster for any more development to take place along the A46 Shurdington Road towards Shurdington village, and beyond, towards Brockworth.  The Leckhampton to Shurdington village area has taken much more than its share of development, the infrastructure to support it being almost non-existent, let alone all the extra traffic this latest additional 360 Miller Homes site will generate.....a new roundabout is soon to be built on the A46 Shurdington Road which we are sure will cause traffic chaos for a number of months, even years, and the existing residents (us) will have to travel through the new estate – all a terrible upheaval for probably years !  At the Miller Homes appeal hearing last summer, it was argued that the sheer number of houses should be reduced, given how many are already being built in Leckhampton and so ease the likely traffic pressure and preserve a bit more valuable green space.  At present 377 Redrow (now Barratt Redrow) dwellings are being built, along with the other local developments of Kendrick and Newlands Homes and now the latest 360 Miller Homes development....not forgetting the huge Leckhampton High School (LHS) that was completed very recently.  Therefore a new development on the Brizen Farm fields would saturate the area and no doubt cause traffic chaos in the Leckhampton to Shurdington area for an eternity. I am forwarding emails that were sent for the past two attempts to build on Brizen Farm, both attempts being refused by the Tewkesbury Planners without going to their Planning Committee.  Nothing has changed except that far more development has taken place in Leckhampton, the Brizen Farm fields being right next to all this on the A46. We hope you will take this email, with all its detail, into consideration before recommending any future development in this part of Cheltenham which has already been saturated. Regards Gerry and Jacky Potter. PS  Further emails to follow regarding previous objections to building on the Brizen Farm fields."]
["","GE  Aerospace Ltd","","","","","GE Aerospace Ltd generally support the draft vision as set out on page 13 of the consultation document in terms of achieving sustainable growth for the area's needs. However, the vision should acknowledge that the location of growth areas are most appropriately located where people can live, work and access the countryside, and all such factors should be considered together when identifying suitable growth areas. This means that new residential areas should consider proximity to existing and proposed employment areas, local service centres and places for recreation. By applying this approach we contend that this site (discussed above) which is surplus to GE Aerospace Ltd requirements would be an appropriate residential site as it is in close proximity to an existing and growing employment site (GE Aerospace Ltd and Furlong Business Park) as well as the service centre of Bishops Cleeve, both within walking distance. Development of the site could also create public open space and provide connections into the countryside. We suggest that additional wording is added to the fourth paragraph of the Draft Vision to address this point (underlining denotes suggested additional text): \"Growth in sustainable locations will have enabled the provision of healthy, accessible and walkable neighbourhoods, the promotion of active travel and sustainable travel, and provision of new transport systems that work for local people. Such growth will focus on residential and employment areas in compatible and cohesive locations to enable people to have sustainable access to employment and living opportunities and enable places to thrive.\"","","","","","","No","","","","","","","It is acknowledged in both the SLP consultation document and the Gloucestershire Local Housing Needs Assessment (September 2020) that the Standard Method for assessing local housing needs provides a minimum starting point in determining the number of homes needed in an area. Additionally the National Planning Policy Guidance (PPG) states that \"It does not attempt to predict the impact that future government policies, changing economic circumstances or other factors might have on demographic behaviour. Therefore there will be circumstances where it is appropriate to consider whether actual housing need is higher than the standard method indicates.\" (Reference: National Planning Practice Guidance: Biodiversity Net Gain Paragraph 006 Reference ID: 74-006-20240214). We note that the exceptional circumstances test in the NPPF is narrow in its scope and is therefore a high bar to reach. However, the LPA's should, through the evidence base, explore alternative scenarios for housing growth which consider whether demographic trends and market signals could result in a higher housing need figure which should be used in the SLP. This should consider whether an employment-led scenario and jobs growth would result in the need for a higher housing need figure. Notwithstanding the above, GE Aerospace Ltd support the presentation of the housing need figure as a minimum and encourage the LPA's to explore any alternative assessments that would constitute an \"exceptional circumstance\" in accordance with the PPG. We encourage further evidence to be prepared to inform the next stage of the SLP.","","","","","","","","","","","","","","","","","","","","Section 6 of the SLP sets out six different development scenarios summarising approaches to the distribution of growth throughout the plan period. Paragraph 6.7 of the consultation document notes that the six development scenarios have been informed by site opportunities currently being promoted to the Council's for development, to understand the geographical spread. Whilst the development scenario diagrams within pages 35 - 48 identify the locations of the three main settlements of Gloucester, Cheltenham and Tewkesbury, it is difficult to ascertain where the growth is proposed in scenarios 3, 4 and 5. It is assumed that further sites received through this consultation will also contribute to further refinement of the approach to spatial growth. We agree with the notion of paragraph 6.8 where it is understood that none of the scenarios would, on their own, deliver sustainable development, and that the final strategy will be a combination of different elements in order to meet housing and employment targets over the plan period. Question 29: Which of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? In assessing the development scenarios, and in response to Question 29, we primarily support Scenario 2 as an appropriate approach for development growth in the SLP. We agree that delivering development as urban extensions to key urban areas, including sites within the Green Belt, will enable the Joint Authorities to meet their housing and economic needs in full, where they might not otherwise be able to due to a lack of available land supply outside of the Green Belt. These settlements are encompassed by the Green Belt and therefore to utilise existing sustainability credentials, land will need to be released in some locations to meet the full housing and employment need. Scenario 2 however should also consider larger rural service centres, such as Bishops Cleeve, alongside the three main settlements of Gloucester, Cheltenham and Tewkesbury, which is also sustainable and well connected to those settlements. The GE Aerospace Ltd site, adjacent to the settlement of Bishops Cleeve, is considered to be an appropriate site to provide a suitable urban extension. In reviewing the existing shape of the Bishop's Cleeve settlement, and the sites' adjacency to residential areas in the north and east and local employment, we contend that a residential-led scheme on this site would serve as an appropriate extension that visually and spatially completes the settlement. Development of this site would mean that housing is delivered in a sustainable location, and reduces the likelihood of unnecessary travel and allowing it to be accessed from existing infrastructure. The site has scope to provide for a range of housing types, sizes and tenures to contribute to Tewkesbury in meeting its housing need in full. Due to the size of the site it is capable of accommodating social infrastructure as required such as a primary school and local centre, benefitting Bishops Cleeve as a whole. We acknowledge that the site is located within the Green Belt and that the Local Planning Authorities will be undertaking an updated Green Belt Assessment to identify suitable areas for release through the SLP process as set out in NPPF paragraph 144. The NPPF sets out in paragraph 143 that the Green Belt serves five purposes. We have considered the GE Aerospace Ltd site in relation to these 5 purposes and provide our assessment in Table 2 below how the site performs against the five purposes of the Green Belt. Table 2 - The Five Purposes of the Green Belt Purpose Contribution of the site to the purpose a) To check the unrestricted sprawl of large built-up areas. b) To prevent neighbouring towns merging into one another. c) To assist in safeguarding the countryside from encroachment. d) To preserve the setting and special character of historic towns. e) To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Due to the adjacency of the site to the existing settlement, and the shape of the existing residential area, development of the site would serve as an appropriate urban extension. It would effectively 'round off' the settlement by appropriately filling in the gap between the residential area north of Stoke Orchard Road and the employment area south and west of the A435. Bishop's Cleeve is not considered to be a large built-up area due to its scale. Development of the site would not result in Bishop's Cleeve merging into another settlement due to it being buffered from Tewkesbury to the west and Cheltenham to the south by further agricultural land. Development of the site would not result in the encroachment of the countryside due to the significant amount of other parcels of agricultural land surrounding the site that would remain. As per point a) the release of this land would is not encroachment as spatially it would 'round off' the settlement. Whilst the heart of Bishop's Cleeve's origins are historic, the area has since seen modern residential expansion. Consequently, an urban extension through Green Belt release would not impact on the historic character of Bishop's Cleeve or any other nearby settlements. The brownfield land registers identify that there is a lack of large scale brownfield sites across the area, with the exception of a small number of sites within Gloucester. As a small proportion of the land is within the urban area, Green Belt and greenfield land will inevitably need to be considered for development. In the Joint Core Strategy Green Belt Assessment (2011), the site falls within Green Belt segment NE16 which is identified as making a significant contribution to Green Belt purposes. Consequently, it states that the area does not merit further consideration for release from the Green Belt at this stage unless other elements of the evidence base strongly suggest otherwise. However, this segment considered a wider area of land than which we are suggesting be released. Secondly, this assessment is now out of date having been prepared in 2011 and it is likely that the context of the Green Belt parcels assessed have changed over time. We therefore recommend that an updated and refined assessment is undertaken for the parcels of land around the existing settlements which could realistically be released and brought forward for development, such as the assessment carried out in Table 2. In terms of landscape, the Landscape Characterisation Assessment and Sensitivity Analysis (2013), identifies the site within a larger area - Area C18: Court Farm to Orchard Farm - which is identified as having a low to medium to low sensitivity. This considers that the land has been particularly degraded by association with industrial form and loss of hedge boundaries and therefore the development of this site is unlikely to result in a loss of high quality landscape. Aligned with an updated Green Belt Assessment as asserted above, the approach to growth scenarios should also consider allocating sites as sustainable urban extensions to those areas which are not assessed as having a high landscape sensitivity. Currently, Tewkesbury Borough Council cannot demonstrate a five year supply of deliverable housing land and is falling significantly short at 3.24 years. A recent appeal decision (Planning Inspectorate Reference APP/G1630/W/23/3326538) stated that the Council acknowledges that they will be reliant on releasing greenfield sites to meet the need. Whilst this was not a Green Belt site, it nonetheless raises the issue that there is insufficient brownfield land to meet the housing need for a 5 year period. If a 5 year housing land supply cannot be demonstrated, then it is subsequently likely that insufficient brownfield land can be identified for the whole plan period therefore highlighting the need to release greenfield and Green Belt sites for allocation in the Plan. Land to the east of the SLP area (i.e. east of Cheltenham, Bishop's Cleeve and Tewkesbury) is within the Cotswolds National Landscape Area (formerly the Cotswolds AONB) which limits the availability of appropriate sites for development. Those sites which have previously been submitted to the HELAA have been assessed as being not developable owing to their location within the Cotswolds National Landscape Area. Therefore Green Belt sites outside of the AONB will need to be released for development in order to meet the housing and employment need for the area. We note that Scenario 5 focuses on growth around the Rural Service Centres. Bishops Cleeve is currently classified as a Rural Service Centre in the Tewkesbury Borough Plan 2011-2031. Whilst we consider that Bishops Cleeve is of an appropriate size to accommodate a sustainable urban extension as set out in Scenario 2, as a Rural Service Village, it could also be considered appropriate for growth under Scenario 5. This Scenario should acknowledge that there will be areas of Green Belt around the rural service villages and appropriate release should be supported where sustainable growth could be achieved, such as around Bishops Cleeve. A combined approach of Scenario 2 and 5 could therefore lead to comprehensively planned development meeting the needs of all three authorities' areas.","","","","[Q8.] Whilst we appreciate the aspiration to seek to deliver more than the mandatory minimum of 10% Biodiversity Net Gain ('BNG') through development, we would caution creating a policy in the SLP which specifies a higher figure. A higher requirement could affect the deliverability of greenfield sites and could subsequently make sites unviable or result in lower S106 contributions. It is important to note that each site will likely have its own unique baseline and therefore the ability to achieve more than a 10% BNG will vary depending on a site by site basis. The requirement in the legislation sets the 10% as a minimum figure, and it is therefore possible for Applicants to achieve a higher amount of gain where there is opportunity. We consider that the legislative requirement is therefore sufficient to achieve the minimum biodiversity gains in the area. The National Planning Practice Guidance states that Plan-makes should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area wide basis or for specific allocations for development unless justified. The guidance says that to justify such policies they will need to provide evidence including the local need for a higher percentage, local opportunities and any impacts on viability for development. and we would encourage the 3 LPA's to undertake this if progressed.\n\n[Q29.] Section 6 of the SLP sets out six different development scenarios summarising approaches to the distribution of growth throughout the plan period. Paragraph 6.7 of the consultation document notes that the six development scenarios have been informed by site opportunities currently being promoted to the Council's for development, to understand the geographical spread. Whilst the development scenario diagrams within pages 35 - 48 identify the locations of the three main settlements of Gloucester, Cheltenham and Tewkesbury, it is difficult to ascertain where the growth is proposed in scenarios 3, 4 and 5. It is assumed that further sites received through this consultation will also contribute to further refinement of the approach to spatial growth. We agree with the notion of paragraph 6.8 where it is understood that none of the scenarios would, on their own, deliver sustainable development, and that the final strategy will be a combination of different elements in order to meet housing and employment targets over the plan period. Question 29: Which of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? In assessing the development scenarios, and in response to Question 29, we primarily support Scenario 2 as an appropriate approach for development growth in the SLP. We agree that delivering development as urban extensions to key urban areas, including sites within the Green Belt, will enable the Joint Authorities to meet their housing and economic needs in full, where they might not otherwise be able to due to a lack of available land supply outside of the Green Belt. These settlements are encompassed by the Green Belt and therefore to utilise existing sustainability credentials, land will need to be released in some locations to meet the full housing and employment need. Scenario 2 however should also consider larger rural service centres, such as Bishops Cleeve, alongside the three main settlements of Gloucester, Cheltenham and Tewkesbury, which is also sustainable and well connected to those settlements. The GE Aerospace Ltd site, adjacent to the settlement of Bishops Cleeve, is considered to be an appropriate site to provide a suitable urban extension. In reviewing the existing shape of the Bishop's Cleeve settlement, and the sites' adjacency to residential areas in the north and east and local employment, we contend that a residential-led scheme on this site would serve as an appropriate extension that visually and spatially completes the settlement. Development of this site would mean that housing is delivered in a sustainable location, and reduces the likelihood of unnecessary travel and allowing it to be accessed from existing infrastructure. The site has scope to provide for a range of housing types, sizes and tenures to contribute to Tewkesbury in meeting its housing need in full. Due to the size of the site it is capable of accommodating social infrastructure as required such as a primary school and local centre, benefitting Bishops Cleeve as a whole. We acknowledge that the site is located within the Green Belt and that the Local Planning Authorities will be undertaking an updated Green Belt Assessment to identify suitable areas for release through the SLP process as set out in NPPF paragraph 144. The NPPF sets out in paragraph 143 that the Green Belt serves five purposes. We have considered the GE Aerospace Ltd site in relation to these 5 purposes and provide our assessment in Table 2 below how the site performs against the five purposes of the Green Belt. Table 2 - The Five Purposes of the Green Belt Purpose Contribution of the site to the purpose a) To check the unrestricted sprawl of large built-up areas. b) To prevent neighbouring towns merging into one another. c) To assist in safeguarding the countryside from encroachment. d) To preserve the setting and special character of historic towns. e) To assist in urban regeneration, by encouraging the recycling of derelict and other urban land. Due to the adjacency of the site to the existing settlement, and the shape of the existing residential area, development of the site would serve as an appropriate urban extension. It would effectively 'round off' the settlement by appropriately filling in the gap between the residential area north of Stoke Orchard Road and the employment area south and west of the A435. Bishop's Cleeve is not considered to be a large built-up area due to its scale. Development of the site would not result in Bishop's Cleeve merging into another settlement due to it being buffered from Tewkesbury to the west and Cheltenham to the south by further agricultural land. Development of the site would not result in the encroachment of the countryside due to the significant amount of other parcels of agricultural land surrounding the site that would remain. As per point a) the release of this land would is not encroachment as spatially it would 'round off' the settlement. Whilst the heart of Bishop's Cleeve's origins are historic, the area has since seen modern residential expansion. Consequently, an urban extension through Green Belt release would not impact on the historic character of Bishop's Cleeve or any other nearby settlements. The brownfield land registers identify that there is a lack of large scale brownfield sites across the area, with the exception of a small number of sites within Gloucester. As a small proportion of the land is within the urban area, Green Belt and greenfield land will inevitably need to be considered for development. In the Joint Core Strategy Green Belt Assessment (2011), the site falls within Green Belt segment NE16 which is identified as making a significant contribution to Green Belt purposes. Consequently, it states that the area does not merit further consideration for release from the Green Belt at this stage unless other elements of the evidence base strongly suggest otherwise. However, this segment considered a wider area of land than which we are suggesting be released. Secondly, this assessment is now out of date having been prepared in 2011 and it is likely that the context of the Green Belt parcels assessed have changed over time. We therefore recommend that an updated and refined assessment is undertaken for the parcels of land around the existing settlements which could realistically be released and brought forward for development, such as the assessment carried out in Table 2. In terms of landscape, the Landscape Characterisation Assessment and Sensitivity Analysis (2013), identifies the site within a larger area - Area C18: Court Farm to Orchard Farm - which is identified as having a low to medium to low sensitivity. This considers that the land has been particularly degraded by association with industrial form and loss of hedge boundaries and therefore the development of this site is unlikely to result in a loss of high quality landscape. Aligned with an updated Green Belt Assessment as asserted above, the approach to growth scenarios should also consider allocating sites as sustainable urban extensions to those areas which are not assessed as having a high landscape sensitivity. Currently, Tewkesbury Borough Council cannot demonstrate a five year supply of deliverable housing land and is falling significantly short at 3.24 years. A recent appeal decision (Planning Inspectorate Reference APP/G1630/W/23/3326538) stated that the Council acknowledges that they will be reliant on releasing greenfield sites to meet the need. Whilst this was not a Green Belt site, it nonetheless raises the issue that there is insufficient brownfield land to meet the housing need for a 5 year period. If a 5 year housing land supply cannot be demonstrated, then it is subsequently likely that insufficient brownfield land can be identified for the whole plan period therefore highlighting the need to release greenfield and Green Belt sites for allocation in the Plan. Land to the east of the SLP area (i.e. east of Cheltenham, Bishop's Cleeve and Tewkesbury) is within the Cotswolds National Landscape Area (formerly the Cotswolds AONB) which limits the availability of appropriate sites for development. Those sites which have previously been submitted to the HELAA have been assessed as being not developable owing to their location within the Cotswolds National Landscape Area. Therefore Green Belt sites outside of the AONB will need to be released for development in order to meet the housing and employment need for the area. We note that Scenario 5 focuses on growth around the Rural Service Centres. Bishops Cleeve is currently classified as a Rural Service Centre in the Tewkesbury Borough Plan 2011-2031. Whilst we consider that Bishops Cleeve is of an appropriate size to accommodate a sustainable urban extension as set out in Scenario 2, as a Rural Service Village, it could also be considered appropriate for growth under Scenario 5. This Scenario should acknowledge that there will be areas of Green Belt around the rural service villages and appropriate release should be supported where sustainable growth could be achieved, such as around Bishops Cleeve. A combined approach of Scenario 2 and 5 could therefore lead to comprehensively planned development meeting the needs of all three authorities' areas.\n\n[Summary] Land surplus to GE Aerospace Ltd requirements can be made available for development over the plan period and is considered to be appropriate for promotion for residential led development. The site provides 43ha of land to the north west of GE Aerospace Ltd's main campus and would need to be released from the Green Belt via the Local Plan process to come forward. In terms of the growth scenarios, it is asserted that Scenario 2 would be an appropriate option subject to including the larger rural settlement of Bishops Cleeve as also suitable for sustainable urban extensions. Scenario 5 should also be considered alongside Scenario 2 providing that it is acknowledged that Green Belt release could be included. I would be grateful if you could keep me updated going forward, including when the responses are published. GE Aerospace Ltd is willing and committed to working with the LPA's in growing their established business within the region and is keen to meet with Officers and Members to discuss the opportunity provided by their surplus land around Bishops Cleeve further. Should you have any queries with the above, then please do not hesitate to contact me or my colleagues Simon Phillips, Director (Simon.Phillips@cbre.com) or Lydia Faizey, Assistant Planner (Lydia.Faizey@cbre.com)."]
["Planning agent or developer","SF Planning","","","","","","","","By incentivising schemes which can demonstrate measures to combat climate change or future proof developments. This may include schemes to encourage walking and cycling, net zero homes.","","","","","Our client has submitted two sites to the call for sites consultation – Land at Bentham and land at Little Shurdington. Both would be ideal for biodiversity net gain as detailed in that submission.","Policy could be drafted to support developments which meet certain criteria such as being within a specified travelling time of at least 3 services on foot or public transport. Note that this shouldn’t mean development outside of settlements offering the level of services outlined in the policy would be refused. The policy should be permissive.\nSome of the criteria could include;\n•employment area(s) offering 500+ jobs;\n•secondary school\n•Allotment\n•Bank\n•Café / other food outlet\n•Community hall\n•Dentist\n•Further education\n•GP surgery or pharmacy\n•Hospital\n•Leisure centre\n•Library\n•Nursery / pre-school\n•Place of worship\n•Play area or sports field\n•Post office\n•Primary school\n•Pub\n•Public open space\n•Town centre, supermarket or convenience store selling fresh food.\n\nThis means that as settlements grow and evolve and bring with them new developments (and potentially new services as a result) the policy can still be applicable rather than becoming out of date. This avoids the potential issue created by designating specific villages as service villages as was done with the JCS and means that a similar policy can apply consistently across the SLP area to any location which perhaps does not have a long list of services in the immediate location, but which has a good regular public transport service to a location which does.","","","","Yes, there do not appear to be any exceptional circumstances to justify not using the standard method. That said, the Council should consider separate clear requirements for open market housing alternatives such as self build.","","","","A self-build policy should be included in the SLP which could read along the lines of the following;\nProposals for self or custom build sites immediately adjacent to existing settlements will normally be permitted where they\n1. Help to meet demand as demonstrated by Part 1 of the council’s Self and Custom Housebuilding Register and\n2. Do not constitute major development\n3. Will be occupied by someone with a local connection\n4. Can demonstrate ongoing involvement of the intended occupier in the design and planning process\n5. Are not on land at risk of flooding\nUnless there are clear reasons not to permit the development such as green belt or landscape designations which cannot be overcome.\nIn the event that houses approved under this policy have been actively marketed for self/custom build for at least 12 months; and an application is then made to the Council to sell the self build dwellings on the open market, such application will be approved provided that\ni)prior to the application being made they have been offered to the council, a housing association or the town/parish council for the delivery of affordable housing products.\nii)Evidence of 12 months marketing is provided to the Council with the application","","","","","","","","","","","See response to Q10. The question isn’t as simple as just looking at how many services a rural settlement has. Account should be taken of the ability to easily access services via footpaths, cycle paths and public transport too. A settlement could have no services whatsoever but could be on an excellent public transport route with a relatively short journey time to a larger settlement. This should still be considered acceptable.","","","","","Our client considers the following growth scenarios can be acceptable;\na)\nurban extensions (scenario 2) - The strategy of allocating urban extensions (of varying sizes) around the existing towns can be an ideal and sustainable approach to distributing housing, particularly in terms of meeting local housing need.\nb)\nThe Rural Dispersal scenario (5) can also be appropriate. However, this scenario advocates for development at the smallest of hamlets.\nThere does not appear to be a scenario which directs growth to locations which have access to a base level of facilities such as those outlined in response to Q10 above (whether or not that is a small village with good transport links or a larger villages with more services in the village itself).\nWe agree that scenario 5 can help to support thriving communities by supporting shops services and facilities and with the other pros identified in relation to this scenario.\nIn terms of the cons for scenario 5, we do not consider it is ‘likely’ that the character and setting of existing settlements will be harmed by development in more rural locations. Much will depend on the scale and size of the development and, more critically, how it is designed.\nAlso, policies which incentivise certain types of housing which are needed (including self-build) could overcome some of the more significant\nperceived impacts of the reduced ability to provide a full range of housing sizes, types and tenures.\nWe are not aware of any rural services or facilities which would experience undue pressure as a result of a small amount of additional housing in the vicinity.\nc)\nScenario 6 – sustainable transport\nThe approach makes sense from a carbon emissions perspective but is limited as some focus on development around proposed road network enhancements would be acceptable.","Scenario 2: Urban extensions; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","",""]
["Planning agent or developer","Land owners","","","","","","","","","","","","","","","","","","","","","","G/T needs will be assessed by an up-to-date GTAA. \nSuch assessment, and policy based thereon, needs to take account of ethnic groups (e.g., Romany Gypsys) and not just those who accord with the current PPTS definition of G/T. \n(Note: the Court of Appeal Lisa Smith decision- [2022] EWCA Civ 1391) ",""," No.(Travellers sites as part of large development) Such polices are considered unlikely to be successful. The SLP team may wish to review the success/failure rate of such polices in other Development Plans. Criteria based polices are likely to be more appropriate. The expansion of existing G/T sites either by making best use of land on existing sites, or on adjoining land should be a primary consideration. The importance of family sites should not be overlooked. There is a high unmet need for G/T and ethnic Gypsy in the SLP area, and in TBC in particular. Like general housing needs, the specific needs of this group have not been met for many years. There is a serious lack of supply and sufficient land has not been made available through past/current Development Plans."," Good access to education and healthcare and to other services and facilities should be a high priority.\nGood access to the primary road network is advantageous. ","","","","","","","","","","","","","","","",""," There is a high unmet need for G/T and ethnic Gypsy in the SLP area, and in TBC in particular. Like general housing needs, the specific needs of this group have not been met for many years. There is a serious lack of supply and sufficient land has not been made available through past/current Development Plans."]
["Other","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","These are my comments in response to Question 31 of the questionnaire.  I hope the format of a simple email is acceptable.\n\nMy comments refer to the TBC HELAA MAP, specifically to SOU006, 007 and 008:\nPlanning policy should not be to the detriment of landscape with historic and environmental importance which has been hitherto consistently recognized and protected in planning and related documents. For this reason, I wish to question the categorisation of these sites as ‘potentially developable’.\n\n1. Both looking down and looking up, the sweeping panoramic view of the Cotswolds, with Cleeve Hill – the highest point of the Cotswolds and of Gloucestershire as a whole – at its centre, is consistently described as ‘breathtaking’.  It is known nationally and internationally and is seen regularly as part of Channel 4’s racing coverage. The view is enjoyed by the many regular users of Cleeve Hill: the walkers, dog-walkers and riders and also by rock-climbers and hang-gliding enthusiasts.  The three sites suggested for development are an integral part of this view.  They are central to it.  SOU006 and 007 in particular are on rising land but all are visible whether looking down from the Cleeve Hill viewpoint or looking up from the A435 driving past the racecourse coming out of Cheltenham.  Development on these sites would significantly interrupt and intersect what is recognized and appreciated as an iconic view.  \n\n2. All three sites form part of the green segments between Prestbury and Bishop’s Cleeve/ Woodmancote.  The importance of maintaining and protecting the separation of these areas in times of development has been consistently recognized and respected in local planning decisions.\nThe development suggested on the HELAA map would constitute a huge encroachment on these segments in both directions and would completely fly in the face of previous planning attitudes and apparently accepted priorities.\n\n3. The sites are situated in Green Belt or designated Special Landscape Area (SLA) or both and adjoin AONB.  In August 2017 an appeal for a development of 76 houses on the edge of Prestbury (the Gleeson site) was dismissed (Appeal Ref. APP/G1630/W/16/3165534). In the planning inspector’s report considerable weight is given to the relevance of SLA as one of the factors considered in his decision to dismiss the appeal.  The SLA in Southam – only about a mile away - is at least as relevant and valuable to the AONB and character of the landscape as it is in Prestbury.  To allow development that would involve rescinding the designation of the SLA in this neighbouring, and equally valid, location, would not only seem hypocritical and cynical but it would also deprive both the Green Belt and AONB of vital transitional landscape. \n\n4. My connections with Prestbury go back to the mid-1980s and I have been resident in Southam since 2004.  Southam did not flood in 2007 only because the surrounding fields provide Southam’s natural flood defences.  This is particularly true of the relationship of SOU006 to the lower part of Ratcliff Lawns.  Removing these vital facilities would place existing housing currently not at any risk of flooding at every likelihood of that eventuality.  Is that really an acceptable part of planning strategy?  Surface water is also an increasingly regular problem on Southam Lane between the 40mph limit when leaving Southam and the railway bridge.  This often crosses the width of the road in some depth and residual splashes remain for some days.  Housing development would only exacerbate the present problems. The fields need to be retained in their entirety.\n\n5.  Southam Lane – which is a residential road - has become a heavily used cut-through, at times under stress, sometimes unable to cope.  It has no capacity to absorb the increase in traffic which development would produce.  \n\n6.  Southam is a small village and, in estate-agent speak, it is ‘semi-rural’.  In addition to causing unacceptable harm to the landscape, the impact of the blanket development identified in the SLP would double the village in size, deprive it of all character, have detrimental implications of noise and pollution, and would change the nature and quality of the life it offers unrecognizably and irrevocably.  In addition to the increased use of Southam Lane, the impact of development would be felt dramatically by the lower part of Ratcliff Lawns.  This is an unadopted road with 37 houses but it offers the only access to SOU006.  Currently it offers children a place to play and is used as a safe thoroughfare by walkers, runners, cyclists, dog-walkers and horse-riders.  If development of SOU006 were approved, this road, like the rest of the village, would be changed beyond recognition. \n\n7.  An approach that simply identifies spaces on a map, uses a standard formula to calculate the number of houses that might be accommodated within the area and then drops these figures onto the location without taking into account the nature of the surrounding environment or the impact on any existing established community does not make for good planning, good strategy or, ultimately, successful development.\n"]
["","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","I’d like to submit some feedback for the SLP 2024. I strongly believe that the Chargrove triangle should be an area protected for nature and recreation - any development for urban extensions should avoid the greenbelt.\nI think the greenbelt in Cheltenham and Gloucester should remain unchanged, it is one of the smallest in England and any erosion of the existing greenbelt leads to urban sprawl; the merging of Tewkesbury, Cheltenham and Gloucester should be avoided, and greenbelt helps to do that, as well as providing an area of peace and wellbeing for local residents, and a haven for local wildlife.\n\nI sincerely hope you remove the Chargrove area from the plan.\n"]
["Planning agent or developer","Pye Homes Blenheim ","","","","","","","","","","","","","","","","","Yes"," The Strategic and Local Plan (SLP) should use the local annual housing need from the \nstandard method (SM LHN), as a starting point in identifying the housing requirement. The \nNPPF (para 61) confirms that the local needs assessment should be conducted using the \nSH LHN, unless exceptional circumstances exist to use a different method. No such \nevidence is presented in the consultation document or the evidence base to justify a \ndeparture from the SM.\nHowever, the PPG (ID 2a-010-20201216) confirms that, in using the SM LHN, a higher \nhousing need figure can be identified, for example with reference to economic\ncircumstances and infrastructure improvements. Hence, unless exceptional circumstances \nexist, the LHN must address both the SM LHN as the baseline need – starting point, as \nwell as the Council’s aspiration to meet the growth priorities, as set out in the Draft Vision\nand Strategic Objectives at the beginning of the consultation document. \nThis assessment of need must take place, “prior to, and separate from, considering how \nmuch of the overall need can be accommodated”, through this stepped process, these \nfactors can then be translated into a housing requirement figure to be addressed within \nthe strategic policies, and housing allocations made, in the plan.\nThe SLP consultation document sets out a housing needs figure for the three areas of \nTewksbury Borough, Gloucester City and Cheltenham; the table after paragraph 5.16 \nidentifies this based on the SM LHN. The SM LHA for the Cheltenham Borough is for 547 \ndwellings per annum, which translates into 10,940 dwellings across the forthcoming plan \nperiod.\nWhile it is understood that the current evidence base (including the Gloucestershire Local \nhousing Needs Assessment (2020) and the Gloucester Economics Needs Assessment \n(2020)) forecast only modest growth for the period up to 2041, these documents plus the \nunderlying assumptions are of some antiquity, prepared in a time prior to the global \npandemic and Brexit. \nWe note from the SLP consultation document that the councils acknowledge this to be the \ncase and intends to renew the evidence base to inform the direction of policy. It is \nconsidered that the current evidence base is not sufficiently robust to justify a departure \nfrom the SM LHN, as the starting point, at the present time.\nHowever, in looking at the affordable need in the district, the Local Housing Needs \nAssessment (ORS September 2020) (LHNA) indicates that there is a significant \nmisalignment between affordable need in Cheltenham and provision, including the scale \nof provision likely to be achieved under the SM LHN. Affordable need as a percentage of \nthe SM LHN is highest of all the Gloucestershire authorities. Hence, additional housing \nprovision, through a higher housing requirement (subject to capacity within the borough) \nwould be significantly beneficial, particularly when acknowledging that small sites and \nprior approvals will not secure affordable homes. The LHNA acknowledges this, as \nfollows:\n“However, as the LHN itself already incorporates a significant uplift beyond the \nhousehold projection-based housing need, a further uplift to market housing is likely \nto prove difficult to sustain; so it may be more appropriate to consider any uplift \nbeing identified as additional supply to provide flexibility within the plan rather than \nincreasing the housing requirement and associated target.”\nThe LHNA concludes that there is no justification to increase the housing need on the \nbasis of economic growth. Whilst, there may be an alignment in the projected growth in \njobs and the SM LHN, the age of the area is increasing significantly Hence, it cannot be \nassumed that there will be sufficient housing to meet the needs of the economically active \npopulation. Further, it is notable that the ‘no uplift necessary’ position is based on no \nchange to the existing levels of in-commuting (for jobs) into the area. Providing a greater \nlevel of affordable housing through increased supply, could reduce the level of incommuting to create a more sustainable, self-contained, area. This approach would also \nassist in addressing the challenges of climate change. \nThese factors should be further considered, and in doing so are likely to confirm that \nmaximizing the supply of housing across the plan period, whether through an increase to \nthe housing requirement, or allocation of a surplus of sites to meet that requirement and \nprovide flexibility (as recommended in the LHNA), is fully justified. In the absence of such \nan approach the Vision and Strategic Objectives will not be positively addressed, and the \nplan will be unsound. ",""," There are no constraints identified in the evidence base to justify a reduced housing \nrequirement for Cheltenham Borough relative to the SM LHN. There are sites sustainably \nlocated on the edge of settlements, particularly on the northern edge of Cheltenham, that \nare unconstrained and could deliver housing without compromising the purposes of the \nGreen Belt. One such site is ‘land at Apple Close’. Specifically such extensions would not \nclose, or even reduce the minimum width of, the gap between Cheltenham and Bishops \nCleeve. Their well-planned development, would not represent unacceptable \nencroachment into the countryside or unrestricted sprawl, particularly given the ability to \nprovide revised but still strong Green Belt boundaries. Their development would preserve \nthe setting of Cheltenham, with respect to which we would highlight that, the opportunities \nfor increased urban capacity within the town are severely restricted due to the historic and \nspecial character of the core of the settlement, as demonstrated by recent appeals – even \nwith respect to an allocated site (APP/B1605/W/23/3316744). In this respect it is apparent \nthat even when making as much possible use of suitable brownfield land, urban capacity, \nand optimising development densities (NPPF paragraph 146), in the interests of meeting \nthe presumption in favour of sustainable development, and achieving a sustainable \npattern of growth in the Borough, Green Belt release must be made, there are exceptional \ncircumstances to do so. \nIn this context, it is notable that the SM LHA for the Cheltenham Borough is for 547 \ndwellings per annum, which translates to 10,940 dwellings across the forthcoming plan \nperiod. The Housing and Economic Land Availability Assessment (HELAA) (December \n2023) identifies 50 sites across Cheltenham Borough considered ‘deliverable’,\n‘developable’ or ‘potentially developable’, capable of providing more than 18,000 homes \nas part of mixed use or wholly residential schemes.\nThe identified sites capable of delivering most new housing development are concentrated \ntowards the fringe of the urban area, on account of the fact that the more central areas of \nthe town comprise 599 hectares of conservation area and accommodate over 2,602 listed \nbuildings. The town centre and more central urban areas have a poor track record of \nincreasing housing land supply, because of these factors and even from sites allocated in \nthe development plan, as referenced above.\nOverall, it is evident that some Green Belt release will be necessary to deliver on the \nSLP’s Draft Vision and Strategic Objectives, specifically ensuring that the right amount of \nland for homes and employment is identified to meet the needs across the timeframe of \nthe plan, and to address affordability.\nIt is acknowledged that the NPPF states that there is no requirement to review Green Belt \nboundaries when local plans are being prepared, and authorities may choose to do so \nwhere exceptional circumstances are fully evidenced and justified (NPPF para 145). \nHowever, in reality, to achieve the plan objectives, and given the NPPF focus on achieving \nsustainable development, delivering a sufficient supply of housing, securing a sustainable \npattern of development, and building a strong, competitive, economy, there is no option in \nCheltenham Borough but to review Green Belt boundaries to accommodate housing.\nTo reconfirm, exceptional circumstances do exist to review Green Belt boundaries along \nthe northern edge of Cheltenham to accommodate the SM LHN plus any uplift \nappropriate. \nAs referenced under Q12, an uplift would be justified to further redress affordability \n(beyond provisions made through the SM, and application of the affordability ratio) and \nsecure an alignment of economic growth and homes for the economically active \npopulation, particularly given the expectation that a growing number of homes within the \nBorough will be occupied by older non-economically active residents. ","Yes"," The Local Housing Needs Assessment (LHNA) forecasts that 9,800 new households will \nbe formed in the Cheltenham Borough during the forthcoming plan period, most of which \nwill be in their twenties and thirties at the time they form. Given the expectation that many \nof the growing number of older households will continue to occupy their existing homes, it \nwill generate a need for wide range of market housing types, specifically including 3 and \n4-bedroom family homes.\nCheltenham has an affordable housing need of 1,510 dwellings across the forthcoming \nplan period, the highest level of need across all of the Gloucestershire authorities when \nconsidered as a proportion of the LHN (38%). In response, there is a significant need for \n2-bedroom housing in affordable tenures, although also a considerable need to provide a \ncomparable number of larger affordable homes (4+ bedrooms).\nIt is therefore clear that a reliable supply of housing sites within and on the edge of the \nexisting urban areas, the latter to deliver family housing, will be required in the borough to \ndeliver the homes needed for the forthcoming plan period. One such site being ‘land at \nApple Close, Cheltenham’.","","","","","","","","","","","","","","","Yes"," Whilst Scenario 1 ‘Urban Concentration’ would preserve the Green Belt in its current form, \nthere would be no associated opportunity to improve public access to the Green Belt, or to \nprovide quality, publicly accessible, open space at scale. \nWith respect to Scenario 2 ‘Urban Extensions’ we note the limited number of cons, also \ntheir characterisation as ‘potential’, and agree that this is a strong option whereby the cons \ncan be mitigated through careful site selection and master planning. \nUnder Scenario 3 ‘Urban Extensions Excluding Green Belt’, the diagram highlights the risk \nthat this scenario focuses development towards areas that are more environmentally \nsensitive, and constrained. Whilst Green Belt policy has been an effective planning tool, it \nis not an environmental designation per se. This should be listed under the cons.\nThe Scenario 4 option ‘New Strategic Settlement’ proposes to meet development needs\nthrough the provision of one or more comprehensive, master-planned new settlements, of \na minimum of around 4,000 new homes, with supporting infrastructure. It is considered \nthat full reliance on new planned settlements to deliver the required new homes and \neconomic growth would be a high-risk strategy, both in terms of timely delivery (as \nacknowledged under the cons) but also in terms of the ability to provide a mix of sites,\nparticularly when compared to the alternative scenario 2 spatial strategy ‘Urban \nExtensions’ which would allow timely delivery, and for that delivery to be distributed across \na wider range of site types and sizes (strategic sites and smaller, more immediate, sites). \nThe NPPF (paragraph 70) recognises the importance of small and medium sized sites in \ncontributing towards meeting the housing requirement of an area, as they can are often \nbuilt-out relatively quickly when compared to much larger sites or new planned \nsettlements.\nWith respect to scenario 6 ‘Sustainable Transport’, we see no benefit or advantage of this \noption over scenario 2, if the sites are carefully selected. As shown by the diagram, the \nstrategy could lead to longer journeys and focus development not only in the Green Belt \nbut towards more environmentally sensitive areas. This should be acknowledged under \nthe cons.","Scenario 2: Urban extensions","","","[Q29] It is considered that Development Scenario 2 (Urban Extensions) is the spatial option most likely to meet the draft Vision and Strategic Objectives for Cheltenham Borough based upon the available evidence. This scenario includes the release of Green Belt around the urban fringe to meet growth needs, in accordance with the requirement to secure a sustainable pattern of development. Further, and as highlighted under our response to Q13, such extensions need not close, or even reduce the minimum width of, the gap between Cheltenham and Bishops Cleeve. Careful site-selection, and theirwellplanned development, would not represent unacceptable encroachment into the countryside or unrestricted sprawl, particularly given the ability to provide revised but still strong Green Belt boundaries based on existing landscape features. Their development would preserve the setting of Cheltenham, with respect to which we would highlight that, the opportunities for increased urban capacity within the town are severely restricted due to the historic and special character of the core of the settlement.\nA finer grain Green Belt Assessment and careful site selection would reconfirm this position, noting that previous Green Belt assessments, and consideration of Green Belt constraint (through the former Joint Core Strategy work) has identified significant potential on the northern edge of the settlement, without affecting the strongly performing Green Belt (see below and attached for further details on Apple Close).\nThe SM LHA for the Cheltenham Borough is for 547 dwellings per annum, which translates to 10,940 dwellings across the forthcoming plan period. The HELAA (2023) identifies 50 sites across the Cheltenham borough considered ‘deliverable’, ‘developable’or ‘potentially developable’ the majority of which are located away from the urban centre and towards the urban fringe. \nThis approach would ensure that the full range of housing typologies identified in the Gloucestershire Local Housing Needs Assessment (GLHNA) for Cheltenham can be met within the forthcoming plan period. There are significant benefits in allocating strategic sites and smaller sites in confirming a five-year housing land supply on adoption of the plan and ensuring a rolling housing land supply throughout the plan period. Providing flexibility in the plan, noting the difficulties of securing a sufficient five-year housing land supply in Cheltenham Borough, is fundamental to the effectiveness of the plan.\nAside from housing delivery, the Sustainability Appraisal (December 2023) scores Scenario 2 relatively highly for biodiversity, climate change and education, reflecting that the range of available development sites available and the ability of these to deliver wide ranging infrastructure and facilities proximate to the existing urban areas.\nIn contrast, the available evidence suggests that Scenario 1 (Urban Concentration) would fail to meet the draft Vision and Strategic Objectives for Cheltenham Borough. The constrained nature of the existing urban areas (599 hectares of conservation area and nearly 3,000 listed buildings), the absence in the range of available housing sites and the past difficulties of delivery from sites from within the existing urban area means that Scenario 1 cannot be relied upon to deliver the level of growth sought by the SLP.\nThe difficulties of delivering housing from the existing urban area in the Cheltenham Borough is acknowledged and can is clearly demonstrated by the repeated failure of the allocated site “Land off Oakhurst Rise” to deliver new homes within the existing urban area. This site has been the subject of three dismissed appeals, in 2019, 2021 and 2023. The first two planning appeal (ref APP/B1605/W/19/3227293 and APP/B1605/W/20/3261154) were dismissed on the basis that they would cause significant harm to the setting of several listed buildings (Ashley Manor and Charlton Manor) which was considered to outweigh the benefits of the appeal schemes despite the delivery of much needed market and affordable homes and lack of a five year housing land supply. This same site was subject to an appeal scheme (ref APP/B1605/W/23/3316744) for 25 dwellings which was dismissed in November 2023.\nDevelopment Scenario 2 (Urban Extensions) is the spatial option most likely to meet the draft Vision and Strategic Objectives for Cheltenham Borough based upon the available evidence.\n\nCheltenham Borough: Land at Apple Close, Cheltenham\nParagraph 6.14 of the consultation document invites the submission of additional, new or \nupdated information on sites already submitted to the council.\nPye Homes Blenheim and The Jockey Club have interests in land at Apple Close, \nCheltenham. This site is identified in the HELAA (2023) as “land off New Barn Lane 3 \n(South of Racecourse)” with the reference “S017”. \nWhilst the assessment of the site in the HELAA (Cheltenham BC HELAA) considers this \nsite to be “potentially developable”, including the comments that it is “potentially available”, \nwe can confirm that the site is being actively promoted, and is available and deliverable for \nhousing (subject to Green Belt release). We can also confirm that there is the ability to \nprovide an appropriate site access, as identified in the accompanying vision document. \nThe Vision document, is relied on with respect to our Reg 18 representations to confirm \nthat exceptional circumstances do exist for the release of this ‘Apple Close’ site for the \ndevelopment of family homes, in a sustainable location, to help meet the requirements for \nthe provision of small – medium sized sites. \nWe acknowledge that the Joint Core Strategy Green Belt Assessment (GBA), published in \n2011, forms part of the evidence base for the current Joint Core Strategy (2017) and \nidentifies the site within a much larger parcel of land with a ‘significant’ contribution to the \nGreen Belt. However, this is a high-level assessment on how strategic segments of the \nGreen Belt perform against each of the purposes set out in paragraph 143 of the NPPF. \nThe promoted site is located within an extensive strategic segment (NE22), spreading \nacross half of the distance between Cheltenham and Bishops Cleeve and Cheltenham \nRacecourse. Whilst the GBA considers that, as a whole, segment NE22 makes a \nsignificant contribution to the Green Belt purposes, it is clear that small areas of the \nparcel, on the edge of Cheltenham, do not perform in the same way. \nAs evidence to this, the site, which is sandwiched between the existing urban edge of \nCheltenham and the racecourse, scored low in terms of is performance and effectiveness \nagainst Green Belt purposes in a locally focused assessment conducted in 2007; the\nCheltenham Green Belt Review (2007). This finer gain assessment can be relied upon, \nthe purposes of the Green Belt having not changed since that time, and there having been \nvery little change to the character and components of the urban fringe in the location of \nthe site over the last 15 years. \nIt is further notable that, whilst the GBA is informative, in making Green Belt release, the \nNPPF does not require a sequential approach that releases poorly performing Green Belt \nahead of strongly performing Green Belt. For obvious reasons, instead, it requires the \npromotion of sustainable patterns of development and the definition of clear boundaries, \namong other matters (NPPF paragraphs 147 & 148).\nIt is considered that exceptional circumstances exist for the release of Apple Close from \nthe Green Belt, with the ability to contribute to Scenario 2 and achieve a strong and more \nlogical landscape response and defensible boundary.\nWe submit for the Council’s consideration the Vision Document demonstrating the \nsuitability of the site for residential development to assist with meeting the SLP’s Draft \nVision and Strategic Objectives, specifically ensuring that the right amount of land for \nhomes is identified to meet the needs across the timeframe of the emerging plan."]
["Local Councillor","Quedgeley Town Council","","Future proofing of housing ie possible extension as families expand.  All services in conduit to allow for change, if solar not fitted, roofs should be robust enough to have retro fit.","","Yes","A good base to work from.","Yes","","","Should be as energy efficient as possible.  Outside living space, gardens should be considered more.  Garages should be made to fit modern car sizes and charging.  It should be considered that people will still have cars and space allowed to accommodate this.  Recent builds have shown roads, pavements and POS will be used to park vehicles with all the subsequent problems as people will have vehicles.","","","","","Schools, health facilities, retail, outside spaces, youth services, play areas, sports provision.","","","","","","","","","","","","","","","","","Layout the transport links at the start of the development, (roads, pedestrian & cycles paths, bus routes).  These should be fixed and not (tweaked) for additional housing.  Dedicated site set for schools, health facilities and retail prior to any homes and not to be amended for other use.  All services should be in place prior to final build, houses should be the last item to be put in place. ","","","Yes","","","","","","","","Facilities for young people should also be considered when developing areas.  Sch as youth centres.  Too often the layout facilitates the very young but not the young adults leading to local problems."]
["Resident","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","We were alerted to the proposals re. the above, and the opportunity to comment, by our good neighbour Rob Whiteoak - see. below. \n\nWe are aware of a previous large-scale proposal re. White House Farm, circulating a few years ago, that didn't appear to proceed but was very concerning in its proposed scale and proximity to Brookfield Road. \n\nThis proposal appears to be equally worrying in its proposed scale, and its proximity to local roads and public pathways/footpaths, and likely severe impact on them and on general views and local ambience and wildlife. \n\nWe strongly agree with Rob Whiteoak's comments, and in particular the likely strong adverse impact on traffic on Brookfield Road and on local essential services, including the local Medical Centre on Parton Road. \n\nThe air quality on Brookfield Road is regularly noticeably poor/polluted during the morning and evening peak travel times. This proposal would likely massively add to that pollution. \n\nIn view of all the other recent housing developments in and around Churchdown, some still ongoing, we consider this proposal to be both very unwise and clearly reckless, in being extremely likely to drastically change the character and pleasantness of this attractive part of Churchdown, not to mention the impact on local facilities and key services. \n"]
["Planning agent or developer","Gladman","","","","","","","","It is acknowledged that the planning system has an important role to play in tackling the \neffects of climate change. In this respect, the overarching environmental objective of \nsustainable development cited in paragraph 8 of the National Planning Policy Framework \nhighlights how the planning system should help to mitigate and adapt to climate change \nand support the transition to a low carbon economy.\nThis objective filters through to other elements of the Framework, including Section 14 that \ndeals specifically with Meeting the Challenge of Climate Change. In this regard, paragraph \n152 of the Framework identifies how the planning system should:\n“support the transition to a low carbon future in a changing climate, taking full account \nof flood risk and coastal change. It should help to: shape places in ways that contribute \nto radical reductions in greenhouse gas emissions, minimise vulnerability and improve \nresilience; encourage the reuse of existing resources, including the conversion of existing \nbuildings; and support renewable and low carbon energy and associated infrastructure”\nGladman therefore recognise the increasing importance of tackling climate change and \nencourage sustainable housing developments to mitigate its impact. The Council should \ncontinue to take account of climate change in its plan-making, including any updates to \nguidance to the Framework and PPG. It is important to recognise that mitigating and \nadapting to climate change must also be compatible with other important objectives for \nthe planning system, including the requirement to boost housing delivery and build a \nstrong, competitive economy."," Whilst we agree that there is a need to act to reduce carbon emissions through the \nconstruction and operation of new buildings, we would suggest that this should not be \nundertaken through local plan policies given that there is already a national approach, the \nFuture Homes Standard, being taken forward to achieve the same goal. Delivering these \nimprovements through building regulations has a distinct advantage over delivering a \nvariety of different approach across the county in that it provides a single approach that all \nSLP Issues and Options Consultation \n5\ndevelopers understand and can be rolled out at scale. This allows supply chains and skills to \nbe improved prior to implementation and ensure that improvements to building standards \nare actually deliverable from the point at which they are introduced.","","","","","","","","","  The NPPF requires the standard method to be used unless exceptional circumstances justify \nan alternative approach. In our view there are no exceptional circumstances which would \nwarrant a different approach than the standard method being used as the starting point for \nconsidering the housing requirements for the Cheltenham, Gloucester and Tewkesbury \nSLP. \nThe Government has made it clear that it still supports the national target of 300,000 new \nhomes per year. The standard method housing requirement has always been only the \nstarting point for setting the housing requirement in a Plan. \nSLP Issues and Options Consultation \n6\nPara 61 of the newly revised (Dec 2023) NPPF says that “to determine the minimum number \nof homes needed, strategic policies should be informed by a local housing need assessment, \nconducted using the standard method in national planning guidance. The outcome of the \nstandard method is an advisory starting-point for establishing a housing requirement for \nthe area”. Para 67 states that “The requirement may be higher than the identified housing \nneed if, for example, it includes provision for neighbouring areas, or reflects growth \nambitions linked to economic development or infrastructure investment.”\nGladman strongly support the need for more housing in the SLP for a variety of reasons \nincluding addressing the current housing crisis, meeting housing need, providing affordable \nhousing and to support employment growth. Gladman would request that the Councils\nfully consider all of the issues when determining the housing requirement and recognise \nthat this may result in a need for a higher housing requirement.","No","Gladman do not consider there to be any reasons why the number of houses to be actually planned for should be less than the minimum number of homes calculated using the standard methodology. For the reasons set out above there may in fact be strong justification to increase the housing requirement of the SLP and this should be carefully considered when progressing the SLP","","","","","","","","","","","","","","","","","","","","","","[Introduction] Gladman Developments Ltd (Gladman) welcome the opportunity to comment on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan Issues and Options \nconsultation and request to be updated on future consultations and the progress of the Local Plan. \nGladman specialise in the promotion of strategic land for residential development and associated community infrastructure and have considerable experience in contributing to the development plan preparation process having made representations on numerous planning documents throughout the UK alongside participating in many Examinations in Public.\nGladman have land interests within the plan area, land to the south of Tewkesbury. The Councils are aware of our long-standing interest in this land as we seek to promote proposals through the Strategic Plan for a residential led allocation. A site submission has been included in Section 3 of these representations and we would appreciate the opportunity to discuss these proposals further with the Councils in due course. \nThe Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (SLP) Issues and Options consultations marks a significant stage of the production of the review of the Joint Core Strategy (JCS), which commenced upon adoption of the of the JCS in December 2017. \nPlan making has subsequently continued with the individual local authorities progressing to adoption Part 2 plans, however these documents were not the appropriate platform to \nreconsider the strategic issues around overall housing delivery in the plan area. Getting an up to date strategic plan that facilitates the delivery of much needed new housing is critical in the context of a national housing crisis. Gladman welcome this significant stage and are keen to work with the Councils moving forward.\nOur response deals with seven of the thirty-one questions posed and sets out how the land interest we are promoting to the south of Tewkesbury aligns with the Councils overall vision and strategic objectives, two of the six scenarios or spatial options proposed for Sustainable Urban Extensions (“SUEs”), whilst supporting Tewkesbury’s role and function within the region as a priority location for growth.\n\n[Q1.] Noting the intention to submit the SLP to the Secretary of State for examination in 2026, Gladman suggest that it may be prudent to ensure that there is sufficient time in the plan period from the outset to account for any slippage in these timescales and the fact that on average it takes 18 months for a Local Plan to be adopted from submission. It is therefore considered highly optimistic to be planning until 2041 and to ensure flexibility in these timescales adding 2 to 3 years to the plan period from the outset even before the development strategy is determined would be sensible.\n\n[Q8.] Recognising that the Environment Act sets the 10% as a minimum and Government statements indicate that Councils can go further in local plans, this needs to be justified that there is both a need togo beyond 10% and that this requirement will not, when considered in combination with other policies impact on the deliverability of the local plan. \nThe Councils must recognise that delivering statutory net gains is still in its infancy and as such there is great uncertainty as to the most effective way of delivering BNG, the cost of delivering 10% net gain, and whether there will be sufficient local offsite credits in the short and medium term to support schemes that cannot deliver a 10% gain on site.\nThe Councils must also be clear as to ecological reasons why development would be required to deliver a higher level of net gain than the statutory minimum. A 10% net gain will ensure that development leaves more biodiversity than was previously the case.\n\n[Infrastructure] A critical part of any Local Plan is ensuring the timely delivery of infrastructure to facilitate development. Gladman are willing to contribute towards necessary infrastructure requirements, whether that be through on-site delivery or offsite contributions. A combination of a number of the strategy options will ensure that the delivery of necessary infrastructure occurs when it is needed and so that housing delivery is not delayed, both within the short and long-term.\n\n[Q29.] The consultation document presents six varying development scenarios, these are as follows: The six different development scenarios tested at this stage are:\n1. Urban concentration\n2. Urban extensions\n3. Urban extensions, avoiding the Green Belt\n4. New strategic settlements\n5. Rural dispersal\n6. Sustainable transport\nNo one scenario will likely deliver the full housing needs and it is likely that a combination of the varying scenarios will be required to maximise housing delivery and in a timely nature, recognising the existing housing delivery issues of the plan area.\nIn allocating sites, the Council should be mindful that to maximize 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. \nThe maximum delivery is achieved not just because there are more sales outlets but because the widest possible range of products and locations are available to meet the widest possible range of demand. In summary 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.\nThe development proposal Gladman are promoting, land to the south of Tewkesbury is considered to meet the criteria for an urban extension, outside of the greenbelt and therefore fits well within two of the six development scenarios being considered. Whilst not being directly identified within this scenario, we would also say the allocation of this site would accord with development along sustainable transport corridors. This is because the A38 is a key public transport corridor with high frequency public transport services between Tewkesbury, Cheltenham and Gloucester. \nIn any combined development scenario, we suggest that land south of Tewkesbury is a strong contender for allocation and can play a significant role in meeting the Councils developments needs within the region over the short and long term. We would welcome further discussion with the Councils in this regard. We have included further detail of our proposals in the section that follows.\n\n[Summary] Gladman welcomes the opportunity to comment on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan Issues and Options. These representations have been drafted with reference to the revised National Planning Policy Framework (NPPF 2023) and the associated Planning Practice Guidance. \nGladman have provided comments on a number of the issues that have been identified in the Council’s consultation material and recommend that the matters raised are carefully explored during the next stage of plan-preparation to ensure the Local Plan meets the tests of soundness set out in the NPPF. \nGladman have land interests within the plan area, land to the south of Tewkesbury. The Councils are aware of our long-standing interest in this land as we seek to promote proposals through the Strategic Plan for a residential led allocation. A site submission has been included in Section 3 ofthese representations along with an interactive and illustrative StoryMap, and an indicative concept plan showing how the site could be delivered whilst delivering a range of significant benefits that align with the overall vision and strategic objectives. We would appreciate the opportunity to discuss these proposals further with the Councils in due course.\nWe hope you have found these representations informative and useful towards the preparation of the emerging Strategic and Local Plan and Gladman welcome any future engagement with the Councils."]
["I work for a charity or volunteer in the area","Active Gloucestershire","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","",""," In reference to the strategic local plan that is being carried out regarding Hardwick Green in St Pauls.\n\nI believe it's important that the area be kept as a green space to benefit local residents. Though bordering Pittville Park there is limited green space within St Pauls itself and losing this area for local residents would be a negative for the ward."]
["Statutory/Specific Consultee","Gloucestershire County Council","","","","","","","","Ensuring all future housing development is located where people will have a genuine option to walk and cycle to access daily services (food shop, primary school, open space, community facility, GP) and facilities and conveniently use public transport to access employment and for longer trips, either because those services and facilities exist already or because it is realistic and feasible that they can provided permanently as a result of the scale of the development proposed. \nEnsuring all employment and other development including retail can be accessed by the majority of its catchment within an hour’s whole journey time by public transport or by easily cyclable journeys along LTN 1/20 compliant cycle facilities such as the Gloucestershire cycle spine.","","","","","","For residential development the services which should be within easy c800m walking and cycling distance should as an absolute minimum be those facilities which people use daily/several times a week which should include a food shop, park or green space including play facilities, indoor meeting space, a primary school. For a genuinely walkable / cycle-able community a post office or bank and GP surgery and other facilities important to local communities should also be included.\nA bus stop should be within 400m (from individual front doors for both residential and employment development) of all significant development served by an express bus service with 4 buses per hour in urban areas and 2 buses per hour in rural areas. These should be existing bus services or services where the frequency can be increased or the service extended through development funding to deliver a financially viable service. All other development should be within 400 m of a bus stop that has at least 1 bus per hour.","","","","","","","","","","","","","","","","","It is important that the need for major new highway works are minimised as far as possible. This should be achieved through locating development where there is a genuine choice of using active modes access daily services and facilities and public transport to access destinations further afield such as the main town/city centres, employment and higher/further education.  \nA programme of bus priority is being developed as part of the development of the Expressbus /Mass Rapid Transit work. The delivery of bus priority along corridors serving major development will be critical.\nLTN 1/20 compliant cycle infrastructure should provide complete connections to all key destinations within cycling distance.\nHealthy streets should be provided which support walking and cycling by people of all ages and abilities and also include measures including SUDs and trees planting to manage drainage impacts and encourage biodiversity.  \nHaving first considered opportunities for active and sustainable modes, the development of strategic and local highway infrastructure which addresses both capacity and safety issues exacerbated or caused by proposed development.","The same measures for Q23 are generally applicable for Q24.\nWhilst new strategic settlement offers opportunities for sustainable travel, the planning of infrastructure required to enable a large strategic development is inherently complex. Whilst careful master-planning (considering links between housing with local jobs and amenities) is essential to maximise “containment” of trips, it is also critical to consider interactions with the existing transport network – particularly where there are opportunities to link with and enhance existing or planned public transport provision to prevent reliance on the private car for longer-distance trips. From this perspective, reviewing potential alignment with the Gloucestershire BSIP is very important – establishing the feasibility of bus services which could form part of the express bus network (or an extended part of it) with a frequency of 4 buses per hour, bus stops within 400m of all dwellings or business premises). \nIn some circumstances, given the scale of development it likely inevitable that new highway infrastructure will be required to allow development to come forward. However, where this is identified, careful scrutiny is needed to ensure this will complement and facilitate more sustainable transport options by resolving existing vehicle movement conflicts (e.g. strategic movements versus local movements) as well as capacity and safety issues.\n\"Of the three options, more is known about the issues related to the Tewkesbury Garden Town. Specific comments in relation to this strategic settlement are as follows:\n•\tThe consultation document notes that 'major improvements to Junction 9 (M5)' may be required to address existing pressures on the Strategic Road Network and provide additional road capacity to enable development. In addition, the previous section identified options for urban extensions at Tewkesbury, which although not named include potential locations to the north, east and south of Tewkesbury. (The location to the north of Tewkesbury appears to relate to the Mitton strategic site proposed in the South Worcestershire Development Plan review which is currently at the examination stage.)\nA co-ordinated approach is essential for the planning of transport infrastructure required to enable development at Tewkesbury / Ashchurch (whether this is in the form of urban extensions or new strategic settlement of combination of the two, and including development in the Mitton / Bredon Road area). \n•\tIn addition to addressing capacity constraints on the Strategic Road Network (M5 Junction 9 and A46), an overall plan or strategy should identify requirements for upgrades to the local road network and sustainable travel infrastructure. This must address the requirements for east-west movements across the M5 between Tewkesbury and Ashchurch that will be generated by new development and the current reliance on the A46 / A438 corridor passing though M5 Junction 9 for most of these journeys. While upgrades to the transport infrastructure along the A46/A438 including M5 Junction 9 may be feasible, further increases to traffic flows on this corridor may not be sustainable, noting the proximity of Junction 9 to schools (including Tewkesbury Academy) and existing residential areas along the A438 (Newtown) and A46 (Ashchurch). \n•\tThe overall plan for new development in the Tewkesbury / Ashchurch area should also include suitable provision for employment opportunities that are aligned with future market needs and provide for locations and forms of development that integrate with existing communities and future housing development locations and facilitate sustainable travel for commuting to workplaces. New employment sites that result in significant increases in traffic using the Strategic Road Network may not be sustainable, even allowing for major improvements at M5 Junction 9, due to potential impacts on operation and safety of the M5 and A46.\n•\tDiscussions between GCC and National Highways, Department for Transport and DLUHC clearly identify the link between a government funded upgrade to M5 Junction 9 and the A46 and the Tewkesbury Garden Town (Community), and it is essential to the case for the infrastructure that the Garden Town concept (10,000+ homes and employment land) is clearly laid out in the SLP.  This provides the important policy ‘hook’ that Government requires in the emerging development plan, to enable progression of the infrastructure through the business case process.\""," As noted in point 5 of the documentation review section of this response; there are notable concerns regarding the potential for this option to perform well from a sustainable transport perspective where there is an absence of any quality sustainable transport provision as well as jobs and a range of local amenities. The viability of new services is likely to be low – unless clear links to a wider sustainable transport strategy can be demonstrated. ","","","","No","•\tUrban Concentration: \nThe reason for the disadvantage stated “Increased journey lengths as housing and economic growth diverted to alternative locations outside of the SLP area” is potentially misleading. It is accepted that there will likely be an insufficient number of sites to meet the housing and jobs requirements for the SLP area – but individually the sites that fall within urban concentration are likely to perform well from a sustainable transport perspective (supporting use of bus and rail, walking, cycling and car clubs as stated in the advantages).\n•\tUrban Extensions/Urban Extensions avoiding Green Belt: \nThe assumption that there will be stronger existing public transport services or better access to local amenities may not be universally true. Only urban extensions which are on or adjacent to a high frequency corridor (circa 4 buses per hour) and where development could be within a suitable walking distance will genuinely offer sustainable transport choices. \n•\tNew Strategic Settlement: \nThe complexity of delivering sustainable transport infrastructure (and ensuring this connects to the wider network) in areas where there is currently a lack of provision should be recognised. Careful planning is required to consider how the trajectory of large housing delivery in a single area accords with new infrastructure as well the delivery of nearby jobs and amenities – to avoid the potential for a high number of long-distance car trips in a localised area which could have severe impacts on the local and strategic road networks. \n•\tRural Dispersal: \nStrongly agree with the listed disadvantage: “Unlikely to support existing or new public transport, leading to greater dependency on the private car and road congestion, particularly for travel to larger built-up areas.”","","","","[Q29.] The Broad Site Assessment alone does not provide a clear enough picture at present to determine which development scenario is most appropriate from a sustainable transport perspective. There is also likely to be substantial variation regarding the suitability of different sites that fall into the same scenario. As such clear evidence for individual sites needs to be presented – to help justify their inclusion or exclusion based on transport grounds.\nFrom GCC’s perspective, the need to quantifiably assess different sites and spatial options as a whole in terms of the level of vehicle kilometres and associated carbon emissions is a key factor in being able to determine suitability for sites.\nIn broad terms, clearly urban concentration would be expected to offer good opportunities in being able to rely on existing sustainable transport provision (where there is good accessibility and sustainable mode shares are already comparatively high). But is acknowledged this scenario alone will not be sufficient to meet growth targets. \n\nThe option of a 'new strategic settlement' at Tewkesbury (Garden Town) is identified and noted that 'major improvements to Junction 9 (M5)' may be required to address existing pressures on the Strategic Road Network and provide additional road capacity to enable development. In addition, the previous section identified options for urban extensions at Tewkesbury, which although not named include potential locations to the north, east and south of Tewkesbury. (The location to the north of Tewkesbury appears to relate to the Mitton strategic site proposed in the South Worcestershire Development Plan review which is currently at the examination stage.)\nA co-ordinated approach is essential for the planning of transport infrastructure required to enable development at Tewkesbury / Ashchurch (whether this is in the form of urban extensions or new strategic settlement of combination of the two, and including development in the Mitton / Bredon Road area). In addition to addressing capacity constraints on the Strategic Road Network (M5 Junction 9 and A46), an overall plan or strategy should identify requirements for upgrades to the local road network and  sustainable travel infrastructure. This must address the requirements for east-west movements across the M5 between Tewkesbury and Ashchurch that will be generated by new development and the current reliance on the A46 / A438 corridor passing though M5 Junction 9 for most of these journeys. While upgrades to the transport infrastructure along the A46/A438 including M5 Junction 9 may be feasible, further increases to traffic flows on this corridor may not be sustainable, noting the proximity of Junction 9 to schools (including Tewkesbury Academy) and impacts on residential areas along the A438 (Newtown) and A46 (Ashchurch). \nThe overall plan for new development in the Tewkesbury / Ashchurch area should also include suitable provision for employment opportunities that are aligned with future market needs and provide for locations and forms of development that integrate with existing communities and future housing development locations and facilitate sustainable travel for commuting to workplaces. New employment sites that result in significant increases in traffic using the Strategic Road Network may not be sustainable, even allowing for major improvements at M5 Junction 9, due to potential impacts on operation and safety of the M5 and A46.\nGovernment funding for major improvements to M5 Junction 9 is not confirmed and would not be available until the 2030-2034 funding period. This may limit the scope of development that can be delivered in the Tewkesbury / Ashchurch area until the mid 2030s.\nReference made to Tewkesbury Garden Town however recent draft Charter, changes focus to six broad garden communities. Article on BBC news talks about Garden Village - there is a need for consistency in how development is referred to as there will be people that have different opinions on what a garden town v. garden village v. garden communities means. Can a terminology be agreed amongst the SLP local authorities?\nRefers to GCC and NH and other relevant local highway authorities, drawing up detailed proposals for major improvements to Junction 9 (M5) to facilitate option 3 of the scenarios : strategic new settlement (The third option lies to the east of the M5 at Ashchurch on the edge of the built-up area of Tewkesbury). No infrastructure requirements set out for Option 1 and opton 2 of scenario 4. Option 3 therefore has more merit / evidence in SOC development in that options are already being considered for addressing existing recognised pressures on the strategic road network as well as potentially provide the additional road capacity necessary to support the development of the proposed Garden Town. Could this be added as a pro?\nThis paragraph states that \"As with all options, this includes the urban capacity of Gloucester and Cheltenham as a starting point\" - suggesting additional 5 scenarios being considered would be in addition to and required to meet housing forecast. What evidence is there that scenerios 1, 2, 3, 5 and 6 could meet the required 35,700 housing, therefore meaning no need for new strategic settlement?\n23: What types of infrastructure do you consider are most critical to be delivered alongside new development? \n24. Given their size, if strategic scale new settlements were to form a part of the Strategic and Local Plan, what accompanying infrastructure would be necessary?\nA response to this questions could be: - the collective need for policy support for M5 J9 A46 Ashchurch Scheme to facilate development in the Ashchurch Area (Option 3 of scenario 6: strategic settlement). \nThe document could be read as detailed proposals for major improvements to Junction 9 (M5) are being produced by GCC and NH, the junction itself. This could be misleading coupled with the reference to a new master planned settlement with a minimum of around 4,000 new homes with supporting infrastructure. The M5 J9 scheme is at the options identification stage with a number of shortlisted options identified, it is part of the NH RIS4 pipeline and will not be built and open to traffic until 2034. Prior to this in 2024 various developers are putting forward proposals for potential 4000+ houses at Ashchurch. Those developments will have an impact on the existing A46 and M5 J9, the developers will need to demonstrate how the impacts of their developments can be mitigated. This may result in holding conditions on planning applications and/or significant local developer contributions to pay for improvements to the existing A46 and M5 J9. GCC and NH do not have funding or detailed proposals for these works. \nNo mention of active and sustainable travel, buses etc is referred to the New Stategic settlement section all of these things will be needed for a Garden Town / this type of settlement."]
["Statutory/Specific Consultee","Gloucestershire County Council","","","","","","","","Private vehicle use can be minimised with the SLP.\nDevelopment sites should be selected where existing public transport and active travel \n(cycle/walking paths) infrastructure is accessible for future occupiers. Where development is \noutside of these areas, the onus should be on the developer to assist in the development of such \ninfrastructure.\nNew development should have Car Club provisions, reduced private vehicle spaces and secure \ncycle storage facilities. Any parking provisions should provide electric vehicle charging points (not \njust cables) and go above and beyond the Building Regulations Approved Document S on Electric \nVehicle Charging Infrastructure. Developers should also be encouraged to provide Low Emission \nTravel Plans to promote sustainable travel.\nEnsuring all future housing development is located where people will have a genuine option to \nwalk and cycle to access daily services (food shop, primary school, open space, community facility, \nGP) and facilities and conveniently use public transport to access employment and for longer trips, \neither because those services and facilities exist already or because it is realistic and feasible that \nthey can provided permanently as a result of the scale of the development proposed. \nEnsuring all employment and other development including retail can be accessed by the majority \nof its catchment within an hour’s whole journey time by public transport or by easily cyclable \njourneys along LTN 1/20 compliant cycle facilities such as the Gloucestershire cycle spine.\nThe SLP has the opportunity to build upon existing public and active travel infrastructure and \ninstall new infrastructure where needed which will also encourage existing residents to use it.","Construction should be sustainable and environmentally conscious, and this can be secured via \ncondition at the planning stage e.g. a Construction Environmental Management Plan. Buildings \nshould be designed in line with Passivhaus design, and exhibit features which boost energy \nefficiency, e.g. window orientation, size, glazing and deciduous vegetation that can provide \ncooling in summer and solar gain in winter. Developers should familiarise themselves with the \nCheltenham Borough Council SPD on Climate Change and demonstrate how their development \nwill show compliance. Regarding operation, renewable energy is to be prioritised. Installation of \nroof solar panels, heat pumps, district and communal heating, etc. is to be promoted with gas \nconnection avoided where possible.","Retrofitting of existing building stock to ensure maximum energy efficiency is achieved is \nnecessary. The Cheltenham Climate Change SPD guidance should be followed.","","","","For residential development the services which should be within easy c800m walking and cycling \ndistance should as an absolute minimum be those facilities which people use daily/several times a \nweek which should include a food shop, park or green space including play facilities, indoor \nmeeting space and a primary school. For a genuinely walkable / cycle-able community, a post \noffice or bank and GP surgery and other facilities important to local communities should also be \nincluded.\nA bus stop should be within 400m (from individual front doors for both residential and \nemployment development) of all significant development served by an express bus service with 4 \nbuses per hour in urban areas and 2 buses per hour in rural areas. These should be existing bus \nservices or services where the frequency can be increased or the service extended through \ndevelopment funding to deliver a financially viable service. All other development should be \nwithin 400 m of a bus stop that has at least 1 bus per hour.","Yes","Allocating sites within the SLP towards renewable energy generation will help Gloucestershire \nachieve its climate commitments. Sites should be areas where development may not be \nfavourable, e.g. where land contamination may be present and remediation undesirable. Solar \nfarms may be preferable here owing to agricultural land availability and the ability for sheep \ngrazing alongside its operation. Additionally, solar farms are typically commissioned for 40 years \nand therefore are technically temporary allowing for redevelopment in the future. Renewable \nenergy site developers are to be mindful of potential adverse impacts however on existing and \nfuture occupiers. Using solar as an example, glint and glare surveys are to be provided, alongside \nacoustic assessments demonstrating necessary British Standard compliance of associated Battery \nEnergy Storage Systems.\n","","","","","","","","There is a lot of discussion at officer level throughout the districts regarding a call for suitable sites\nfrom landowners, however there still seem to be barriers to bring them forward. It would be \ndesirable to have discussions with existing traveller communities who have land and or private \nsites that they may be able to offer for sale. ","Officers have found that when sites are too large, it can lead to tensions within the traveller \ncommunity and encourage anti-social behaviour impacting on the surrounding settled \ncommunities. \nSites developed with around 4-8 plots seem to be more manageable and generally attract less \ncriticism from the wider community. \nTravellers who live on permanent sites all year, still like to retain their sense of tradition and are \ncontent for them to be rural but equally near to major road networks, e.g. motorways or major A \nroads, even if the areas tend to be slightly more industrial.","These will be explained in the emerging Gloucestershire Economic Strategy – currently anticipated \nto be considered by GCC’s Cabinet on 15th May 2024. ","These will be explained in the emerging Gloucestershire Economic Strategy – currently anticipated \nto be considered by GCC’s Cabinet on 15th May 2024. ","These will be explained in the emerging Gloucestershire Economic Strategy – currently anticipated \nto be considered by GCC’s Cabinet on 15th May 2024. ","These will be explained in the emerging Gloucestershire Economic Strategy – currently anticipated \nto be considered by GCC’s Cabinet on 15th May 2024. ","These will be explained in the emerging Gloucestershire Economic Strategy – currently anticipated \nto be considered by GCC’s Cabinet on 15th May 2024. ","It is important that the need for major new highway works are minimised as far as possible. This \nshould be achieved through locating development where there is a genuine choice of using active \nmodes access daily services and facilities and public transport to access destinations further afield \nsuch as the main town/city centres, employment and higher/further education. \nA programme of bus priority is being developed as part of the development of the Expressbus /\nMass Rapid Transit work. The delivery of bus priority along corridors serving major development \nwill be critical.\nLTN 1/20 compliant cycle infrastructure should provide complete connections to all key \ndestinations within cycling distance.\nHealthy streets should be provided which support walking and cycling by people of all ages and \nabilities and also include measures including SUDs and trees planting to manage drainage impacts \nand encourage biodiversity. \nHaving first considered opportunities for active and sustainable modes, the development of \nstrategic and local highway infrastructure which addresses both capacity and safety issues \nexacerbated or caused by proposed development.","The same measures for Q23 are generally applicable for Q24.\nWhilst a new strategic settlement offers opportunities for sustainable travel, the planning of \ninfrastructure required to enable a large strategic development is inherently complex. Whilst \ncareful master-planning (considering links between housing with local jobs and amenities) is \nessential to maximise “containment” of trips, it is also critical to consider interactions with the \nexisting transport network – particularly where there are opportunities to link with and enhance \nexisting or planned public transport provision to prevent reliance on the private car for longerdistance trips. From this perspective, reviewing potential alignment with the Gloucestershire Bus \nService Improvement Plan (BSIP) is very important – establishing the feasibility of bus services \nwhich could form part of the express bus network (or an extended part of it) with a frequency of 4 \nbuses per hour, bus stops within 400m of all dwellings or business premises). \nIn some circumstances, given the scale of development, it seems inevitable that new highway \ninfrastructure will be required to allow development to come forward. However, where this is \nidentified, careful scrutiny is needed to ensure this will complement and facilitate more \nsustainable transport options by resolving existing vehicle movement conflicts (e.g. strategic \nmovements versus local movements) as well as capacity and safety issues. \nOf the three options, more is known about the issues related to the Tewkesbury Garden \nCommunities. Specific comments in relation to this strategic settlement are as follows:\nThe consultation document notes that 'major improvements to Junction 9 (M5)' may be required \nto address existing pressures on the Strategic Road Network (SRN) and provide additional road \ncapacity to enable development. In addition, the previous section identified options for urban \nextensions at Tewkesbury, which although not named, include potential locations to the north, \neast and south of Tewkesbury. (The location to the north of Tewkesbury appears to relate to the \nMitton strategic site proposed in the South Worcestershire Development Plan review which is \ncurrently at the Examination stage.)\nA co-ordinated approach is essential for the planning of transport infrastructure required to \nenable development at Tewkesbury/Ashchurch (whether this is in the form of urban extensions or \na new strategic settlement or combination of the two, and including development in the Mitton / \nBredon Road area). \nIn addition to addressing capacity constraints on the SRN (M5 Junction 9 and A46), an overall plan \nor strategy should identify requirements for upgrades to the local road network and sustainable \ntravel infrastructure. This must address the requirements for east-west movements across the M5 \nbetween Tewkesbury and Ashchurch that will be generated by new development and the current \nreliance on the A46/A438 corridor passing though M5 Junction 9 for most of these journeys. \nWhile upgrades to the transport infrastructure along the A46/A438 including M5 Junction 9 may \nbe feasible, further increases to traffic flows on this corridor may not be sustainable, noting the \nproximity of Junction 9 to schools (including Tewkesbury Academy) and existing residential areas \nalong the A438 (Newtown) and A46 (Ashchurch). \nThe overall plan for new development in the Tewkesbury/Ashchurch area should also include \nsuitable provision for employment opportunities that are aligned with future market needs and \nprovide for locations and forms of development that integrate with existing communities and \nfuture housing development locations and facilitate sustainable travel for commuting to \nworkplaces. New employment sites that result in significant increases in traffic using the SRN may \nnot be sustainable, even allowing for major improvements at M5 Junction 9, due to potential \nimpacts on operation and safety of the M5 and A46.\nDiscussions between GCC, National Highways, Department for Transport and DLUHC clearly \nidentify the link between a Government funded upgrade to M5 Junction 9 and the A46 and the \nTewkesbury Garden Town (Communities), and it is essential to the case for the infrastructure that \nthe Garden Town concept (10,000+ homes and employment land) is clearly laid out in the SLP. \nThis provides the important policy ‘hook’ that Government requires in the emerging development \nplan, to enable progression of the infrastructure through the business case process. It may be that \na larger proposal in this area would be more sustainable. ","As noted in point 5 of the documentation review section of GCC’s response; there are notable \nconcerns regarding the potential for this option to perform well from a sustainable transport \nperspective where there is an absence of any quality sustainable transport provision as well as \njobs and a range of local amenities. The viability of new services is likely to be low – unless clear \nlinks to a wider sustainable transport strategy can be demonstrated. This proposed development \noption is therefore objected to. ","","Yes","An expansion of the Garden Communities option could be considered to better enable a future \nself-contained sustainable development scenario, with more scope for the required infrastructure. ","","The reason for the disadvantage stated “Increased journey lengths as housing and economic \ngrowth diverted to alternative locations outside of the SLP area” re- the urban concentration \nscenario is potentially misleading. It is accepted that there will likely be an insufficient number of \nsites to meet the housing and jobs requirements for the SLP area – but individually the sites that \nfall within urban concentration are likely to perform well from a sustainable transport perspective \n(supporting use of bus and rail, walking, cycling and car clubs as stated in the advantages).\nUrban Extensions/Urban Extensions avoiding Green Belt: \nThe assumption that there will be stronger existing public transport services or better access to \nlocal amenities may not be universally true. Only urban extensions which are on or adjacent to a \nhigh frequency corridor (circa 4 buses per hour) and where development could be within a \nsuitable walking distance will genuinely offer sustainable transport choices. \nNew Strategic Settlement: \nThe complexity of delivering sustainable transport infrastructure (and ensuring this connects to \nthe wider network) in areas where there is currently a lack of provision should be recognised. \nCareful planning is required to consider how the trajectory of large housing delivery in a single \narea accords with new infrastructure as well as the delivery of nearby jobs and amenities – to \navoid the potential for a high number of long-distance car trips in a localised area which could \nhave severe impacts on the local and strategic road networks. As stated above, an expansion of \nthe Garden Communities option could be considered to better enable a future self-contained \nsustainable development scenario, with more scope for the required infrastructure. \nRural Dispersal: \nStrongly agree with the listed disadvantage: “Unlikely to support existing or new public transport, \nleading to greater dependency on the private car and road congestion, particularly for travel to \nlarger built-up areas.” It would also be very difficult to deliver any viable public transport \nimprovements due to the dispersed nature of new development. This option is therefore \nobjected to by GCC officers. ","","","","[Q1.] Given that the Tewkesbury Garden Communities project will be timed significantly further into the future than the current CGTSLP proposed end date, it may be prudent to extend the end date of \nthe CGTSLP accordingly.\n\n[Q8.] This should be explored, but, as a minimum, the statutory mandatory minimum must be applied.\n\n[Q9.] The GCC Asset Management and Property Services (AMPS) team would be happy to discuss this issue further with the SLP authorities as appropriate.\n\n[Q15.] In an “ideal” world, when housing developments are designed, it would be desirable to see within the same vicinity a small allocation of land for the Gypsy & Traveller community, although this might prove difficult to deliver. \nMany travellers in the community work and contribute to the local economy, many have part time jobs, especially more women are in employment now. \n\n[Q26.] This could be an option for proposed highways / transport projects, such as Mass Rapid Transit (MRT). However, at this stage, no route has been identified. More will be known as the MRT project continues its business case development in 2024/25. The SLP authorities will be kept updated of progress in due course. \n\n[Q29.] The Broad Site Assessment alone does not provide a clear enough picture at present to determine which development scenario is most appropriate from a sustainable transport perspective. There is also likely to be substantial variation regarding the suitability of different sites that fall into the same scenario. As such, clear evidence for each of the individual sites needs to be presented – to help justify their inclusion or exclusion based on transport / highway grounds.\nFrom GCC’s perspective, the need to quantifiably assess different sites and spatial options as a whole in terms of the level of vehicle kilometres and associated carbon emissions is a key factor in being able to determine suitability for sites.\nIn broad terms, clearly urban concentration would be expected to offer good opportunities in being able to rely on existing sustainable transport provision (where there is good accessibility and sustainable mode shares are already comparatively high). But it is acknowledged this scenario alone will not be sufficient to meet growth targets. The Garden Communities project, if planned well, could offer a sustainable future growth option.\n\n[Q31.] Public transport and active travel provisions, alongside energy efficient homes should be prioritised to assist in Gloucestershire meeting its climate commitments. This will provide cobenefits additionally, from economic perspectives, to direct health improvements such as improved mental and physical health from active travel and also to respiratory health thatexposure to poor air quality traffic and congestion presents.The GCC Minerals and Waste comments in relation to Green Belt should be actively considered by the SLP authorities."]
["Resident","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","We were alerted to the proposals re. the above, and the opportunity to comment, by our good neighbour Rob Whiteoak - see. below. \n\nWe are aware of a previous large-scale proposal re. White House Farm, circulating a few years ago, that didn't appear to proceed but was very concerning in its proposed scale and proximity to Brookfield Road. \n\nThis proposal appears to be equally worrying in its proposed scale, and its proximity to local roads and public pathways/footpaths, and likely severe impact on them and on general views and local ambience. \n\nWe strongly agree with Rob Whiteoak's comments, and in particular the likely strong adverse impact on traffic on Brookfield Road and on local essential services, including the local Medical Centre on Parton Road\n"]
["Planning agent or developer","SF Planning","","","","","",""," Although the term ‘beautiful’ is used \nin national policy, it is such a \nsubjective term as to be meaningless\nor confusing. A more objective term \nshould be used instead to ensure well \ndesigned places (with that being the \nfocus)."," Incentivising schemes which can \ndemonstrate measures to combat \nclimate change or future proof \ndevelopments. This may include \nschemes to encourage walking and \ncycling, net zero homes.","","","","","","","","","Yes","Yes, there do not appear to be any \nreasons not to use the standard \nmethod. ","","","","","","","","By taking a flexible approach to mixed use sites, changes of use and re-use of existing land and buildings (or part of land and buildings) for alternative purposes.\nRecognising that, particularly in Gloucester and Tewkesbury, some needs may need to be met on land which is susceptible to flooding. The emphasis should be instead on appropriate management of these sites including access/egress management plans and warning systems. ","","","By taking a flexible approach to mixed use sites, changes of use and re-use of existing land and buildings (or part of land and buildings) for alternative purposes.\nRecognising that, particularly in Gloucester and Tewkesbury, some needs may need to be met on land which is susceptible to flooding. The emphasis should be instead on appropriate management of these sites including access/egress management plans and warning systems.","","","","","","","","","Allocation of our client’s site aligns with the urban concentration strategy. We note that one of the cons identified is loss of employment land. Our proposal for a mixed use scheme would avoid this. Also it is within a sustainable location in the SLP area so there would not be increased journey lengths. \nIn reality more than one of the scenarios, possibly a combination of 3 or 4 will need to be taken forward in order to meet local need but urban concentration is appropriate as part of this.","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement","","","[Q8.] It can be very difficult to meet this target on constrained sites, but there could be positively worded policies to incentivise providing more than 10% \nBNG. "]
["I work for a charity or volunteer in the area","Active Gloucestershire",20," There are no obvious omissions, but it would be good to see certain definitions broadened so that \nphysical activity and wellbeing are more clearly acknowledged and supported e.g. ‘sport, informal \nphysical activity and leisure’ (instead of simply ‘leisure’); ‘infrastructure for transport (including \nactive travel)’; ‘health and wellbeing’.","","Yes"," We warmly welcome the vision’s commitment to the promotion of active travel, walkable \nneighbourhoods and interconnected green spaces. The SLP may want to consider using the phrase \n‘active environments’, which is used by us, Sport England and the Government to refer to all \nspaces and places where people can be more active. \nWe also strongly endorse the commitment to ‘the retention and management of existing sports \nand leisure facilities, and the unlocking of opportunities for healthy lifestyles and inclusive access \nto sport and recreation’. \nSo as to ensure the provision of dedicated, high quality spaces and facilities for young people, this \nlatter point would be strengthened by a specific reference to play – ‘sport, play and recreation’. ",""," Broadly, yes. However, we would like to see more explicit reference made to community sport, \nfitness, informal physical activity and play, particularly under ‘Promoting healthy and resilient \ncommunities’. This would ensure a better connection with, and expounding of, the draft vision’s \naim of ‘unlocking of opportunities for healthy lifestyles and inclusive access to sport and \nrecreation’.\nWe suggest that wording from para 102 of the National Planning Policy Framework is adopted or \nreflected within the SLP’s strategic objectives i.e. “Access to a network of high quality open spaces \nand opportunities for sport and physical activity is important for the health and well-being of \ncommunities”. \nWith reference to para 97b of the NPPF - take into account and support the delivery of local \nstrategies to improve health, social and cultural well-being for all sections of the community - it\nwould also be good to see a commitment to developing, delivering and consulting strategies \ndesigned to protect and enhance the provision of places and spaces for active recreation, \nincluding Playing Pitch Strategies, Indoor Built Facilities Strategies and Play and Open Space \nStrategies. \nOverall, the SLP should strive to look beyond traditional sport and physical activity infrastructure \nand embrace diverse and inclusive amenities that promote community well-being and \nconnectivity.\n"," We strongly support the SLP’s ambitions with regard to addressing the impacts of climate change, \nparticularly around ‘Movement’ and the ‘Built Environment’. \nSport and physical activity have a significant climate footprint, whether that’s the transport \ninvolved, facilities, energy consumption or the goods and services brought up and down the \nsupply chain – mitigating this impact and showcasing best practice in sport and physical \nactivity, given its prominence in society, has an important role to play in our collective net zero \nambitions.\nThe sport and physical activity sector can play a key role in achieving net zero in our daily \nactivities, whether it involves sustainable planning and design for each districts’ sports and leisure \nfacilities or optimising environments for walking and cycling to ensure they are both convenient \nand safe while remaining cost-effective. \nActive travel policies will be a crucial aspect of contribution to the net zero goal, and we are \nworking to support Gloucestershire County Council and the districts with the development and \nimplementation of these strategies."," We would strongly recommend that the measures and standards contained within Sport \nEngland’s ‘Active Design’ guidance are referenced and recommended for adoption within the SLP. \nDeveloped in partnership with Active Travel England and the Office for Health Improvement and \nDisparities, the guide seeks to help planners, designers and everyone involved in delivering and \nmanaging our places to create and maintain active environments.\nThe guide has 10 principles: Activity for all, Walkable communities, Providing connected active \ntravel routes, Mixing uses and co-locating facilities, Network of multi-functional open spaces, \nHigh-quality streets and spaces, Providing activity infrastructure, Active buildings inside and out, \nMaintaining high-quality flexible spaces and Activating spaces. \nEach of these should be applied to the provision of new facilities and the retention and reuse of \nexisting facilities. \nWe would also support the adoption within the SLP of The Building with Nature Standards.\nBuilding with Nature is a framework of standards for good green infrastructure. It is a voluntary \napproach which encourages developers to create places that really deliver for people and wildlife. \nIt brings together existing guidance and good practice to recognise high-quality green \ninfrastructure at all stages of the development process including policy, planning, design, delivery, \nand long-term management and maintenance."," We would strongly recommend that the measures and standards contained within Sport \nEngland’s ‘Active Design’ guidance are referenced and recommended for adoption within the SLP. \nDeveloped in partnership with Active Travel England and the Office for Health Improvement and \nDisparities, the guide seeks to help planners, designers and everyone involved in delivering and \nmanaging our places to create and maintain active environments.\nThe guide has 10 principles: Activity for all, Walkable communities, Providing connected active \ntravel routes, Mixing uses and co-locating facilities, Network of multi-functional open spaces, \nHigh-quality streets and spaces, Providing activity infrastructure, Active buildings inside and out, \nMaintaining high-quality flexible spaces and Activating spaces. \nEach of these should be applied to the provision of new facilities and the retention and reuse of \nexisting facilities. \nWe would also support the adoption within the SLP of The Building with Nature Standards.\nBuilding with Nature is a framework of standards for good green infrastructure. It is a voluntary \napproach which encourages developers to create places that really deliver for people and wildlife. \nIt brings together existing guidance and good practice to recognise high-quality green \ninfrastructure at all stages of the development process including policy, planning, design, delivery, \nand long-term management and maintenance.","","",""," Active Gloucestershire’s vision is ‘Everyone in Gloucestershire living healthy and happy lives.’ To\nachieve this vision, we see as a priority the need to provide communities with easy access to \nfacilities and services that enable them to be active and support their wellbeing. This of course \nencompasses a huge range of provision, and so it is helpful to break it down into three areas: \n1. Dedicated sport and physical activity facilities, i.e. pitches, courts, pools and leisure \ncentres\n2. Other community spaces, i.e. parks and open spaces, village halls, community centres and \nschools\n3. The wider built environment, i.e. streets, housing estates, squares and tow paths\nWhile the provision – and easy reach - of each of these facilities or settings naturally depends \nupon the size and location of any development, it is always the case that residents should be able \nto easily access services and facilities even if they are beyond their immediate local area. For this \nreason, it is essential that people can where possible travel actively and sustainably to and from \nfacilities and services that support their overall wellbeing. Incorporating active travel options \nwithin urban expansion or development areas is crucial for enhancing community connectivity.\nThe SLP should promote physical activity beyond standard playing fields and leisure facilities. \nExpanding into green belts could provide accessible nature spaces, although balancing this with \nenvironmental concerns is essential. Integrating green spaces within developments to meet multigenerational needs, including level pathways and ample seating, improves inclusivity. Addressing \npractical issues like community WC facilities is vital for encouraging older adults to engage in local \nparks.","","","","","","","","","","","","","","",""," Paragraph 97a of the NPPF requires local authorities to “plan positively for the provision and use \nof shared spaces, community facilities (such as local shops, meeting places, sports venues, open \nspace…) and other local services to enhance the sustainability of communities and residential \nenvironments”. \nIt is critical this guidance is followed for villages and rural areas as the loss of amenity can be felt \neven more strongly than in more developed areas. As such, we would like to see the SLP \nacknowledge the vital role facilities for sport and physical activity play in these areas, and that \nmeasures are put in place to ensure that their loss is discouraged or prevented, that they are \nmodernised, or that alternative means of management and delivery are supported, such as \ncommunity ownership (eg establishing Community Benefit Societies), crowdfunding or \ndiversifying of usage. While dispersed communities pose challenges for cost-effective facility \ndevelopment, community-owned projects can offer viable solutions."," We strongly endorse para 96c of the NPPF which states that:\n“Planning policies and decisions should aim to achieve healthy, inclusive and safe places and \nbeautiful buildings which: …enable and support healthy lifestyles, especially where this would \naddress identified local health and well-being needs – for example through the provision of safe \nand accessible green infrastructure, sports facilities, local shops, access to healthier food, \nallotments and layouts that encourage walking and cycling.”\nIn order to help achieve this requirement we would urge the three districts to ensure that their \nPlaying Pitch Strategies and Indoor Built Facilities Strategies are regularly refreshed so that \nplanners and developers are accurately informed as to the sport and physical activity facility \nneeds of their communities. \nThere is also a need to consider leveraging existing community assets alongside new \ndevelopments to foster integration and activity beyond traditional facilities. This encompasses \ndiverse recreational spaces like nature exploration areas and inclusive amenities such as walkable \npaths and accessible cycling routes with appropriate infrastructure like dropped kerbs."," Strategic scale new settlements typically require significant investment into larger community \nfacilities, particularly if they are not easily accessible in neighbouring areas, or if nearby facilities \nare at capacity or are reaching the end of their economic life. \nIt is therefore critical that an assessment is made at the earliest stage as to the needs of the \nproposed settlement and its neighbouring areas, and for this reason we would urge local \nauthorities to ensure their sports facilities strategies are up to date, and that they have clear \nguidance on developing active travel solutions, play provision and access to open spaces. \nIn planning for strategic scale infrastructure we understand that local authorities should be guided \nby the following sections of the NPPF:\n• Para 88d – supporting a prosperous economy\n“Planning policies and decisions should enable: …the retention and development of \naccessible local services and community facilities, such as local shops, meeting places, \nsports venues, open space…”\n• Para 108 – promoting sustainable transport\n“Transport issues should be considered from the earliest stages of plan-making and \ndevelopment proposals, so that:… c) opportunities to promote walking, cycling and public \ntransport use are identified and pursued…”\n• Para 110 – promoting sustainable transport\n“Planning policies should:… d) provide for attractive and well-designed walking and cycling \nnetworks with supporting facilities such as secure cycle parking (drawing on Local Cycling \nand Walking Infrastructure Plans).”\nAlso, as with our response to question 7, we would like to see the measures and standards \ncontained within Sport England’s ‘Active Design’ guidance referred to by both planners and \ndevelopers at the earliest stage in considering strategic scale new settlements. \n"," From the perspective of promoting participation in physical activity and sport we would highlight \nthe following services and facilities: \n1. Recreational and Cultural Amenities: playing fields, indoor sports facilities, parks, play\nareas, community centres and cultural venues enable people to be active and foster \ncommunity engagement.\n2. Social Infrastructure: community spaces, places of worship, and social organisations\n(including sports clubs and organisations delivering physical activity opportunities)\npromote social cohesion and provide opportunities for individual and community \nwellbeing.\n3. Infrastructure: adequate transport networks, including roads, access to public transport\nand active travel opportunities, are essential for connectivity within the settlement and to \nneighbouring areas.\n4. Education: proximity to schools and educational institutions is vital for families with \nchildren, ensuring access to quality education without requiring long commutes.\n5. Healthcare: access to medical facilities, including hospitals, GP surgeries, and emergency \nservices, is critical for residents' health and well-being.\n6. Environmental Considerations: preservation and enhancement of natural landscapes, \ngreen spaces and adherence to environmental regulations are important for maintaining \nthe rural character and ecological balance of rural settlements.","Yes","","","","","","","","[Q1.]  We believe the proposed ‘lifespan’ of 15 to 20 years is suitable and appropriate for the ambitions of the SLP.\n\n[Q8.]  Natural green and blue spaces provide invaluable and diverse opportunities for people to be more physically active, particularly in non-traditional and informal ways. They also provide desirable and exciting environments for children and young people to be active through play. It makes sense, therefore, to aim for the maximum net gain in biodiversity or habitat as the result of built developments within the SLP area. Sport and physical activity facilities very often neighbour - or have as their perimeter - parks, fields, hedgerows, woodland or rivers, streams and canals. It is logical therefore to aim to increase the amount of and access to these habitats when new facilities are being built or existing facilities are being refurbished or redeveloped. \n\n[Q26.] Yes, particularly for active travel opportunities. Safeguarding sites or routes for active travel \nwithin longer-term infrastructure projects can involve some or all of the following strategies:\n1. Incorporate into Planning: integrate active travel routes and facilities into urban planning \nframeworks, such as master plans and transportation plans, to ensure their inclusion from \nthe outset of the project.\n2. Designation and Zoning: designate specific areas or corridors for active travel within \nzoning regulations to protect them from incompatible development and encroachment.\n3. Legal Protections: establish legal protections, such as easements or land use designations, \nto safeguard active travel routes and ensure their preservation over time.\n4. Community Engagement: involve local communities and stakeholders in the planning \nprocess to raise awareness of the importance of active travel and garner support for its \ninclusion in infrastructure projects.\n5. Partnerships and Collaboration: collaborate with relevant agencies, organisations, and \nadvocacy groups to advocate for the protection and enhancement of active travel \ninfrastructure.\n6. Long-Term Maintenance Plans: develop sustainable funding mechanisms and long-term \nmaintenance plans to ensure the ongoing upkeep and viability of active travel routes.\n7. Flexibility and Adaptability: design infrastructure projects with flexibility and adaptability \nin mind to accommodate changing needs and emerging technologies in active travel.\n8. Education and Promotion: educate the public about the benefits of active travel and \npromote its use through outreach campaigns, events, and incentives to build support for \nsafeguarding these routes.\nBy employing these strategies, sites or routes for active travel can be effectively safeguarded \nwithin longer-term infrastructure projects, ensuring their preservation and continued accessibility \nfor communities.\n\n[Q29.]  We are generally content with the scenarios presented and broadly agree with their pros and cons. While we do not favour one particular scenario, we would be very interested in being \nconsulted around the sport and physical activity opportunities of the preferred scenario or scenarios once selected.\n\n[Q31.] Active Gloucestershire embraces the chance to engage in the consultation around the SLP, highlighting the significance of sport, informal physical activity and play for the growing communities of Cheltenham, Gloucester, and Tewkesbury. \nWe are committed to supporting the development of comprehensive plans to ensure the SLP aligns with the evolving needs of our communities, and we are keen to invite further collaboration with the SLP team and its partners throughout the next stages of the consultation phase.\nOur response at this stage is high level and we would very much welcome the opportunity to expand on the answers given to this survey. If it was thought to be beneficial by the SLP team we are able to support our statements with detailed insight, evidence and data, and we are also able to provide examples of good practice from around the country and abroad."]
["Planning agent or developer","Ministry of Defence","","","","","[Neither Yes or No was answered] \n\nThe Ministry of Defence has significant land interests within the area covered by the Plan with three operational establishments in Tewkesbury. \n\nThe three operational establishments are Defence Equipment and Support (DE&S) Ashchurch, Information Systems and Services (ISS) Boddington and Imjin Barracks. \n\nParagraph 101 of the NPPF says that planning policies should promote public safety and take into account wider security and defence requirements. The draft Vision covers a range of key areas but is silent on public safety and defence requirements. Therefore the Defence Infrastructure Organisation would like to see a Vision that includes support for national defence needs.","","[Yes or No was not answered but the following answer was given]: \n\nThe Ministry of Defence has significant land interests within the area covered by the Plan with three operational establishments in Tewkesbury. The three operational establishments are Defence Equipment and Support (DE&S) Ashchurch, Information Systems and Services (ISS) Boddington and Imjin Barracks. Paragraph 101 of the NPPF says that planning policies should promote public safety and take into account wider security and defence requirements by recognising and supporting development required for operational defence and security purposes, and ensuring that operational defence sites are not affected adversely by the impact of other development proposed in the area. A further Strategic Objective should be added to the Building strong, competitive and sustainable urban and rural economies section. This should state support for development required for and supporting operational defence and security purposes and protection of defence operations from the adverse impact of other development proposed in the area.","","","","","","","","","","","","","","","[Yes or No was not answered but the following comment was given]: \n\nThere has been significant investment in DE&S Ashchurch and further developments are envisaged at Imjin Barracks during the Plan period. To react to any defence needs at the time it is possible for additional personnel to be based at the sites and this in turn can result in the need for local housing. The Defence Infrastructure Organisation are not in a position to have any certainty of when and how many additional houses could be required for service personnel, indeed if any. However, it is important that as a Strategic and Local Plan that contains three major defence sites it acknowledges the current housing stock includes occupation by service personnel and their families and this can change in the future due to evolving defence needs.","","","","It is important that the Strategic and Local Plan recognises that the three defence sites contribute to economic and regeneration needs and sites that over the Plan period will need to have investment, expansion and adaption. The Plan should include provisions to support sustainable development.","","","","","","","","","","[Yes or No was not answered but the following comment was given]: The Ministry of Defence has significant land interests within the area covered by the Plan with three operational establishments in Tewkesbury. The three operational establishments are Defence Equipment and Support (DE&S) Ashchurch, Information Systems and Services (ISS) Boddington and Imjin Barracks. Paragraph 101 of the NPPF says that planning policies should promote public safety and take into account wider security and defence requirements by recognising and supporting development required for operational defence and security purposes, and ensuring that operational defence sites are not affected adversely by the impact of other development proposed in the area. It is therefore wholly appropriate that defence interests are safeguarded through the Plan.","","","","","","We thank the Councils for the opportunity to comment on the above Consultation. In addition to responses to questions 4, 5, 14, 18 and 26 please find set out below specific representations submitted on behalf of the Secretary of State for Defence. Background The Defence Infrastructure Organisation (DIO), on behalf of the Ministry of Defence (MOD) welcomes the opportunity to comment on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan. The DIO is the estate expert for defence, supporting the armed forces to enable military capability by planning, building, maintaining, and servicing infrastructure on behalf of the MOD. The MOD has significant land interests within the area covered by the Plan with three operational establishments in Tewkesbury in addition to service personal family accommodation. The three operational establishments are Defence Equipment and Support (DE&S) Ashchurch, Information Systems and Services (ISS) Boddington and Imjin Barracks. There is the opportunity within the new Plan to preserve the operation and capability of these defence assets and sites and support future needs. The DIO, on behalf of the MOD, are keen to work with the Community to achieve these aims. Additionally, MOD establishments provide civilian employment and training opportunities and many service personnel and their families choose to settle within the Plan area both during and after their military service. \n\n\nThe MOD welcomes the opportunity to work closely with Planning Authorities in the development of policies and strategies within the Development Plan. In line with the National Planning Policy \nFramework (NPPF) it is important that planning authorities and development plans recognise that MOD Establishments are of strategic military importance to the UK. It is important that Planning Authorities consult with the MOD during the preparation of their plans and take into account the need to safeguard operational sites. We would like to draw your attention to paragraph 101 of the National Planning Policy Framework (December 2023), which states: “Planning policies and decisions should promote public safety and take into account wider security \nand defence requirements by:… b) recognising and supporting development required for operational defence and security purposes, and ensuring that operational sites are not affected \nadversely by the impact of other development proposed in the area.” The importance of operational capability is recognised by virtue that the MOD are exempt from action under the Environmental Protection Act for noise nuisance. In addition, paragraph 193 of the NPPF and the ‘agent of change’ principle protects MODs continuing and future military needs of operational sites from any unreasonable restrictions being places on it as a result of development permitted after it was established. It is important that MOD establishments and land of interest to defence are considered within the new Plan for two principal reasons. Firstly, ongoing operational defence needs and secondly, to protect operational defence land from being affected adversely from third party development proposed in the area. To ensure that the sites deliver on their defence output there will be times when further developments are required within or associated with the sites. It is important for national defence that the Plan is able to support the principle of such developments. In addition, the MOD is committed to reducing its carbon footprint and will be looking to implement measures on sites to achieve this. It is essential for operational reasons that current and any future defence related activities can be \nundertaken at the site without any additional restrictions or controls. For example, third party developments within the vicinity of the site have the potential to restrict operations of certain \nfacilities and potentially requiring the implementation of additional engineered safeguards that together could constrain the ability to manage any future change and restricting the potential of \nfuture development requirements – all to the cost of the public purse and to the detriment of national defence preparedness. In such circumstances this operational defence site could be \naffected adversely by the impact of development proposed in the area, contrary to paragraphs 101 and 193 of the NPPF. Accordingly, the Councils may consider it prudent within the new Plan to include a specific MOD establishment policy that provides and protects both on-going and future operational defence needs within or associated with these sites and serves to ensure that any neighbouring development does not adversely impact upon these operations or, in turn, would be affected by the established use. For example, the policy could include that proposals associated with defence and military operations in connection with these existing sites will be supported where they would enhance or sustain operational capabilities. Any policy should also ensure that for proposed non-military or non-defence related development within or in the areas of a defence or military site will not be supported where it would adversely affect military operations or capability. The Councils will be aware that part of DE&S Ashchurch is no longer required for military output and is separately being promoted for alternative use through the Strategic and Local plan. A separate response to this consultation regarding this part of the site is due to be submitted. Conclusion: It is important that the MOD establishments and interests are considered within the new Plan for two principal reasons, firstly, ongoing operational defence needs and secondly, to protect operational defence land from being affected adversely from third party development proposed in the area. To ensure that the site delivers on its defence output there will be times when further developments are required at or associated with these sites. It is important for national defence that the Local Plan is able to support the principle of such developments. This can be achieved by including the following Policy: Development within and effecting operational defence sites at Defence Equipment and Support (DE&S) Ashchurch, Information Systems and Services (ISS) Boddington and Imjin Barracks a) Development required for operational defence purposes within and around Defence Equipment and Support (DE&S) Ashchurch, Information Systems and Services (ISS) Boddington and Imjin Barracks will be supported where it sustains the functioning of these defence establishments. b) Non-defence related development in the areas around a defence site will only be supported where it would not adversely affect defence related operation or capability. The MOD also considers that the following text would be suitable to support the above recommended Policy: Defence Equipment and Support (DE&S) Ashchurch, Information Systems and Services (ISS) Boddington and Imjin Barracks provide important outputs that support national defence activities. The NPPF outlines that planning policies and decisions should recognise and support development required for operational defence and security purposes, ensuring that operational sites are not affected adversely by the impact of other development proposed in the area and existing businesses and facilities should not have unreasonable restrictions placed on them as a result of development permitted after they were established. The Councils are also invited to consider examples of similar policies within adopted Plans at Central Lincolnshire, Cheshire West and Chester, Northumberland, West Suffolk and Wiltshire. A copy of these policies have been included below. [Submitted but not included in this upload]"]
["","Cheltenham Civic Society",25,"Whilst recognising that these come from the NPPF, they seem to be very traditional: allocating land for economic and social purposes whilst protecting and improving the environment. What is missing are:\na.\tan emphasis on upgrading the existing stock (e.g., of housing and public buildings. Even in 15 years’ time the great majority of people will still be living in homes that exist now. A strategic priority should be their improvement for net zero and in other ways. \nb.\ta strategic approach to the recovery of nature that would benefit urban as well as rural areas. This will help guide the assessment of the strategic options in questions  27-30. \nIn our comments on question 31 we make these points again with references.","This depends how fine the policy grain is. For example, in Cheltenham a particular concern for its Regency heritage would be appropriate; in Gloucester policies for the setting of the cathedral or the docks would be needed.","No","Suggested improvement are:\n•\tDefine “green growth”. \n•\tAdd “nature rich” to para. 1.\n•\tA new line on the widespread use of “nature-based solutions to climate change” is needed (this is much more than natural flood management techniques) .\n•\tAdd reference to education and research in para. 2.\n•\tAdd reference to the need for housing etc. to be highly efficient in terms of carbon emissions (para 3).\n•\tAdd a major theme that the existing stock of housing, community buildings etc. will have been upgraded to meet net zero standards.\n•\tEmphasise that each of the three major settlements will have retained their distinctive characters.\n•\tHighlight the role of heritage buildings as assets that are valued, conserved and put to good use.","No","•\tUnder “Meeting the challenge of climate change” add these:\n- a major programme to plant and maintain street trees throughout.\n- a major programme to cover suitable industrial, warehouse etc. roofs with solar PV arrays.\n- ensure sewage systems are sufficient to end all spillages of raw sewage (and soon).\n- ensure homes are provided with space to store refuse and recycling materials.\n- a specific commitment to promoting district heating systems, especially in all major, new high-density development.\n• Under “Delivering well designed, beautiful and safe places” add:\n- ensure that the infrastructure needed for new residential development is in place before people move in.\n- all new development should meet the Building with Nature standards and certified as doing so (see also answer to question 23 and 31).\n- add a reference to the aspiration that everyone lives within 15 minutes walk of accessible biodiversity rich green space (already endorsed by the Gloucestershrie Local Nature Partnership and Climate Leadership  SUDS should be a standard requirement in the design of all new development. \n• Under “Prioritising sustainable transport and active travel”:\n- we recognise the desirability of a greater emphasis on walking, cycling and public transport but for some important groups (e.g., disabled people, young mothers, tradesman, emergency services) private vehicle access will still be needed.\n• Under “Making as much use as possible of brownfield land and conserving and enhancing the natural and historic environment”, we call for:\n- a major emphasis on the reuse of existing buildings before replacing them with new ones; and prioritising the use of brownfield land over greenfield sites. \n• Under “Promoting healthy and resilient communities” it is important to:\n- ensure that publicly-owned greenspace in development is properly managed This may require special legal arrangements to be put in place at the time of development. ","• All new development should be designed to cope with heat waves. \n• Areas liable to flood should be kept free of new development; or such development should be specifically designed to cope with flooding.\n• Areas of high biodiversity value should be protected, especially where these can buffer the effects of climate change (i.e., adopting nature-based solutions to climate change).\n• Large scale tree planting in urban areas. All streets in new developments to be planted with trees that will grow large on maturity; and a concerted drive to plant trees in all areas of existing development (inc. industrial estates) that lack them.\n• A major campaign to get solar panels installed on suitable roofs on existing industrial and commercial buildings. And make solar panels a mandatory part of the design of all new development.","• Re new buildings: Follow the excellent advice and standards about construction and operation already set out in the Cheltenham Climate Change SPD.\n• Require solar panels on all suitably-oriented roofs in new developments.\n• All new buildings to be planned with a life expectancy of at least 100 years to minimise carbon-releasing demolition. \n• SUDS to be a standard requirement in all new development. ","• Re existing buildings, encourage their reuse before replacement; publish advice on insulation and renewable energy in old buildings, especially listed buildings tailor-made to Cheltenham.","","Yes","• The land identified in the mapping done for the Gloucestershire Nature Recovery Network (see below).\n• Review potential on all land held by council and CBH, and then adopt 5-year plans to ensure they contribute to environmental improvement. ","• Those that can best be reached on foot, e.g., local shops, schools, play areas, health centres.\n• Plan for Cheltenham to become a “15-minute town”,","","• More important to integrate renewable energy into existing development, e.g., solar panels on roofs of business and industry; and to exploit the potential offered by large new developments of medium or high density to instal district heating systems. ","","","","","","","","","","• Land, services, infrastructure, access to skilled labour etc.\n• Incentives for using brownfield sites rather than greenfield ones.","• Making suitable land available when needed (that includes a programme for releasing brownfield sites).","• By supporting growth sectors of the rural economy such as: locally-grown or locally-reared food; sustainable forms of tourism; renewable energy generation; schemes to capture carbon in soils, trees etc. \n• By supporting local public transport in rural areas.\n• By supporting other services, such as schools, shops, medical services and libraries, needed by rural communities. \n• By providing genuinely affordable housing for local people and resisting the pressure for second homes where this pushes up house prices to levels that local people cannot afford.\n• Seek the advice of the Gloucestershire Rural Community Council.","One important aspect of our city and town centres is the rich historic and architectural heritage that they retain. We can see in the Gloucester Docks and in Cheltenham’s Montpellier district how these can support a thriving economy.  A major part of town centre planning should, therefore, be focused on protecting this heritage and using it wisely and sympathetically. The key to this is good, up-to-date plans. Cheltenham urgently needs a town centre master plan and a set of updated Conservation Area plans that show how a well-preserved heritage can be the key to economic success. ","See answer to question 20.\n• By supporting growth sectors of the rural economy such as: locally-grown or locally-reared food; sustainable forms of tourism; renewable energy generation; schemes to capture carbon in soils, trees etc. \n• By supporting local public transport in rural areas.\n• By supporting other services, such as schools, shops, medical services and libraries, needed by rural communities. \n• By providing genuinely affordable housing for local people and resisting the pressure for second homes where this pushes up house prices to levels that local people cannot afford.\n• Seek the advice of the Gloucestershire Rural Community Council.","The obvious network of transport facilities; networks providing energy, water and waste; and community facilities. But we know now that green infrastructure is just as important as human-made infrastructure: a framework of nature, based on healthy and interconnected natural features. Green spaces have been linked to positive effects on human health and wellbeing: physical, mental and social. People need access to - and to live alongside - green space that is managed to allow nature to flourish. So, the SLP should include a commitment to everyone living within 15 minutes’ walk of accessible biodiversity-rich green space, in line with Natural England’s Accessible Natural Greenspace standards - https://www.gov.uk/government/news/natural-england-unveils-new-green-infrastructure-framework.   Furthermore, all new development should meet the Building with Nature standards - see below. ","See answer to question 23. The obvious network of transport facilities; networks providing energy, water and waste; and community facilities. But we know now that green infrastructure is just as important as human-made infrastructure: a framework of nature, based on healthy and interconnected natural features. Green spaces have been linked to positive effects on human health and wellbeing: physical, mental and social. People need access to - and to live alongside - green space that is managed to allow nature to flourish. So, the SLP should include a commitment to everyone living within 15 minutes’ walk of accessible biodiversity-rich green space, in line with Natural England’s Accessible Natural Greenspace standards - https://www.gov.uk/government/news/natural-england-unveils-new-green-infrastructure-framework.   Furthermore, all new development should meet the Building with Nature standards - see below. ","The capacity to meet the employment, community education, retail, health and other needs of new development so that these new places are not just dormitories for towns far away. Priority should also be given to locations that can be well served by mass transport, especially rail.","Yes","","","","",null,"","","Introduction \nThe Planning Forum of the Cheltenham Civic Society (CCS) welcomes the opportunity to comment on the consultation over the Strategic and Local Plan for Cheltenham, Gloucester and Tewkesbury.\nThe CCS are an active network of citizens that promotes civic pride in our town. We aim to encourage:\n• high standards of design and execution for buildings and public spaces\n• conservation of the town’s heritage\n• discussion and understanding of our urban environment. \nWe do this by identifying concerns, developing ideas and galvanising the community to help make the town more distinctive, attractive and enjoyable. For more information, see https://cheltcivicsoc.org/. \nThe Planning Forum assists the CCS in addressing planning issues that affect the town, and has prepared these comments for the society.\n \nWhat we look for in the Strategic and Local Plan (SLP)\nWe look for a plan that will help realise our aims for Cheltenham, in terms of good design, heritage conservation and a high-quality urban environment. Our vision is for a prosperous, beautiful town which provides for its citizens’ needs at a time of great change, whilst retaining its distinctive and rich heritage and providing space for nature as well as people.\nThe scope of the SLP is wider than our remit in that it covers the neighbouring areas of Gloucester and Tewkesbury as well as Cheltenham, but of course people living in Cheltenham also have an interest in the future of these neighbouring towns and the local countryside between the built-up areas. We applaud the continued collaborative strategic approach, recognising the realities of how people live and work in the sub-region.\nAlso, whilst all the topics covered by the SLP have some bearing on our concerns, they include a number of areas which are marginal to our interests. While we have tried to respond to most of the questions, our comments in respect of our core concerns are more detailed. Thus, we focus mainly on these areas: Cheltenham’s built heritage, urban green space, townscape and design; and how they are affected by the forces of change which the SLP addresses. We have though discussed some other areas where we feel the plan can help improve the quality of life of people in and near Cheltenham. The protection of nature and landscape in the countryside in and around our town is a case in point.\n\n[Q1.]\nWe live in a time of rapid and unpredictable change. This argues for i) a long term vision for, say, 25 years; ii) a medium term strategy (with a 10 year time horizon); and iii) a short term (3 year) work plan.\nAlso, subsidiary policy or guidance documents will be required once the SLP is adopted. The last JCS superseded a number of more detailed documents. We feel this was a loss: those documents may have needed updating, but their deletion has weakened the relationship between strategy and implementation. This means that broad objectives are not able to be effectively implemented in day-to-day decisions, and so may remain unmet. The SLP should therefore flag up the areas where such subsidiary policy or guidance will follow. Town centre and Conservation Area plans are good examples (see below).\n\nWe have two comments that relate to all three of these introductory questions:\n• The first of the’ key issues’ on page says there is a need to address the causes and mitigate the effects of climate change. Much more could be said, and agreed to, by the respective councils. After all, they have all declared a ‘climate emergency’. Climate issues overlap with other interests, e.g., reducing air pollution by reducing traffic, providing a ‘greener’ environment (trees, nature, and not simply green technology) and pursuing nature-based solutions to climate change. This will require making bold choices, followed by sensitive management of expectations and sequencing behavioural change, if this is not a time to make these decisions, when is?\n• The last of the ‘key issues’ is about resource constraints on local authorities. This too means that choices and trade-offs will need to be made and we would expect this kind of a document, or perhaps the next stage at least, to lay out how these are being considered in a transparent and accountable way. At the moment this document appears to make all ‘issues’ of equal importance, and this is simply not the reality. We encourage the local authorities to seize this opportunity to make what might be more radical change, so as to maximise benefits for future generations. That discussion of this is lacking from the current document.\n[Q8.] \n• More important in the first place to equip CBC with staff able to deal with BNG issues.\n• And to embrace and support the concept of the Nature Recovery Network so that BNG funding can be used strategically (see below). \n[Q15.]\n•If this is done, provision must be made for their need for a transitory lifestyle and recycling requirements.\n[Q27. - Q30.]\nWe have answered these four questions together as our response to the strategic options section of the consultation document. Looking at these options, we have the following comments:\n• A major theme that is absent from, but should be worked into, the strategic plan - and the consideration of development options - is the Gloucestershire Wildlife Trust’s vision of a Nature Recovery Network, which would allow plants, animals, seeds, nutrients and water to move from place to place and enable the natural world to adapt to change (see below).\n• The maps identify a floodzone in the Severn Valley but in practice other areas will be unsuitable for development because of their liability to flooding, or even its potential to cause flooding downstream. Climate change should make that a major consideration in determining future urban form. \n• The analysis tends to treat the SLP area is an island, whereas of course there are all sorts of links, especially along the Bristol-Birmingham corridor, to adjoining regions. A truly strategic approach will thus involve cooperative working with neighbours in developing and assessing these options.\n\nWhat's Missing from the SLP\nThe first 30 questions cover a wide range of issues. But they do not allow respondents to answer the question:  What’s Missing? (we interpret question 31 as inviting an answer to that question).\nThere are six strategic issues that are not adequately covered by the 30 questions:\n- The limits of planning.\n- The balance between attention given to new development and existing development.\n- The economic and cultural value of heritage.\n- The strategy needed for nature recovery.\n- The importance of bringing nature into our towns.\n- The potential for working with local groups such as the CCS. \nThe limits of planning\nThe plan needs to be explicit about what can be achieved through the formal planning system and what cannot be achieved without complementary regulatory regimes operating in areas like building control, nature conservation or traffic regulation. The SLP should set the framework for these other regimes too, but it is important not to give the impression that the planning system alone can deliver all the ambitions of the SLP. \nThe balance between attention given to new development and existing development.\nIt is understandable that so much attention is given to new developments as these are often the most controversial aspects of plans: they are also the places where change will be most rapid and evident. But most of the urban fabric that exists in 2024 will still be there in 2044. The SLP needs to say more about how the existing stock of homes, workplaces and infrastructure will be adapted to meet the needs of the future. Examples of opportunities that could feature in the SLP are:\n• A massive upgrading of the housing stock to meet the challenge of net zero. Plans will obviously be constrained by the availability of local and national funds, but a major emphasis of the SLP should be on encouraging the better insulation of the existing stock of homes. This will require suitable financial incentives, a supportive policy framework (including planning) and a trained work force: the SLP should encourage all three. Specific support will be needed to help improve the insulation of buildings of heritage value.\n• The “retro-fitting” of provision for charging e-vehicles into existing residential areas will be a big challenge in coming years. It needs a strategic, not a piecemeal, response by highways and planning authorities.\n• Cheltenham has several large industrial estates on the edge of town. Environmentally these are disaster zones. The SLP should plan for their transformation by working with the estate owners and occupiers to carry out a programme of tree planting, better insulation of warehouses etc., and solar PV installation on all suitable roofs – see https://www.cpre.org.uk/news/rooftops-can-provide-over-half-our-solar-energy-targets-report-shows/ \n• Throughout Cheltenham there are possibilities to make the existing town more “porous” for walkers and cyclists, e.g. by creating routes alongside streams or along disused railway lines. This will call for imaginative solutions which will challenge some established interests. For example, it may require reduced speed limits and vehicular access; it may also need some small but targeted land purchases, or agreements, so as to link up existing sections of potentially longer networks..  \n• The quality of the public realm has been badly neglected in parts of central Cheltenham. Though the reinstatement of paving stones or the design of street furniture may not seem to be strategic issues, they directly affect the image of the town and so its attraction to investors and its economic performance. There is understandable concern about potholes in roads but good quality pavement surfaces are just as important. The SLP should commit to aiming at the highest standards in the public realm generally and specifically in the town centre. \nThe economic and cultural value of heritage \nCheltenham’s heritage, and that of Gloucester and Tewkesbury, are not just “nice to have” but essential parts of their life and economy. It is therefore surprising that it receives so little attention in the SLP. We acknowledge the statement to protect and enhance heritage on P3, but a search throws up the word ‘heritage’ just four times, with some very generalised comments and objectives. We suggest that the SLP should make these explicit policy statements: \n• That all designated Conservation Areas will be made the subject of detailed plans within 5 years to show how heritage assets will be assessed, monitored and protected; and that these plans will be kept up to date.\n• That the conservation of the built heritage will be given the highest priority, not only in assessing planning applications but also in the councils’ plans and policies, as well as those of all relevant public bodies and statutory undertakers.\n• The preparation of a master plan for the centre of Cheltenham is a priority to ensure that its historic character is conserved, and its economic potential is maximised without adverse impacts on the heritage.\n• That design guides will be produced by the planning authority as a matter of urgency to assist applicants in drawing up planning proposals and to guide the authority itself in making decisions.\nThe strategy needed for nature recovery\nWe have noted above the several references to the need for nature to recover within the strategy area, but also that there are no strategic initiatives proposed as to how to bring that about. We recommend two:\n- require all significant new development to meet Building with Nature standards - see https://www.buildingwithnature.org.uk/\n- incorporate into the consideration of strategic options the need to build not only new homes, workplaces and infrastructure but also the idea of a Nature Recovery Network. This is a national commitment in the 25-year Plan for the Environment The mapping work done by the Gloucestershire Wildlife Trust and other members of the Gloucestershire Nature Partnership (which includes all four local authorities in the SLP) should help shape the strategic options of the SLP - see https://gcerdata.com/naturalcapital/.  Note that this is also a national priority, see https://www.gov.uk/government/publications/nature-recovery-network \nThe importance of bringing nature into our towns\nThe SLP has some good things to say about the importance of greenspace in towns, but we would like it to be more ambitious with plans for:\n- Local networks of greenspace in all urban areas.\n- Adopting a standard of biodiversity-rich greenspace within 15-minutes’ walk for everyone (see Questions 4 and 5 above).\n- Earmarking some CIL or similar payments associated with new development for the upkeep and improvement of urban greenspace.\n- Adopting the Building with Nature Standards for new development (see above).\nThe potential for working with local groups, such as the CCS\nThe draft SLP makes a number of generalised comments about working with community groups etc. But the impression is that the ‘community’ is something for which services are provided, or which – as with SLP document itself – has to be consulted. What is missing is a vision of the community (or community groups) as “partners” in the delivery of the plan.  We suggest that the CLP should explicitly propose:\n•\tTo draw on the expertise of groups, such as the CCS, for their expertise as part of the implementation of the plan.\n•\tTo set up a consultative mechanism with groups like ours so that we can feed in our ideas at an early stage. The recently completed Peer Review of planning services in Cheltenham made such a proposal. It should be acted on."]
[null,null,5,"Traffic calming","New developments keep being added and no consideration is given to increased traffic on residential roads.  Existing settlements need support to cope with increased traffic volumes and speeds.  This needs to be driven by Policy.","No","The Vision does not harness the opportunity to regenerate failing town centres  as residential centres.  \nThe Visions talks about large scale development - so that rules out small scale rural dispersal","No","1.  Quiet peaceful streets in existing neighbourhoods\n2.  Creation of new formal parks and gardens\n3.  Creation of new allotment sites\n4.  Reuse of redundant shops and re-purposing of empty employment space\n5.  Stop the creation of out of town retail centres.","Housing Policy & Transport Policy","electric charging points\nsolar panels\ninsulation\nbuild on stilts in flood prone areas\ncreate new bridges in flood prone areas","increase energy efficiency\nallocate parking in town centres for resident use where empty shops are turned into houses","Yes","Yes","common land","formal parks for people to walk in","No","energy should be captured from solar panels on all rooftops particularly on employment sites","","","Yes","Tewkesbury borough should not have to take in development from Cheltenham and Gloucester","Yes","There is a lack of property available for down-sizing. 2 bed bungalows are needed","No","There needs to be a distinction between real gypsies who travel and are happy to stop off here and there without causing a nuisance and the groups of mobile home dwellers who all work in the black economy.","","","","","","","Traffic calming","","Schools\nHealth Centres\nBus Service","","Yes","Small scale development in rural villages","No","You are deliberately drawing the consultee to the conclusion you have already decided","Scenario 4: New strategic settlement; Scenario 1: Urban concentration;","Yes","Small scale village development",""]
["Planning agent or developer","Newland Homes","","","","","2.3 Chapter 3 of the SLP sets out a comprehensive set of strategic objectives based around a draft vision. Clearly, the vision and strategic objectives are high level and set out broad themes for the SLP to follow as the strategy is developed. We reserve the right to comment further in later iterations of the plan, as it becomes clear how the vision and objectives are translated into strategy and policy. \n\n2.4 Within this context, we support the emerging vision as set out in the SLP. We note, however, that the third paragraph of the vision on page 13 sets out the following position: “People’s housing needs will have been met through the provision of sustainable, high quality market, affordable and other specialist homes set in beautiful, safe places and conforming to sustainable standards of design and construction. The focus will have been on making best possible use of brownfield sites in built up areas and large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved.” \n\n2.5 We support the commitment to provide new homes in beautiful safe places, conforming to sustainable standards of design and construction. Although we also support the plan emphasising the use of brownfield land, we would note that given the SLP covers an area which includes large rural areas, it seems unlikely that all needs can be met on brownfield sites and that therefore it would be helpful if the vision were to recognise that there will be a need to also plan for some development on greenfield sites. Such development will naturally need to be high quality and comprehensively planned to make the best use of the land and should avoid important green spaces and the highest quality farmland where possible. Therefore, the vision could be adjusted to read: “The focus will have been on making best possible use of brownfield sites in built up areas and ensuring that greenfield development where \nrequired is large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved.” ","","2.3 Chapter 3 of the SLP sets out a comprehensive set of strategic objectives based around a draft vision. Clearly, the vision and strategic objectives are high level and set out broad themes for the SLP to follow as the strategy is developed. We reserve the right to comment further in later iterations of the plan, as it becomes clear how the vision and objectives are translated into strategy and policy. \n\n2.4 Within this context, we support the emerging vision as set out in the SLP. We note, however, that the third paragraph of the vision on page 13 sets out the following position: “People’s housing needs will have been met through the provision of sustainable, high quality market, affordable and other specialist homes set in beautiful, safe places and conforming to sustainable standards of design and construction. The focus will have been on making best possible use of brownfield sites in built up areas and large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved.” \n\n2.5 We support the commitment to provide new homes in beautiful safe places, conforming to sustainable standards of design and construction. Although we also support the plan emphasising the use of brownfield land, we would note that given the SLP covers an area which includes large rural areas, it seems unlikely that all needs can be met on brownfield sites and that therefore it would be helpful if the vision were to recognise that there will be a need to also plan for some development on greenfield sites. Such development will naturally need to be high quality and comprehensively planned to make the best use of the land and should avoid important green spaces and the highest quality farmland where possible. Therefore, the vision could be adjusted to read: “The focus will have been on making best possible use of brownfield sites in built up areas and ensuring that greenfield development where \nrequired is large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved.” ","","","","","","","","","","Yes","We support the use of the Standard Method calculation for assessing local housing need.","2.11 The NPPF is clear that the standard methodology is a starting point for assessing housing need. Exceptional circumstances may justify an alternative approach, and that approach could lead to a higher assessment of need as well as lower. We would suggest that a Local Housing Need Assessment to inform the next iteration of the SLP follows this approach and in particular looks at whether there are any factors which may indicate that a higher assessment of need is required. For example, given that results from the 2021 Census are now available it has become apparent in some parts of the country that population and household growth has been higher than projected by household projections based on the 2011 Census. It may also be that job growth would create a need for more economically active people in the plan area than provided for by the Standard Method, which would also necessitate a change to the assessment. We would note that the question refers to ‘constraints’ which could affect the number of homes to be planned for. Strictly speaking, the assessment of housing need should be an unconstrained calculation, and any exceptional circumstances for deviating from the Standard Method should be based on demographic factors alone. However, it will be important to understand whether neighbouring districts have unmet housing need which should be added to the assessment of need in the SLP authorities. \n\n2.12 We also note that paragraph 5.19 correctly sets out that the number of homes to be provided by the plan should be set out as the housing requirement. We would urge the SLP authorities to make clear that the housing requirement will, as a minimum, meet housing needs in full along with the agreed unmet need of any adjacent authorities. In addition, the housing requirement can take into account other factors which could lead to a higher requirement figure than the housing need figure – for example to ensure the delivery of sufficient numbers of affordable housing, or responding to growth ambitions in terms of additional jobs and infrastructure (NPPF paragraph 67). We would urge the SLP authorities to consider whether the needs and ambitions of the SLP area justify an increased housing requirement in the plan. ","","","","","","","","","","","","","","","","","","","[For the question - Are the pros and cons identified for the six development scenarios a fair and accurate assessment? - a Yes or No was not given but the following text is given here]: \n\n2.13 Chapter 6 of the Consultation Document sets out 6 ‘scenarios’ which represent the options for setting out a sustainable spatial strategy for meeting development needs across the SLP area. Paragraph 6.8 is clear that no one scenario on its own would represent a sustainable strategy, and therefore the SLP will set out a combined approach. Our comments on each strategy are set out below. We also set out how Newland’s site at Northway would complement each scenario, if at all. Scenario 1 – Urban Concentration \n\n2.14 We agree with the pros and cons set out under this scenario. \n\n2.15 Furthermore, we would add the following ‘Cons’ with regard to this scenario: a. By focusing on urban concentration, the needs of rural communities would be completely overlooked. New homes enabling families and younger people to live in rural communities would not be created, exacerbating the effects of the housing crisis and leading to additional vehicle movements as people working in rural businesses would be forced to find accommodation in urban areas. b. Additionally, it is noted that the accompanying diagram appears to show development concentrated at Cheltenham and Gloucester. The vast majority of Tewkesbury Borough, including Tewkesbury itself, would see no housing development of any scale meaning that the needs of the Borough would not be met. \n\n2.16 This scenario appears to be unworkable on its own. Whilst a focus on re-using brownfield sites within urban areas would be supported it is clear that in order to create a sustainable pattern of growth and ensure needs can be met, it will be necessary to look at greenfield sites in other sustainable locations across the plan area. This scenario should therefore be seen as one element of a broader spatial strategy. \n\n2.17 Clearly the site at Northway does not fit well into this scenario as it is described. Scenario 2 – Urban Extensions \n\n2.18 We agree with the pros and cons set out under this scenario.\n\n2.19 We would make further comments in addition to the pros and cons set out in the Consultation Document: a. Clearly, urban extensions would chiefly take place at Cheltenham, Gloucester and Tewkesbury. Extensions at Gloucester and Cheltenham would most likely fall into Tewkesbury Borough Council’s administrative area – as is the case in the adopted Joint Core Strategy. It will be important to ensure that Tewkesbury Borough’s needs are therefore accounted for as well as those of Cheltenham and Gloucester. The most sensible way to ensure that the SLP achieves this aim is to identify sufficient urban extensions at Tewkesbury – where the advantages set out in the table under paragraph 6.20 can be realised for the town. We are therefore pleased to see that the diagram accompanying Scenario 2 shows the potential for urban extensions at Tewkesbury. b. We also note that although the diagram on page 38 makes it clear that any development locations shown are purely illustrative, it appears that some of the locations fall outside of the SLP area. For example, the diagram appears to show a location to the south of Gloucester, which appears to be in Stroud District, and a site to the north of Tewkesbury in Wychavon District, which is in Worcestershire County and therefore a different district and county authority. Clearly, these locations cannot be allocated in the SLP, but could be identified as meeting needs if agreement were reached with those authorities. If this is the intention of the Consultation Document, we would suggest that this arrangement should be made clear. \n\n2.20 This scenario appears to be very close to the position in the adopted JCS, and would seem to have merit in providing sufficient opportunities to meet needs. We therefore, support the urban extensions scenario and suggest that it should form part of the spatial strategy in the emerging SLP. \n\n2.21 We would also note that the site at Northway would seem to fit well with this scenario. Northway could come forward as a stand alone urban extension to Tewkesbury providing around 450 new homes. It would provide additional facilities for new and existing residents, would support Tewkesbury’s existing facilities and would be able to take advantage of Tewkesbury’s transport and employment opportunities. It would therefore deliver many of the ‘pros’ set out in the table under paragraph 6.20 and enable the SLP to allocate a sustainable urban extension clearly meeting Tewkesbury’s needs close to where they arise. The Tewkesbury HELAA also identifies the site at Northway separately from the Tewkesbury Garden Town and suggests that it is “potentially developable”. We would therefore support this scenario, and urge the SLP authorities to consider allocating Land at Northway as an urban extension to Tewkesbury. Scenario 3 – Urban Extensions avoiding the Green Belt \n\n2.22 We agree with the pros and cons set out under this scenario. \n\n2.23 We would make the following further comments in addition to the pros and cons set out in the table under paragraph 6.24: a. Clearly, Cheltenham and Gloucester, while the two largest urban areas in the SLP area, are also heavily constrained by Green Belt designations. This scenario therefore explicitly considers not allocating any urban extensions at these locations. Given that it is acknowledged that Cheltenham and Gloucester cannot meet their needs within their urban areas, it seems that the only way for the needs of all three local authorities to be met under this scenario would be by the identification of very significant growth at Tewkesbury – far more in fact than could be accommodated by urban extensions alone. In this sense, this scenario seems unrealistic, given that urban extensions could not accommodate the required growth, and in addition, would require such a scale of growth at Tewkesbury as to entirely overwhelm the town’s facilities. b. As is the case in the adopted Joint Core Strategy, it also seems that the most sustainable locations to meet the need for new homes at Gloucester and Cheltenham is at locations as close as possible to those settlements, in order for needs to be met where they arise, and for new extensions to make use of existing infrastructure and facilities as far as possible. These considerations should take priority over the location of these urban extensions the Green Belt, as otherwise the result will be the creation of unsustainable and long journeys, probably being undertaken by car. In order to deliver on the other elements of the Vision and Objectives, it seems clear that Green Belt land should be explored for locations to accommodate the housing needs of Cheltenham and Gloucester. c. Additionally, as above we note that this scenario includes the identification of locations in Stroud and Wychavon Districts. The importance of these locations would be increased under this scenario, meaning that without an indication of the agreement of those authorities that they would accept a quantum of new homes, this scenario cannot be taken forwards. \n\n2.24 Therefore, although we would consider that the Land at Northway would fit within this scenario, we do not support the scenario as we do not believe that it is workable or realistic. \nScenario 4 - New Strategic Settlement\n\n2.25 Under this scenario, the Consultation Document suggests three locations for a new settlement – at \nBoddington, at a location straddling the boundary of Tewkesbury Borough and Forest of Dean at Churcham and Highnam, and at Tewkesbury Garden Town. It is suggested that each new settlement could accommodate 4,000 new homes. \n\n2.26 We agree with the pros and cons set out under this scenario.\n\n2.27 We would however note that as a stand alone solution, if the new settlements are assessed as \nproviding 4,000 homes at each location, even if all three were to come forwards they would only provide 12,000 new homes against the housing need set out in the Consultation Document. These \nnew settlements would clearly not meet housing need, but it is unclear whether any assessment of the new settlements providing more than 4,000 homes has been made. For example, Tewkesbury Garden Town is being considered by the Borough Council and other stakeholders as a location for around 10,000 new homes, which would clearly make a far greater contribution to needs going forwards. Therefore, bullet point 3 of the cons suggesting that this scenario is unlikely to provide for all of the new homes required may not be accurate. \n2.28 We would also note that bullet point 4 of the cons suggests that new settlements under this scenario “May not provide homes and jobs where they may be needed close to urban and rural settlements.” Clearly, this point is true of Boddington and of Churcham and Highnam, but is not true of Tewkesbury \nGarden Town (TGC). This new settlement is located at Ashchurch at Tewkesbury and therefore shares many of the advantages set out under the urban extensions scenarios set out above. \n\n2.29 In this case, the general pros and cons set out under scenario 4 do not apply equally to the locations identified as potential new settlements, and we would therefore request that the assessment of scenarios following this consultation takes this point into account when considering the Tewkesbury Garden Town. \n\n2.30 We therefore support this scenario for a spatial strategy for the SLP. However, we would make the following points regarding the options set out in the Consultation Document: a. The site at Boddington seems to sit at a location between the three settlements of Cheltenham, Gloucester and Tewkesbury. It would therefore seem to suffer from the criticism that being unconnected to all three settlements it would not provide homes and jobs where they are needed close to the settlements. A new settlement here would also require infrastructure providing ‘from scratch’ in order for it to function from day one, and by virtue of its location close to motorway junctions would run a risk of encouraging car journeys to the three major settlements rather than the use of public transport or active travel. Clearly, Tewkesbury Garden Town being close to Tewkesbury and to the facilities and opportunities available there and at Ashchurch would be able to benefit from existing infrastructure as well as from new \ninfrastructure and facilities which could be provided as part of the new settlement. b. The option at Churcham and Highnam would suffer from the same problems of remoteness set out above, but these would be more severe given the location at the furthest western part of the plan area. Arguably, a new settlement here would only address Gloucester’s needs but would do so in a location distant from Gloucester and not easily accessible by public transport or active travel. Given that the location straddles the boundary with the Forest of Dean, it also seems likely that some of the new homes provided here would go towards the Forest of Dean housing need, and the new settlement would need to be brought forwards with the agreement of and in cooperation with Forest of Dean Council. It is not clear if this agreement would be forthcoming. c. Conversely, the location at Tewkesbury Garden Town is located adjacent to Tewkesbury, able to take advantage of strategic transport links via Ashchurch Railway Station and the M5 motorway, and also an established bus network and active travel links associated with \nTewkesbury. The location has been designated as a Garden Town by the Government and already has funding allocated and an agreed Tewkesbury Garden Communities Charter in place. \nAt a scale of 10,000 new homes the location could provide a significant element of the SLP housing requirement, and would be able to also create new employment areas, district centres \nand all of the associated infrastructure and facilities needed for current and future residents of Ashchurch and Tewkesbury. This location appears to be entirely different to the suggested \nlocations at Boddington and Churcham and Highnam, and we would suggest it should also be assessed differently. \n\n2.31 Clearly, Newland Homes’ Land at Northway forms part of the Tewkesbury Garden Town location and has also been included as such in the Tewkesbury HELAA – which assesses the Garden Town area as “potentially deliverable”. The Land at Northway, as set out above, could also come forwards separately as an urban extension to Tewkesbury. \n\n2.32 We therefore, suggest that the Land at Northway occupies a unique position in relation to a spatial strategy for the SLP. It could come forward as an urban extension to Tewkesbury in the very short term, providing around 450 new homes to meet Tewkesbury’s needs and providing the benefits described under Scenario 2 above. It could at the same time be seen as an early precursor of the Garden Town developments. Newland Homes’ land interest is immediately deliverable, and would not be held back by wider Garden Town infrastructure that may well only be delivered well into the plan period. Land at Northway can be integrated into existing highway networks, and will support schools, shops and employment already found in Northway as well as providing new facilities as required within the new extension itself. However, the development can be easily designed to ensure that infrastructure that is essential to the delivery of the Garden Town, such as the railway bridge and connections to the highway network, can be safeguarded and designed into the Northway development. Northway can therefore facilitate the Garden Town as work progresses on the wider development. Scenario 5 – Rural Dispersal \n\n2.33 We agree with the pros and cons set out in the Consultation Document. \n\n2.34 Although we do not support this scenario as the key element of the spatial strategy, for the reasons set out in the table under paragraph 6.29, we would note that it will be important to ensure that rural communities have the ability to accommodate new homes at an appropriate scale, so that the need for new homes in these locations can be accommodated in the most sustainable way. Scenario 6 – Sustainable Transport Scenario \n\n2.35 We agree with the pros and cons set out under this scenario.\n\n2.36 Although we support this scenario, we would make the following observations: a. It is not clear why the Sustainable Transport Corridor shown on the diagram on page 47 does not extend to Tewkesbury. Cheltenham, Gloucester and Tewkesbury are the three main settlements of the SLP area, and are connected by rail, road and public transport. There is a clear functional relationship between the three settlements. The concept of a sustainable transport corridor connecting the three and guiding the spatial strategy of the SLP would therefore seem sensible and attractive. b. If Tewkesbury is not included in the sustainable transport corridor, as is illustrated by the diagram on page 47, development would be focused at locations around Cheltenham and \nGloucester. The needs of Tewkesbury would not therefore be met close to the settlement – which may therefore create unsustainable travel patterns. c. We would therefore suggest that the corridor should be extended to Tewkesbury. We would note, however, that if this approach is taken the resulting spatial distribution of growth would be very similar to that set out in scenarios 2 and 4 above. It may therefore be more sensible to see Scenario 6 as a guiding principle setting out how a spatial strategy based around sustainable urban extensions and new settlements should be framed. This approach would clearly favour urban extensions at the three major settlements – one of which could be the Land at Northway – and the new settlement location at Tewkesbury Garden Town; and would provide a set of strategic principles to ensure that these developments are based around principles of sustainable transport.   ","","","","[Q1.] Chapter 2 of the Strategic and Local Plan sets out the rationale for the plan, the plan area being covered and suggests broad policy areas to be covered. We support the plan area and the topics as set out, and commend the authorities on their decision to progress a single joint local plan to replace the adopted Joint Core Strategy and all adopted Local Plans. A single joint local plan will provide a more straightforward and easily understood strategy and policy framework for the future development of the three local authority areas. Question 1 of the consultation asks, “How far into the future should the Strategic and Local Plan cover?” Paragraph 2.10 notes that the timetable for producing the Local Plan is for submission to the Secretary of State in 2026, which would lead to an end date for the plan of 2041 at the earliest. We would suggest that the plan period should be significantly longer than this, for the following reasons: a. The NPPF sets out that strategic policies (which the SLP will contain) should look forward for at least 15 years from the point of adoption (para 22 of the NPPF published in December 2023). Clearly, once the SLP is submitted in 2026 it will need to go through an Examination process which will last at least 6 months, and given the complexity of the plan potentially longer, which would mean adoption of the plan in 2027 at the very earliest. A plan period running to 2041 would not therefore meet the requirements of the NPPF. b. Paragraph 22 goes on to say that “Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.” Given that the SLP may well set out a spatial strategy that includes the creation of new settlements and urban extensions (as indicated in the Scenarios), this element of the NPPF would seem to apply, and it would seem sensible for the plan period to be set at a time period that provides a sufficient framework to deliver these larger scale proposals. c. We would therefore suggest that the plan period should aim to cover at least 20 years from the point of adoption, and given that a long term strategic spatial framework is being set out to \nprovide certainty around how needs will be met, a plan period of 25 years may be appropriate, set within a longer term vision of development of up to 30 years.  \n\n2.8 Chapter 5 of the Consultation Document includes comments regarding the housing need that the plan will need to deliver. Paragraph 5.15 sets out that the standard method is the formula that the Government suggests local authorities use to determine housing need. The table below paragraph 5.16 then sets out the latest assessment of housing need for the SLP area based on the standard methodology, by each local authority. This table sets out that for the SLP area, the standard methodology sets out a housing need of 1,785 dpa, which equates to 35,700 new homes over a 20 year period. For Tewkesbury Borough, the equivalent figures are 557 dpa, which equates to 11,140 new homes over a 20 year period. It is worth noting that the Joint Core Strategy failed to provide sufficient housing land in and around Tewkesbury to meet identified needs, and the town is in need of \ngrowth to ensure vitality of existing facilities. \n\n2.9 We note that an up to date Local Housing Needs Assessment for the SLP area has not yet been produced, and therefore we will comment on the detail of the housing needs to be accommodated through the plan strategy once these have been set out in detail. We would note that the housing requirement in the SLP will need to reflect the plan period chosen for the plan, as discussed above, which may mean that housing need may need to be assessed over a period of more than 20 years. \n\n"]
["Planning agent or developer","Vinci St. Modwen and the Defence Infrastructure Organisation / Savills ","","","","No","","Yes","3.1. The draft strategic objectives are, in the main, supported. Indeed, we entirely agree with objectives such as the needs to ensure growth takes place in sustainable locations that minimise the need to travel. We will come back to this later in our commentary on the development scenarios. \n\n3.2. The only other comment on the strategic objectives is the level of detail. In some cases the detail appears to be out of context for a strategic objective and, in places, even for a local plan. For example, objective eight under the meeting the challenges of climate change heading states that: “Ensure people can make carbon friendly choices at home by providing easy to use cycle storage, covered space to dry washing outside, space to grow food and compost.” \n\n3.3. The matters covered in this objective are not 'strategic' in nature but are matters of detail which in many ways extend beyond the remit of the SLP and would be better suited to SPD. This level of detail has led to a list of draft strategic objectives which are too lengthy and not strategic in their application. We therefore recommend that the authorities revisit the draft strategic objectives and to elevate the level of detail such that the objectives can be applied more broadly to the development of the subsequent policy details.","4.1. Section 4 of the consultation document provides a detailed answer to its own question. In so doing, it outlines a number of policy tools and measures which can be incorporated into the SLP in order to address climate change and deliver nature recovery. \n\n4.2. We consider that the most important of these for the SLP and the most impactful is the allocation of land in the most accessible and sustainable locations. Doing so is clearly consistent with national planning policy and Section 39(2) requirement of the Planning and Compulsory Purchase Act 2004 which requires planmaking bodies to: “exercise the function with the objective of contributing to the achievement of sustainable development.” \n\n4.3. It is the location and broad form of development with which the SLP should concern itself rather than building design and engineering which is more appropriately dealt with under the Building Regulations. For the reasons explained in our response to question 7(a), the SLP should focus exclusively on planning considerations and not matters which are covered by other regulatory regimes.","4.4. Whilst we recognise that there may be a desire to establish ambitious targets for future development, for the reasons explained below, we do not consider that such an approach would be consistent with national policy and therefore sound. \n\n4.5. On 13 December 2023 there was a Written Ministerial Statement (WMS) by the Minister of State for Housing, Lee Rowley, which relates to the construction and operation of new buildings and which is it therefore directly  relevant to this question. The WMS includes a number of statements which are pertinent to the soundness of a draft policy: “The improvement in standards already in force, alongside the ones which are due in 2025, demonstrates the Government’s commitment to ensuring new properties have a much lower impact on the environment in the future. In this context, the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations. Any planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a wellreasoned and robustly costed rationale that ensures: That development remains viable, and the impact on housing supply and affordability is considered in accordance with the National Planning Policy Framework. The additional requirement is expressed as a percentage uplift of a dwelling’s Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP). Where plan policies go beyond current or planned building regulations, those polices should be applied flexibly to decisions on planning applications and appeals where the applicant can demonstrate that meeting the higher standards is not technically feasible, in relation to the availability of appropriate local energy infrastructure (for example adequate existing and planned grid connections) and access to adequate supply chains. To be sound, local plans must be consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework and other statements of national planning policy, including this one”. [emphasis added] \n\n4.6. It is clear from the WMS that the Government considers the Building Regulations to be the preferred and primary mechanism to deliver improvements in energy efficiency and reduce the carbon emissions from development. There are a number of reasons why such an approach is supported and considered to be appropriate and sound. \n\n4.7. First, there is a logical cut off point between the two statutory regimes which it is helpful to keep separate. Planning is concerned with matters such as the location, form and design of new development, and Building Regulations controls matters of detailed design and construction such as building fabric, fire safety, access etc. These two statutory regimes are both equally important but have necessarily separate application and approval processes which reflect the stage at which they are applied to development and the knowledge of building form and fabric which is available at each stage. There is a good logic to maintaining a clear separation between these two regimes. \n\n4.8. Planning has an extremely important role to play in reducing carbon emissions and tackling the climate emergency but it should seek to achieve this through policies which direct and ‘plan’ for development in a sustainable manner; it should not seek to stray into territory which is better achieved through nationally prescribed Building Regulations. \n\n4.9. According to Government published statistics from 2021, the largest contributor to greenhouse gas emissions in the UK is transport. Indeed, the movement of people and goods accounts for approximately 26% of emissions, considerably more than residential emissions which account for 16%2 . The plan-making process therefore has an extremely important role to play in addressing the climate emergency without stepping into and duplicating policy areas which are better addressed at a later stage of the development process. \n\n4.10. Second, the Government has strategic (i.e. beyond local authority level) concerns over the capacity of the current grid to accommodate additional local energy infrastructure and the availability of supply chains to meet the need for new building technologies that are required to achieve tightening standards. Aligning the timescales with Building Regulations will allow for investment in the grid to take place which would alleviate this concern. \n\n4.11. Third, it is important to consider the policy in the context of the changing national requirements emerging through Buildings Regulations. Around the time the Local Plan Review is expected to be adopted in 2025, new, more stringent, Building Regulations will be in place. This will require all new homes to achieve the Future Homes Standard and be net zero ready. Then in 2030, the Government is committed to having 2 https://www.gov.uk/government/statistics/final-uk-greenhouse-gas-emissions-national-statistics-1990-to-2021 decarbonised the grid. Less than 3-4 years into the plan period, the new homes built to Building Regulations would therefore be net neutral irrespective of the local plan policies. \n\n4.12. This draws into question whether there is any merit in including a policy in the SLP or instead relying upon Building Regulations. For the reasons set out above, our clients consider that the SLP should focus on ensuring development is directed towards sustainable locations (a matter covered in more detail elsewhere in our representations) and leave the Building Regulations regime to control the detailed standards for building fabric and energy generation. Such an approach would be entirely consistent with the Government’s expectation for the plan-making process.","4.13. Whether development should seek to retain and reuse existing buildings as opposed to demolish and redevelop can be a legitimate planning consideration. In circumstances where the reuse and redevelopment of an existing building is feasible, careful consideration is required by the applicant and local authority to determine whether retention would be desirable. There are a number of planning considerations which feed into such a decision, including but not exclusively the feasibility of reuse, viability, desirability and any design or quality compromises which would be required. A further consideration which we assume to be the reason for this question is the effect on carbon emissions. \n\n4.14. Whilst the carbon impact of alternative scenarios is important, it is only one of a number of relevant planning considerations to be considered in the balance when preparing and determining a planning application. Where there is an existing building which may feasibly be reused as opposed to redeveloped then we can see merit in providing an embodied carbon assessment to inform a balanced planning judgement. Such an assessment should however only be required where such an option is deemed to be feasible","","No","","4.20. Approximately one quarter of carbon emissions in the UK are generated by transport movements. Reducing the need to travel and encouraging sustainable and active modes over the private car is one of, if not the, most important contributions that the planning system can make to addressing climate change. Allocating land for residential development which is either well located to existing frequently used infrastructure such as a convenience shop, primary school etc or which will deliver such facilities as part of a mixed-use development, is crucial to the achievement of sustainable development. \n\n4.21. In other words, and in direct response to this question, it is the key services and facilities which are most frequently used by households and which households are most likely to travel to by sustainable and active travel modes which are the most important to be provided within easy reach of developments.","No","","Yes","5.1. The framework clearly requires at paragraph 61 the use of the standard method to establish the minimum housing requirement for local plans. Whilst it also acknowledges that there may be circumstances where an alternative starting point is deemed appropriate, such circumstances must be \"exceptional\". Footnote 25 of the Framework provides the only example of an exceptional circumstance – that of an island with an elderly population and no land bridge to the mainland UK - which would warrant deviation from the Standard Method. As this example ably demonstrates, to pass the \"exceptional circumstances\" test, requires a set of conditions which are genuinely exceptional. \n\n5.2. No such circumstances are present within the Gloucester, Cheltenham and Tewkesbury area and there is therefore no Framework-compliant justification to depart from the Standard Method as the starting point for the housing requirement. The starting point is sometimes referred to as the ‘policy off’ level of housing need as it represents the baseline before the effect of other local policies and priorities are taken into consideration.","No","5.3. As the staged presentation of the questions suggests, the next step in establishing the housing requirement is to establish whether any ‘policy on’ justification exists to either increase or decrease the ‘Policy Off’ Standard Method starting point. \n\n5.4. Whilst there are environmental and policy constraints which apply to land within the plan area (such as National Landscapes and Green Belt respectively), these do not justify a reduction in the Standard Method requirement for the SLP. Indeed, there is a significant amount of land available which is not constrained and which can collectively deliver the Standard Method output. \n\n5.5. It is for the authorities to establish whether an increase to the standard method is justified by policy objectives such as economic growth or the delivery of affordable housing. This is a matter which will need to be considered in detail in order to inform the next consultation stage of the SLP. \n\n5.6. Notwithstanding the strategic housing requirement, we urge the authorities to apply a degree of flexibility in the supply of land through allocations within the SLP. All three authority areas have struggled to maintain a sufficient housing land supply since the adoption of the JCS. This has resulted in the submission of numerous planning applications on land not allocated for development with many of these being subsequently approved at appeal. Rather than planning for the precise housing requirement and no more, in order to guard against such a circumstance happening again in the future, flexibility should be incorporated into the housing requirement of the SLP to act as a buffer and ensure that delivery matches, as a minimum, the identified needs. \n\n5.7. There is no nationally prescribed buffer nor guidance on what may be appropriate. However, based upon the shortfalls that have accumulated within the three authority areas and the significance of the housing need, a 15-20% buffer is in our view justified","Yes","5.8. The evidence which explains the housing needs mix is contained in the Strategic Housing Market Assessment (SHMA). In the formulation of policy, it is important however to acknowledge the difference between an assessment of housing need, such as that in the SHMA, and the demand for housing. \n\n5.9. There is no legitimate means of controlling the occupation rates of open market housing within the UK and whilst many households may only 'need' a small number of bedrooms, they may nevertheless choose to occupy a larger home. A SHMA with a methodology that is predicated on an analysis of population and demographic change might advise on the needs of the emerging demographic trends but it will not have regard to housing demand. As a consequence, the outputs from such an assessment must be treated with considerable caution and assumed to represent the minimum size breakdown of properties across the SLP area. Cheltenham, Gloucester and Tewkesbury SLP Issues and Options Consultation: Spatial Options and Key Policy Areas L&Q Estates March 2024 13 \n\n5.10. Furthermore, in the absence of an assessment of housing demand, the authorities should avoid placing undue weight upon the output of the SHMA in the formulation of policy. Rather, the mix of housing within the open market component of a development should reflect both need and demand alongside other considerations such as local character, density etc. We therefore advocate a flexible policy approach which allows for this matter to be determined by an applicant and justification provided as part of the planning application submission.","","","","","","","","","5.12. The question of the infrastructure required alongside new development is an important one but impossible to answer in a generic sense across the SLP area as a whole. The individual circumstances of each selected development location need to be carefully considered alongside the impact that development will have on existing local infrastructure and whether there is a localised deficit or surplus. \n\n5.13. Take for example open space provision. If there is a sufficient number of playing pitches within the locality of a development to meet the needs arising from a new development then it would be incompatible with Clause 122 of the Community Infrastructure Regulations and therefore unlawful to seek land or a financial contributions towards the provision of further pitches. The same principle is true of all community infrastructure designed to support the needs of a growing population. \n\n5.14. We therefore recommend that an infrastructure delivery plan for each of the selected strategic development locations is prepared to inform the preferred spatial strategy and strategic site selection, and that this is consulted upon as part of plan preparation. \n\n5.15. Notwithstanding the above, there is just one further topic specific comment we would like to make which relates equally to all strategic development options. For most forms of infrastructure the planning system is designed to assess the needs of the development and to incorporate sufficient mitigation such that these needs will be met without impacting negatively upon existing circumstances. The example provided above regarding playing pitches is such an example. A different approach however is required for transport. \n\n5.16. The joint authorities have established challenging aspirations to address and mitigate the effects of climate change. This will be impossible to achieve if, when considering development proposals, the authorities insist upon the construction of new roads and junction improvement works designed to alleviate the impact of additional vehicles on the highway network. Rather than investing in new tarmac, we strongly recommend that the authorities put in place a policy framework which instead directs investment to enhance sustainable and active travel opportunities. It is only by mitigating the impacts of development in this way that they will be both a disincentive for people to drive and an incentive for people to use alternative modes of travel.","","","","","6.1. The six development scenarios outlined in Section 6 of the consultation document in our view provide a comprehensive range of broad alternative spatial strategy options. There are no further alternative development scenarios which it is therefore necessary to test. \n\n6.2. As explained in relation to each of these within the consultation document, there are pros and cons associated with each scenario and it is inevitable that the ultimate preferred spatial strategy will be a hybrid which, to a greater or lesser degree, combines aspects of each of the alternatives tested. It is with this context in mind that we have commented upon the development scenarios in response to Question 29","","6.3. The pros and cons presented in relation to each of the development scenario provide a helpful starting point and context for those wishing to comment upon the consultation document. As we will explain in our response to Question 29 however, the weight that we consider should be attributed to the pros and cons varies. \n\n6.4. This is true not only in so far as the testing of the alternative scenarios is concerned but also in the locations that have been tested within each of the six scenarios. In other words, some of the broad locations where development is proposed will contribute to the pros and cons to a greater or lesser extent. We expand upon this at the end of our response to the next question.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","",{"$cut":{"chars":32767,"head":"7.1 The South of Gloucester is adjacent to the southern boundary of the Gloucester City urban area and, whilst presently in agricultural use, the urban influence gives the locality a peri-urban or ‘urban fringe’ character. Although L&Q Estates have an interest in only the northernmost part of the area (identified under Policy G2 in the Pre-Submission Draft Stroud Local Plan), this section of the representations addresses the location as a whole as it is this area which is shown on the three of the spatial strategy options of the SLP. \n\n7.2 First and foremost, we support the acknowledgement that the land has good potential for a strategic development. For the reasons we will come on to explain in this section of the representations, the location represents a highly sustainable and suitable location for this scale and form of development. \n\n7.3 In this section of the representations we explain why we consider the Land South of Gloucester: a) has a strong planning pedigree having previously been supported by the independent Panel and Secretary of State through Examination of the South West RSS; and b) represents a suitable, sustainable and deliverable location for strategic scale development. a) Planning pedigree of the Land South of Gloucester \n\n7.4 The land has been promoted for a number of years through successive development plans. It was originally identified with an “area of search” for an urban extension to Gloucester by the Panel appointed to consider the draft South West Regional Spatial Strategy (SWRSS). In proposing the allocation, the Panel confirmed the suitability of the land for development within the defined constraints. At paragraph 4.3.27 of their Report they stated that: “This [the construction of a station at Quedgeley] could also serve development potential within a broad swathe of neighbouring land to the east of the railway and west of M5 at Whaddon, thereby giving the facility added impetus. The land here is beyond the westward extent of the Cotswolds AONB, of no great quality in its own right and equally well related both to the built up area and to the city centre. Whether a station is provided at Quedgeley or not, it is our view that there is potential development capacity in an additional area of search here (within Stroud District and thus requiring joint working under our recommended modification of Policy J) for about 1,500 dwellings. This quantum of development would, we consider, enable the outlook from the viewpoint at Robins Wood (to the north of the land) to be adequately safeguarded without harmful encroachment into the wider countryside.” \n\n7.5 Whilst the SWRSS was revoked prior to adoption, there is a clear planning pedigree and support for the location, which was tested at Examination and supported by an independent Panel and the then Secretary of State. Due to the revocation of the RSS however this “area of search” fell away, as did the joint working between Stroud District and Gloucester City Councils. Indeed, Stroud District was excluded from the joint planning arrangements of the Gloucester, Cheltenham and Tewkesbury Joint Core Strategy (JCS). \n\n7.6 Despite falling outside of the administrative area covered by the JCS, the land was nevertheless promoted throughout its preparation. The Inspector examining the submitted JCS considered the location in her Interim Report on the JCS dated 26 May 2016. The full extract of the relevant paragraphs has been copied below as this provides important context to the Inspector’s conclusions and her explanation of why this represents a suitable and sustainable location for development. The most important elements have been underlined. Sites outside the JCS area 79. On the evidence before me there appear to be no other appropriate sites to form additional, sustainable, urban extensions to Gloucester, which fall entirely within the JCS area and have not otherwise been counted within Gloucester’s district capacity. Nonetheless, there seem to be two reasonable omission sites on the southern edge of the Gloucester urban area in Brookthorpe/Whaddon (OM"}}]
["Planning agent or developer","Godwin Developments","","2.3\tParagraph 2.4 of the consultation plan states “Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for:..”\n\n2.4\tHowever, paragraph 16 a) of the National Planning Policy Framework December 2023 (NPPF) states:\n\n“Plans should:\n\na) be prepared with the objective of contributing to the achievement of sustainable development…”\n\n2.5\tAlthough it is important to include pattern, scale, and design quality in strategic policies in a Local Plan, an identified need for sustainable development is also vital. Godwin believes that the Council should make it clear that it will support the right development in the right location. New housing development for example should be located (to be sustainable) in areas with good access to services and facilities and a wider transport network.","2.6 All policy topics (including sustainable development) identified are unique to only a council area, neighbourhood or community. It is not possible to differentiate between the various components of sustainable development (pattern, scale, design quality of places and sustainable location).\n\n2.1 The spatial strategy needs to reflect the specific characteristics of constituent authorities – one size does not fit all. As Tewkesbury is a rural authority it should have a more dispersed growth strategy than the more urban focused authorities of Gloucester and Cheltenham.\n\n2.2 Linked with this, Godwin would like to see policy topics which recognise and support the need for rural development to ensure, amongst other rural objectives, that village centres remain vibrant and viable. ","","3.1 The draft vision refers to “Building strong, competitive and sustainable urban and rural economies” This ambition is sound planning, in-line with national planning policy and as such is supported by Godwin. \n\n3.2 It then refers to “Ensuring strong and vibrant city and town centres”. Godwin wishes to make the point that many villages (including Twyning) have centres which need supporting to ensure they remain viable and vibrant. Suitably located development can help facilitate this. Godwin suggests that the vision should be amended to read “Ensuring strong and vibrant city, town and village centres”.\n\n3.3 Other aspects of the vision including “Prioritising sustainable transport and active travel” and “Promoting healthy and resilient communities” are supported by Godwin.","","3.4 Godwin supports several of the draft Strategic Objectives. The following identified objectives are considered the most important:\n• The need to address the causes and mitigate the effects of climate change.\n• Recognising and addressing the implications of an ageing population and improving health opportunities, while creating opportunities for young people to stay in our area rather than going outside of the area due to a lack of opportunities.\n• Ensuring the right amount of land for homes and employment is identified to meet needs across the timeframe of the Plan.\n• Ensuring new homes and jobs are provided in locations where services and facilities, including community facilities, can be accessed by different types of transport, including public transport, walking and cycling.\n• Ensuring the SLP’s proposals are viable and deliverable.\n\n3.5 Godwin would also like to see an objective included which seeks to ensure continued support for village centres to ensure they remain viable","4.1 The most effective way is to address the impacts of climate change is to ensure that development is sustainably located so that active travel methods can be used to access necessary services and facilities. This will reduce harmful omissions as fewer\njourneys are made by the private motor car.\n\n4.2 Development that is well connected to existing transport and public transport infrastructure (including the strategic road network) will also reduce emissions by ensure less motor car use.\n\n4.3 Development which incorporates sufficient green and blue infrastructure as part of the proposals will also help address the impacts of climate change. ","","","","","","4.7 The most important services and facilities to be within easy reach of development are those which generate the most vehicles trips. These include:\n• Convenience Retail\n• Education\n• Medical (dependant on size of settlement and development)\n• A community meeting place (village hall etc…)\n• Leisure (public house / restaurant / park and open space etc..)\n• Close proximity to wider strategic road network and larger settlements to provide easy access to higher level services and facilities (not usually found in\nrural areas for example). ","","","","5.1\tTewkesbury’s current adopted Local Plan has an annual housing requirement of 495 dwellings per annum (dpa). The Gloucestershire Local Housing Needs Assessment (2020) has identified an annual need for new homes in Tewkesbury as 557 dpa. This is based on calculations using the ‘standard method’.\n\n5.2\tGovernment guidance explains that the ‘standard method’ for assessing local housing need provides a minimum starting point in determining the number of homes needed in an area. It does not attempt to predict how the impact that future government policies, changing economic circumstances or other factors might affect demographic behaviour. It uses various inputs to determine a minimum average annual need for new homes, including average population (household) growth and the affordability of housing in the council area.\n\n5.3\tThe key word here is ‘minimum’. The NPPF at paragraph 16 (a) states that plans should be “aspirational but deliverable”. The plan should provide for growth and the wider benefits a vibrant housing market brings. For example, a successful housing market can have a substantial positive impact on the economy; and conversely social issues (both of which are overarching objectives for sustainable development according to Paragraph 8 of the NPPF – economic, social and environmental objectives). Positive effects are felt during the construction phase (employed workers putting money into the local economy), through the employment of local trades people carrying out ongoing maintenance work and home improvements, an uplift in retail as residents purchase new products for their new homes and a general uplift in local spending.\n\n5.4\tIt is disappointing to see that the level of housing proposed is not assessed in the Council’s Sustainability Appraisal (SA) which supports this current consultation. If it were, no doubt a higher housing delivery above the ‘minimum’ would score well against economic and social sustainability objectives (perhaps less so for environmental sustainability objectives, but this can be addressed through BNG and other forms of mitigation).\n\n5.5\tAccording to the ONS, in Tewkesbury Borough, 7.7% of the population was income- deprived in 2019. Of the 316 local authorities in England (excluding the Isles of Scilly), Tewkesbury Borough is ranked 244th most income deprived.\n\n5.6\tFigure 1 below (again from the ONS) shows the rise in property prices in Tewkesbury Borough since 2019. Most properties now are a third more expensive than they were in 2018. Obviously, wages have not risen by a similar extent meaning properties are becoming more and unaffordable.\n\n5.7\tFigure 2 below is a map showing the ‘Index of Multiple Deprivation’.\n\n5.8\tFigure 2 shows that large parts of Tewkesbury Town fall within some of the most deprived areas in the country.\n\n5.9\tThe above identifies several pressing issues for Tewkesbury and the wider area. Development in Tewkesbury and other nearby settlements can help these issues by providing work and additional affordable housing in a choice of areas (a ‘spin out’ of positive effects). House prices are becoming more unaffordable creating a wider gap between those who can and can’t afford to live in the area. There are also clear deprivation issues. As explained above, housing delivery can have economic and social benefits. Whilst it is encouraging that the Gloucestershire Local Housing Needs Assessment (2020) recognises the housing need issues in Tewkesbury Borough and identifies the need for a higher annual housing delivery target (compared to that in the current Tewkesbury Local Plan), this is still a ‘minimum’ however (to maintain the status quo).\n\n5.10\tGodwin believes that the Council should now be looking for a level of growth in housing delivery (not maintaining the status quo) to help address the economic and social issues in the borough. It is noted that an objective in the draft plan is to recognise and address the implications of an ageing population and improving health opportunities, while creating opportunities for young people to stay in our area rather than going outside of the area due to a lack of opportunities.\n\n5.11\tGodwin believe that this objective will not be met if only a ‘minimum’ level of housing is provided for in the plan (it would only continue the current trends identified above). The Council should be aspirational and seek to proactively address disparities in its borough.","","5.12\tIt is acknowledged that there are areas of constraint within Tewkesbury Borough (including Green Belt and AONB) but the most recent Housing and Employment Land Availability Assessment (HELAA) which supports this new Local Plan shows that there are plenty of sites which have the potential to be developed. As such, the Council’s own evidence shows that it has sufficient land to facilitate growth in the borough.","","","","","","","","","","5.13\tBy ensuring that the Plan allows for sufficient development in sustainable villages and rural areas to help protect and encourage essential shops, services and facilities.","","","5.14\tGodwin considers the following key services and facilities as the most important in deciding if a rural settlement is a suitable location for new homes and other forms of development:\n\n•\tConvenience Retail\n•\tEducation\n•\tMedical (dependant on size of settlement and development)\n•\tA community meeting place (village hall etc…)\n•\tLeisure (public house / restaurant / park and open space etc..)\n•\tClose proximity to wider strategic road network and larger settlements to provide easy access to higher level services and facilities (not usually found in rural areas).","","","6.1\tThe Reg 18 consultation Local Plan considers six different development scenarios:\n\n1.\tUrban concentration\n2.\tUrban extensions\n3.\tUrban extensions, avoiding the Green Belt\n4.\tNew strategic settlements\n5.\tRural dispersal\n6.\tSustainable transport\n\n6.2\tGodwin believes that there should be a scenario which recognises the needs of all communities and provides for development in the most sustainable urban and rural locations (the options identified suggest that development should be guided towards either urban or rural areas. This would not go towards addressing the issues facing borough identified in the previous section. There should be a mixed approach that takes account of the different character of the constituent local authority areas should be considered.).","",{"$cut":{"chars":16581,"head":"1. Urban concentration\n6.3 For this option the following ‘Pros’ and ‘Cons’ were identified:\nPros:\n• More people living in and using shops, services and facilities in the main city and town centres.\n• Bringing more life and vitality to the city and town centres, including at night.\n• Concentrated development in urban areas, supporting use of bus and rail, walking, cycling and car clubs.\n• Supports maximum use of ‘previously developed land’ and urban regeneration.\n• Protects the existing Green Belt and minimises the loss of greenfield sites and higher quality agricultural land.\n\nCons:\n• On its own, along with baseline capacity, would not deliver sufficient new homes and jobs.\n• Would only provide for a limited range of housing types, sizes and tenures (based on higher density schemes).\n• Could lead to loss of some existing employment and commercial space to housing.\n• Increased journey lengths as housing and economic growth diverted to alternative locations outside of the SLP area.\n• Likely harm to the setting and significance of important heritage assets and character of the urban area.\n• Limited opportunity to deliver climate change mitigation measures, strategic and community infrastructure.\n• Potential strain on existing social and community infrastructure, such as schools and health facilities.\n\n6.4 It is immediately clear that this option has more ‘cons’ than ‘pros’. In terms of the identified ‘pros’ Godwin would say that although there is a high proportion of people in urban areas using shops, services, and facilities there is also a high proportion of people in rural areas using shops, services and facilities. These should not be forgotten.\n6.5 Whilst it is important that urban areas retain their vitality it is vital that rural areas retain theirs also.\n6.6 Development in larger sustainable rural areas can also make use of active travel facilities.\n6.7 It is acknowledged that a pure urban concentration is likely to make best use of brownfield land (meaning less greenfield is developed). As identified above however, Government planning policy in the NPPF identifies three strands to sustainable development (economic, social, and environmental). The economic and social strands should not be put aside just for the environmental strand. Through careful site selection it is possible to still develop greenfield land which helps address economic and social issues in rural areas and minimises environmental impacts. \n6.8 In terms of the identified ‘cons’, Godwin would agree but perhaps the most important ‘con’ which is not identified is that an urban concentration approach does not help rural areas thrive and address the many economic and social issues which rural communities face. Existing services and facilities in villages need supporting. \n\n2. Urban extensions\n6.9 For this option the following ‘Pros’ and ‘Cons’ are identified:\nPros:\n• Likely range of available sites may enable housing and economic needs to be met in full.\n• Development can be delivered close to where the need arises, reducing the likelihood of unnecessary travel into and out of the area.\n• Provides the opportunity for a wide range of housing types, sizes, and tenures to meet local need.\n• Urban extensions to existing urban areas would increase the catchment population to shops, services and facilities in city and town centres, access\nto employment opportunities, and existing/improved public transport, walking, and cycling (depending on location).\n• Would provide opportunity to be supported by high quality public transport infrastructure such as Mass Rapid Transit.\n• Opportunity to enable sites to be comprehensively planned to incorporate social, economic and environmental infrastructure, e.g. everyday shops and services and open spaces.\n\nCons:\n• Loss of some Green Belt land and potentially reducing the gap between Gloucester, Cheltenham, and Bishop’s Cleeve.\n• Loss of greenfield land.\n• Potential loss of higher quality agricultural land for food production.\n\n6.10 Godwin acknowledge that urban areas are sustainable locations for development and the Counci"}},"","","","1.0 Introduction\n1.1 These representations have been prepared by Planning and Design Group (P&DG) on behalf of Godwin Developments (GC No.59 Limited - hereafter referred to as\nGodwin) in response to the Regulation 18 Consultation on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan Issues and Options\nConsultation: Spatial options and key policy areas December 2023 (SLP). \n\n1.2 The SLP has been split in five sections with a set of questions at the end of each. This representation follows that format. Godwin has not provided a response to all\nquestions; only those which it finds pertinent. \n\n[Q1] 2.1\tGovernment planning policy in the National Planning Policy Framework 2023 (NPPF) states at paragraph 22 that:\n\n“Strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery.”\n\n2.2\tThe Council’s emerging Local Plan should reflect this policy.\n\n[Q8]  - 4.4 Recently published legislation requiring a 10% biodiversity net gain (BNG) from major development (Schedule 7A of the Town and Country Planning Act 1990 (as inserted by Schedule 14 of the Environment Act 2021)) was a result of widespread consultation and input from various professional bodies. This was to understand what was realistic in terms of deliverability and availability for biodiversity net gain.\n\n4.5 If requirements for BNG are made higher than the 10% identified in this very recent piece of legislation, there’s a strong risk that development will become unviable or other important deliverables (such as policy levels of affordable housing) will be impossible to deliver as part of the scheme.\n\n4.6 Finally, the Council should note that the Government’s Planning Practice Guidance (PPG) states:\n\n“Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations\nfor development unless justified.” (Paragraph: 006 Reference ID: 74-006-20240214)]\n\n[Q12] - response contains graphics - please see separate PDF]\n\n[Q28] - response contains graphics - please see separate PDF]\n\nPlease see submitted representation document (Section 7 - Site Specific). \n7.0 Land North of Brockeridge Road, Twyning\n\n7.1 As identified in Section 1 above, Godwin has control of Land North of Brockeridge Road, Twyning (site TWY14 in the Council’s current HELAA). The site is identified on\nMap 1 below.\n\n7.2 This representation is supported by a ‘Vision Document’ for the site which provides a ‘Masterplan’ showing how the site can deliver a highly sustainable edge of settlement\ndevelopment with links to the village centre thereby creating active travel routes to key services and facilities.\n\n7.3 The site is not within the Green Belt or AONB and is within Flood Zone 1 (the lowest risk of flooding). The site is free from major constraints, and those that do exist can\nbe satisfactorily addressed through design, mitigation or biodiversity enhancement. \n\n7.4 The ‘Vision Document’ is supported by a suite of supporting evidence documents (all available on request) including:\n• A Preliminary Ecology Appraisal\n• A Landscape Technical Note with landscape proposals which feed into the proposal Masterplan.\n• Transport Access Strategy\n• Tree Constraint Plans\n• Heritage Technical Note \n\n7.5 Within the current Tewkesbury Borough Plan 2011 to 2031, Twyning is designated as a ‘Service Village’ offering a range of services and facilities. It is therefore a sustainable location for appropriate levels of growth in terms of their services and facilities.\n\n7.6 The Transport Access Strategy provided detailed plans for access to the site and the village centre. A key aspect of this site is the ease of access to the wider strategic road\nnetwork (A38, M50, M5), local employment sites, and urban centres in Tewkesbury (8 mins), Worcester (22 mins), Cheltenham (27 mins) and Gloucester (35 mins). If\ndevelopment at Twyning was located to the east of the settlement, traffic would need to drive through the village to gain access to these important destinations. With this\nsite’s western location any traffic traveling in a westerly direction avoids the village centre. \n\n7.7 It is also noted that land to the south of Twyning acts as ‘Strategic Gap’ between Twyning and Church End. Church End has its own unique historic character and\nConservation Area and the Council, understandably, is looking to ensure its retention and protect it from encroaching development.\n\n7.8 On this point however, Godwin also notes that the land which currently acts as the strategic gap is assessed in the Council’s current HELAA (refs: TWY018 and TWY020).\nEven though these sites perform an important function (the prevention of coalescence between Twyning and Church End) they are still assessed as ‘Potentially Suitable’ in\nthe HELAA. Godwin acknowledge that this is the first stage of a new plan for the Council, and as such policies may change (the gap is protected in the current Tewkesbury Local Plan under Policy LAN 3). It is difficult to see however, how, in planning terms, a future plan may not wish to maintain this protection. As explained above, Church End is a historic settlement which is mostly covered by a Conservation Area. Planning policy and local aspirations are unlikely to change to such an extent that the preservation and enhancement of the historic environment is no longer a key built environment driver.\n\n7.9 It has been noted that the Council has previously identified the site’s relationship to the setting of Twyning Manor. Although the Manor is not listed (or locally listed – it\nhas recently been converted into flats) and the landscape is not protected, the Council’s points on this matter have been recognised within the Masterplan creation.\nLandscape architects ADAS prepared detailed landscaping proposals to ensure any landscape impacts as a result of development on the site have been minimised\nthrough a subtle but effective mitigation scheme.\n\n7.10 Overall, the site represents an excellent opportunity to deliver new housing in a sustainable location. The site is considered suitable, achievable, and deliverable for\nthe following reasons:\n• The site is in single ownership and available now.\n• A number of supporting studies have already been carried out on the site thereby ensuring deliverability.\n• It will provide much needed market and policy compliant affordable housing.\n• The site has full access including active travel routes to the village centre.\n• Is in Flood Zone 1 (lowest risk of flooding).\n• The site is not covered by any planning, landscape, heritage or ecological designations.\n• It is within easy access to employment opportunities and the wider strategic road network (M50) which avoids increased traffic through the village centre.\n• It protects an important ‘Strategic Gap’ between Twyning and Church End.\n\n8.0 Conclusion\n8.1 Government planning policy in the NPPF explains that there are three overarching objectives to sustainable development – economic, environmental, and social.\nEvidence identified in these representations show that the Council is facing several social and economic problems. A vibrant housing market can deliver both economic\nand social benefits (whilst environmental impacts through housing can be mitigated and reduced through careful site selection etc…). As such, it is Godwin’s view that in\nterms of the level of housing provided for in the Council’s emerging Local Plan, it should go beyond the ‘minimum’ which simply maintains the ‘status quo’ and\npromote achievable, sustainable growth to help the borough address pressing economic and social problems. Indeed, the NPPF at para 16 (a) states that plans\nshould be “aspirational but deliverable”.\n\n8.2 In terms of a distribution strategy, considering the proposed options above, Godwin believes that a hybrid approach steering development towards the most sustainable\nurban and rural settlements is the most appropriate one for the Council to take. \n\n8.3 Based on the above and available supporting evidence, Land North of Brockeridge Road, Twyning should be identified in Tewkesbury’s Local Plan as a connected,\nsuitable, achievable, deliverable, and overall sustainable housing allocation. It is free from constraints that cannot be satisfactorily addressed through design, mitigation\nor biodiversity enhancement and is available immediately. \n\n[Q.29] 6.29 Based on the analysis of options above, Godwin believes that the Council’s development strategy should be a combination of the urban and rural options,\nwhere growth is steered towards the most sustainable urban and rural settlements in the borough (as per the existing JCS). \n\n\n"]
["Local Councillor","Twyning Parish Council ",10,"It should specifically mention the management of surface and foul water and the infrastructure changes needed to incorporate further development.","The inability of Tewkesbury Borough Council to have a 5-year land supply has had a serious impact on rural communities who as a result, have random and predatory planning applications for housing thrust upon them. This must stop. It is essential that the SLP MUST combine the three Council areas into a corporate calculation of the 5-year land supply using the standard method. \nTo keep them separate will simply put Tewkesbury back into the same trap set by the other two councils in the JCS. ","","The vision should not assume that development of any particular area is a given. Much more attention is required in regards need and the planning balance.","","A housing need assessment must be foremost in the objectives and I don’t see it in Para 3.3.\nYou cannot just dump housing on rural communities just because land is available when the facilities identified in 3.3 g) are just not present. Objective 3.3 j) incorporates ideals that are just not currently met. Sustainable locations do not include communities that are remote with no publict transport and have to rely solely on the car. How do you square the need to support agricultural businesses when nearly all the new housing is permitted on quality agricultural land?","First off, you will not promote healthy and resilient communities if you continue to approve unlimited development in rural areas particularly Service Villages. Your ambitious climate change table at 4.15 says everything that one would expect. The problem you have now and will in the future, is not only delivering these measures, but also enforcing them once planning permission is approved. Sadly this is far from what happens now and councils are not resourced to constructively manage the issues. It is infuriating when you see these lists in the sure knowledge that delivery on these measures is well beyond your scope. We are already facing in Twyning an application for a massive solar farm and you clearly state that you are looking for more opportunites including wind farms. Your consultants must be sensitive to local conditions and not just look for suitable green spaces. There is no such thing as sustainable transport in Twyning which relies solely on the motor car.","We are not qualified to comment here.","","","","Not satisfied with asking land owners for housing land, you now want green space made available for all these activities and in the same breath declare that you are aware of the requirement for food production. Clearly muddled thinking as you cannot have both.","We would expect a public transport system to be available. In the same vein, the capacity of schools should match the level of development and not have to bus primary age children elsewhere.","","TBC 23/00499. Acknowledge that there is a limit to what communities can withstand and recognise what is already in the planning system.","","Back to the 5-year land supply issue. Under the current needs allocation (5.16) there is zero chance that Tewkesbury can build 557 homes a year, they have failed to do that for years. The tilted balance and presumption prevail. The 5YLS calculation must be on a joint approach basis and include all 3 councils.","No","","","Define particular groups.","No","Possibly but not adding to those that are already in place as we are simply struggling to cope with what we already have.","No comment","TBC 21/01384 & 21/01498 These application (one already approved) fit uneasily in rural communities and we know from bitter experience that nothing that appears in a planning policy cannot be overridden by the desire to reach targets. We have little faith in a system that ignores the views of local people and ploughs ahead regardless.","","Does 33,329 sq.m of industrial warehousing seem right for rural employment? I think not, not here and not in any rural community with very limited infrastructure. I disagree strongly with the suggestion made in para 5.33","","You cannot. It's market led and only survives if there is sufficient support.","If you need to ask this question, you are really in the wrong job.","The requirements are blindingly obvious as the Ashchurch Garden Town planners will tell you.","The complete range of infrastructure requirement. Access, roads, schools, doctor’s surgery, shop, play areas, sports fields, a reliable electricity supply, a reliable water supply, public transport and most importantly a sewer system that can cope. In Twyning we have or will have over 200 new homes with no improvements to infrastructure whatever. (Although Severn Trent are finally actively addressing our sewer issue).","Yes","","","","In regards rural dispersal, I think the answer lies in the nine cons – that says it all.","Scenario 4: New strategic settlement","","The HELAA is already alarming rural settlements – we are hardly going to identify more sites.","[Q1] - 15 – 20 years is far too long a period. The Plan will be out-of date much sooner, given that it needs to be reviewed at the 5 year point, it would seem that 10 years ahead would be reasonable. You need to understand what happened to the JCS in this regard.\n[Q8] Ask the developers – they are the ones who will pay for it. We know the answer!\n[Q29] - Definitely the new strategic settlements. Think big and provide the right support and infrastructure schools etc. Stop building in villages where children have to be bussed to school miles from where they live.\n\nYour publication of the HELAA is a serious mistake leading to alarm and concern. Most do not appreciate the caveat that goes with it and to identify a village like Highnam for the possibility of an additional 5279 houses is a very serious misjudgement."]
["Statutory/Specific Consultee","Worcestershire County Council","","","","Yes","We welcome the inclusion of an overarching principle within the Vision which looks to ensure growth is sustainably located, minimising the need to travel, and promotes active and sustainable travel. We also note the inclusion of the aspiration to ensure growth is supported by essential transport and other infrastructure, which is critical in successfully delivering new sustainable development.","No","A number of Strategic Objectives underpin the overarching Vision and include sustainable transport objectives and sub objectives, such as: • Meeting the Challenges of Climate Change o Ensuring growth takes place in sustainable locations that minimise the need to travel and provide genuine sustainable transport and active travel options; o Ensure development effectively integrates with existing development and/or is a self-contained development that provides shops, services, facilities through walking, cycling or public transport. • Prioritising sustainable transport and active travel o Reducing the need to travel by creating real options for healthy, accessible and walkable neighbourhoods where key services are available without the need to use motorised transport; o Promoting the use of sustainable travel modes by improving existing and providing new frequent public transport links and safe walking and cycling routes in all new developments; o Reducing reliance on the private vehicle by improving access to services in rural and urban areas through new development, improved integrated transport links and supporting local and community led transport initiatives in the Local Transport Plan; and o Creating a genuine choice between different modes of transport by integrating new development with existing networks and enhancing these wherever possible. The importance of new development which is or can be made sustainable in transport terms is also a critical part of realising a number of the other SLP Strategic Objectives (for example, ‘Delivering well designed, beautiful and safe places’ and ‘Ensuring strong and vibrant city and town centres’) and Worcestershire County Council supports the aspirations underpinned by these objectives. However, given the proximity of the Plan area to Worcestershire and the key highway links connecting the County to Tewkesbury, there are potential cross-boundary movements utilising Worcestershire’s transport network, particularly the A46, B4079 Cheltenham Road, Tewkesbury Road and Hardwick Bank Road. It is therefore suggested that a specific objective or sub objective relating to ensuring the efficient operation of the highway network for residual traffic would also be appropriate, along with a highway safety objective that aims to ensure safe access and movement for all. This would ensure that the impact of development on the highway and transport network, together with the deliverability/viability of necessary interventions, would be key considerations during the development of the growth strategy and infrastructure plan. Such objectives would also help the assessment of individual development impacts when considering the nature of the proposed mitigating infrastructure provision through the planning process.","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","No","WCC Highways has reviewed the ‘Pros and Cons’ provided for each spatial option and considers that this assessment would benefit from greater cross-reference to the proposed Strategic Objectives. The transport criteria provided within the Sustainability Appraisal and the criteria contained within the Sustainable Transport Strategy Broad Site Assessment should also be cross referenced.","","","","The SLP area adjoins Worcestershire’s highway network at the A46, to the east of the Teddington Hands roundabout, at the B4079 Cheltenham Road and at Hardwick Bank Road immediately east of the M5. These routes provide the key connections between the County and the SLP area and are most likely to be impacted by growth across the north of Gloucestershire, particularly at Tewkesbury and Ashchurch. WCC is particularly concerned about the transport impacts of SLP growth on the South Worcestershire network through the Bredon villages, at Evesham and through the villages north of the A46 between Ashchurch and Evesham. We are therefore keen to ensure that transport and land use planning policy is closely integrated with the SLP, so that the impact of future planned growth throughout Cheltenham, Tewkesbury andGloucester on Worcestershire’s transport network is appropriately managed and so that the network is able to facilitate the delivery of sustainable economic growth across the Plan area.\nThe SLP consultation document outlines that combined, the three district areas have a total need of 35,700 homes over the next 20-year period, although this includes unbuilt allocations within the adopted JCS and unbuilt developments with planning permissions. The consultation document also notes that currently, the M5 corridor is a magnet for employment growth because businesses, their supply chains, workers and consumers collectively depend upon a good-quality, strategic highway network. However, it is acknowledged that the M5 motorway junctions through the Plan area are subject to significant demand, congestion and delay and that the continued safe and efficient operation of the M5 can only be ensured with a transport strategy that results in a significant reduction in travel need and shift to more sustainable modes,particularly the Birmingham to Bristol rail link. As the SLP is developed, it is imperative that any improvements to Worcestershire’s transport network necessary to successfully deliver sustainable growth aspirations across the Plan area are identified, as set out in Government policy. Particular focus needs to be placed on Tewkesbury and Ashchurch, taking account of strategic growth emerging through the South Worcestershire Development Plan Review. In particular,WCC Highways would welcome further information regarding the intended approach to preparing the necessary transport evidence base and associated infrastructure strategy, underpinned by Gloucestershire’s strategic transport model (GC3M).\n[Infrastructure] - The SLP consultation document outlines that the new Plan will be required to set out policy requirements for the contributions expected from different types of development and where necessary, from different sites. This should set out the policy requirements for the level and types of affordable homes and supporting infrastructure, including transport. Policies of the Plan should also seek to ensure the timely provision of the infrastructure required to support the level of development proposed.WCC Highways considers the inclusion of a strategic transport policy within the new Plan that restricts development in line with the availability of necessary transport infrastructure would be beneficial, such as that currently included within the adopted JCS as Policy INF1: Transport Network. Such a policy would positively support proposals that address road safety and congestion. It should include for any necessary cross-boundary mitigation and for contributions towards the delivery of cross-boundary mitigation.\n[Q29.] WCC Highways considers that focussing housing growth and development at sites that are or can be made sustainable in transport terms and are located in proximity to public transport corridors/services and employment opportunities, would offer the best opportunities for reducing the need to travel by private car. WCC Highways notes that strategic growth at Tewkesbury Town is included in Scenarios 2 and 3, and at Ashchurch (Tewkesbury Garden Town) in Scenario 4. Strategic growth in these locations will be of particular interest to WCC Highways and we would expect that the potential traffic and transport implications of proposed development within Tewkesbury, on the A46, B4079, Tewkesbury Road and Hardwick Bank Road within Worcestershire, would be considered as part of the supporting transport assessment/evidence base. WCC Highways notes that there would be a number of challenges for identifying and delivering necessary highways and transport infrastructure with a Rural Dispersal development strategy. As the scale of any one allocation would be limited with development spread across a greater number of locations, there is less opportunity to achieve the necessary scale of development to give confidence that appropriate mitigation, to the local and strategic transport networks, could be provided to address the overall cumulative impact of the Plan. It is considered that the potential size and location of the allocations could be insufficient to both command and hence provide (through provision of funding) the necessary infrastructure to mitigate the cumulative impact of the proposed new development. Furthermore, the provision of more sustainable alternatives to the private car would be challenging due to the limited scale and indicative locations of the dispersed development allocations. In terms of location, employment development often contributes significantly to peakhour traffic, and hence there can be challenges to accommodating high levels of traveldemand, which may only exist for limited periods of the day on the local road network, particularly locally-strategic routes, such as the A46, B4079 and Tewkesbury Road. The attraction to business of locating in highly accessible locations is recognised, and we are aware that for many businesses, close proximity to strategic routes is essential. When considering the location and associated supporting infrastructure for new employment areas, any existing available capacity on locally-strategic routes including the A46, should not be considered as an alternative to providing local improvements to the sustainable modes network (i.e. pedestrian, cycle and bus networks) serving the proposed development areas.When considering potential site allocations and associated supporting infrastructure for new growth sites in the Plan area, WCC Highways requests that consideration isgiven to the planning of adequate transport infrastructure, including any necessaryhighway capacity improvements in Worcestershire to provide for cross-boundary movements.\n\nSustainable Transport Strategy Broad Site Assessment and Sustainability Appraisal\nA Sustainable Transport Strategy Broad Site Assessment (BSA) and Sustainability Appraisal (SA) (2023) has been made available alongside the SLP Issues and Options consultation document. \nThe BSA and SA use a rating system and impact scale to assess each of the six spatial options and provide a relative comparison of their performance against each of the identified transport sustainability and accessibility criteria. \nWCC Highways notes that the BSA and SA assess each of the six options against different transport criteria and utilise different indicators. As a result, the SA concludes that Scenarios 1, 4 and 6 have a positive impact against the Transport and Accessibility criteria and that Scenarios 1 and 4 perform best (more positively most often) overall, whereas the BSA concludes thatScenarios 1,2 and 3 perform best overall (Scenarios 1 and 2 significantly so). In particular, the New Strategic Settlements scenario (Scenario 4) typically performs less well against BSA objective 2 – facilitate viable and genuine alternatives to the private car, which is noted to be a Strategic Objective within the SLP consultation document. However, WCC Highways does acknowledge that the BSA is based on an assessment of existing transport services and infrastructure. \nAs outlined above, WCC Highways would welcome further engagement with the three district councils and Gloucestershire County Council with the aim of exploring the approach to the development of a more detailed transport evidence base required to support the Draft Plan, that includes an appraisal of the transport impacts of planned development in the SLP area on the South Worcestershire highway and transport network.\n\nNext Steps\nWorcestershire County Council requests that as the Strategic and Local Plan is progressed, we are engaged by the three district councils and Gloucestershire County Council. This engagement will help determine any potential impacts on Worcestershire’s transport network, particularly the South Worcestershire network proximate to the SLP area, and identify any necessary infrastructure improvements to be included within the Infrastructure Delivery Plan. In particular, we would welcome an early opportunity to discuss the approach to developing any transport appraisal to inform the stage 2 Regulation 18 consultation/the preferred growth strategy option and the necessary transport evidence base utilising the strategic transport model – GC3M, that will underpin later stages of the plan-making process."]
["Resident",null,20,"NO","Type of housing, flooding, traffic volumes, greenspaces and agriculture","No","Add protect farmland which is feeding us. Don't build houses wihtout the infrastructure. Don't build on flood plains. Put public electric chargers in every village","No","Add protect green open spaces and farmland","Encourage farmers to plant hedges and trees along edges of fields ie not in patches taking up land that can be used for food","All new buildings (houses and industrial) to have solar panels and batteries","Convert empty shops and offices and other brownfield sites before using farmland","Yes","","","Transport, doctors, schools, shops and churches","No","All new building should have solar panels","No","No, not all housing needs, need to be addressed by new build. Please deduct conversions of empty shops and offices etc. from calculation","","","","","","","","Road infrastructure e.g. further Severn Crossing","","","Convert empty shops and offices to low cost housing","","Roads, drains, flood protection of current housing, utilities","","","","","","","","Scenario 1: Urban concentration","","","Green belt and agricultural land should not be used for development"]
["Local Councillor","Local Councillor",25,"The list at 2.4 is comprehensive if slightly confused (by ‘climate change and adaptation’ we understand it to mean climate change mitigation and adaptation which are different concepts) but should also specifically mention housing for rent as well as ‘affordable’ housing for purchase, and nature recovery which is as urgent a priority as climate change. ","As a general principle, policymaking and decision-taking should generally happen at the lowest possible level.  The JSP should focus at strategic level on issues that inevitably cross district boundaries like housing provision and transport infrastructure and recognise and allow more local plans, specifically Neighbourhood Plans and locality-specific policies within the SLP, to determine issues that can be distinctively determined locally such as community facilities and conservation and enhancement of the built and natural environment, although clearly there are cross-cutting themes and some environmental policies like the holding of water in the landscape that should be looked at on a landscape scale. ","No","The draft vision immediately opens with statements about large scale developments and growth and repeatedly sets every subsequent paragraph in the context of growth, including references to “large-scale new developments” and “growth in sustainable locations’ which has in the past been code for unpopular urban extensions which in practice have delivered car-centred housing estates without any local or community facilities.  Growth as an overarching objective is not sustainable and sends entirely the wrong message about the purpose of a local plan in the 21st century which should be about the wellbeing and quality of life of its current and future inhabitants within a sustainable environment and a new, decentralised and sustainable model of prosperity.  The Vision barely mentions the environmental challenges of climate change mitigation and adaptation or the crisis in the natural environment.\n\nThe vision set out by the current JCS is much better: it begins with a vision of Gloucester, Cheltenham and Tewkesbury as “attractive and accessible places in which to live, work and socialise”.  It promises a “vibrant, competitive economy with increased job opportunities” attractive to investors. It promises to retain the “individual character” of communities and that these will be reflected in high quality new developments and improved infrastructure. Although the current JCS vision also neglects the environmental dimension.\nReplace constant references to growth with a vision of an area in which the health, wellbeing and quality of life of inhabitants is increased, in which communities will be better served by active travel and good public transport links and infrastructure, economic development has created sustainable prosperity reflecting new decentralised ways of working and the distinctiveness of local communities has been enhanced and not just protected.\n\nThe vision should much more clearly reflect the contribution the area should have made to climate change mitigation including a huge increase in local renewable energy and the planning of new mass public transit, better adaptation to the impacts of climate change specifically inevitable increases in flooding and a substantial and measurable recovery in the natural environment with increased biodiversity, strengthened ecological networks and better protected green and blue infrastructure.\n\nThe assumption that there will be focus on “large-scale development” in “sustainable locations” should be replaced with a commitment to human-scale environmentally-friendly development to meet identified needs, utilising the existing built-up area better and prioritising dispersed smaller, human-scale development. The commitments to the use of brownfield sites and improvement of town and city centres should be retained. The vision should say that where large-scale development has taken place, it will have delivered accessible local community facilities in the same location and have met the highest possible environmental standards including net zero carbon impact and significant nature biodiversity net gain on site.\n\nThe opaque language of “cultural offer” should be replaced with a clear commitment to respect and enhance the area’s distinctive built heritage of different eras, support local sport and outdoor activities both at major venues and in the community and provide a supportive environment for our important community and cultural festivals.","No","Although many of the specific contents including references to decarbonisation, biodiversity net gain, low and zero energy development are welcome, again there is too much constant emphasis on growth and some significant omissions detailed below. Remove constant references to growth as the reference point for other objectives like meeting the objectives of climate change which must be clear objectives in their own right.\n\nWe would suggest separating the objectives on the natural and built environments which each deserve attention and focus in their own right.\n\nClear reference to nature recovery as an overall objective should be added. This is not simply a matter for specific designated sites like the the AONB and SSSIs and new developments as the natural environment objectives imply.  The crisis in the natural environment is well understood now.  The UK is one of the most nature-depleted countries in the world and local plans can make an important contribution to helping nature recover, including by protecting and enhancing existing green and blue infrastructure such as brook lines and river banks and established hedgerows, biodiversity net gain on site where new development does take place and the reinforcement of nature recovery networks and other ecological connectivity (already well mapped by the Gloucestershire Natural Capital Mapping Project).\nThe objectives under sustainable transport should include the delivery of mass transit (or at least safeguarding potential future mass transit pathways in planning decision-making). Mass transit is already being considered by the county council and is very important for those of us in communities currently blighted by traffic congestion and the prospect of even heavier traffic in future, exacerbated by the lack of reliable alternatives for travel into town centres.\n\nThe objectives under ‘healthy and resilient communities’ are positive but could even more strongly emphasise that every new large- and even medium-size (50-300 dwellings) scale development should not just be supported by but must add to community facilities (the tendency today is to measure walking distances to an existing community facility and resist providing anything new). \n\nA commitment to make all new developments permeable to walking and cycling not a collection of car-led cul-de-sacs would be very welcome.\n\nThere is no reference to growing and enhancing the network of Local Green Spaces (currently 16 in Cheltenham including our own in Leckhampton) which provide an important range of ecosystem services including mental and physical health benefits, cleaner air, reduced carbon dioxide, free access to recreation, tranquility and darker skies and more gentle visual landscapes.\n\nThe reference to supporting development only in “areas that are not liable to flooding” is not realistic as climate change will increasingly put every area at risk of flooding including uphill areas like Leckhampton at risk from flash pluvial flooding from the hill. The JSP should support making all new development flood-resistant by design as is common in the Netherlands and elsewhere as well as the retrospective flood-proofing the older built environment. \n\nNatural flood management techniques, including planting to hold much more water in the landscape uphill, are particularly important to protect downhill areas like Warden Hill.  Floodwater flows should be pro-actively mapped at landscape scale not just on a site by site basis so that active natural management can take place uphill to protect areas like Warden Hill.\n\nLeckhampton in particular has a huge housing affordability gap.  The housing paragraphs make no reference to providing homes for young people or for rent which must surely be a priority.  The risk is that the SLP facilitates yet more executive homes in new developments that are unaffordable for local people, and in particular for local young people.\n\nThe paragraph on beautiful and safe places does not mention the existing built environment at all which must be protected by good conservation and design code policies but nevertheless be flexible enough to adapt to the challenges of climate change and the need, for instance, for local and household renewable energy.","The SLP should more clearly distinguish between climate change mitigation measures (net zero carbon impact in development, renewable energy and transition to low carbon travel and transport) and climate change adaptation (flood resilience in new and existing built environment, natural water management in the landscape, flood defences, heat resilience in new development and retrofitting of anti-heat measures such as natural planting, covered car parks and walkways).  \nEcological matters are not a subset of climate change. Nature recovery should be treated as an objective and strategic area in its own right including protecting and enhancing existing green and blue infrastructure and natural networks in the urban area, delivering a measurable improvements in a range of local ecosystem services.","All new development in the SLP area must now be net zero in its greenhouse gas impact once in use and the achievement of this onsite rather than through offsetting should be the norm and only departed from in exceptional circumstances such as listed building sites. Although guidance such as Cheltenham’s climate supplementary planning document (SPD) is helpful, The SLP should be wary of prescribing exactly how this should be achieved as this is an area of fast improving and changing costs and technology.\nElectric vehicle (EV) charging technology should also be strongly encouraged in policy. It should be the norm for new houses, factored into the site design of flats, offices and conversions of existing buildings.\nBatteries to store domestic renewable energy will also have an important part to play as costs fall and product lifetimes and reliability continue to improve. The SLP should include permissive policy that can allow stronger obligations to include batteries and make space for retrofit in new properties as technology improves.\nThe embedded carbon footprint of construction should also be net zero and the local plan should develop policy to incorporate this into local decision-making. We acknowledge that offsetting may continue to be an important element of this for some time to come.","The reuse of existing building infrastructure and the reuse, recycling and use of local materials should be imperatives, not only for environmental reasons but to contribute to local senses of place and history.","Yes","Yes","The Gloucestershire Natural Capital Mapping Project (GNCMP) has already mapped local areas of opportunity for biodiversity, carbon storage, food provision, local climate regulation, nature connectivity, soil health and water quality as well as the the Cotswold Nature Improvement Area (NIA) and the local Nature Recovery Network. This mapping should provide the important baseline data for planning decision-making and be specifically supported in policy.  The SLP should not create a more limited listing or mapping that undermines the important work of the GNCMP and weakens its status in decision-making.\nThe already designated Leckhampton Fields Local Green Space includes areas significant in the mapping referred to above and offers clear opportunities for enhancement in support of Biodiversity Net Gain and flood risk management (eg by new planting and better management by landowners) and recreation (through better signage and sensitively enhanced walkways). Local smallholdings in the same immediate area have been neglected and blighted by planning uncertainty in recent years but could be restored to their former use as valuable sources of local food production and we would see this as compatible with LGS status.\nWooded walkways in the Leckhampton LGS, along the line of Moorend Stream and the neighbouring Cheltenham Plan MD4 development area currently provide cool shaded pathways in summer and these should be more carefully mapped and protected in policy if development has not overtaken them by the time plan policies emerge.  With sensitive planting, the network of other pathways around the Leckhampton Local Green Space and the MD4 area (including the line of Hatherley Brook) offer further opportunities for the retention and creation of shaded walking routes and protection of biodiversity.\nThe Pilley Bridge Nature Reserve on the edge of our parish also offers a well-shaded walkway and  an area of rich biodiversity which has some scope to be extended, delivering recreational and biodiversity gain and additional carbon storage.\nBurrow’s Field, owned by CBC and managed by Leckhampton Rovers FC, borders the LGS and has already provided opportunities for new planting to deliver biodiversity gain and carbon storage. This could be supported further although its primary use as a recreational and sports field must be protected.\nLeckhampton Hill is already very well used for recreation and agricultural food production, very important as a pre-Roman historic site and rich in biodiversity including a large SSSI.  We would not want to see that balance disturbed and don’t support the use of Leckhampton Hill to enable major developments elsewhere to achieve Biodiversity Net Gain or offset visitor impact on the SAC which they should be delivering in their own local neighbourhoods. But we do obviously support biodiversity gain on the hill in principle and could support better visitor facilities for instance at the partly derelict and neglected Hill Farm (an engagement centre and café and perhaps restaurant as well as possible work spaces for rangers and local community organisations like FOLK would be very appropriate).\n","Public transport access points; accessible green space for walking, pet exercise and informal sports; local shops; primary care facilities, particularly GP surgeries but also local pharmacies; community facilities such as village halls; pubs and other small-scale commercial hospitality.\n","Yes","This council strongly supports policy to support the provision of local renewable energy in the SLP area a general principle and would not want this restricted to specific sites identified in the plan, especially as likely huge increases in government grants for community energy may unlock sites not anticipated to date.  Local renewable energy should certainly include local district heating networks and ground loops, household and community solar photovoltaics and solar thermal energy and air, ground and water source heat pumps (and not preclude hybrid heat pump technology).\nPlanning policy should actively support the installation of household photovoltaics, heat pumps and solar thermal panels including in conservation areas and on listed buildings where a positive solutions-based approach should be taken.\nSolar photovoltaic farms on agricultural land could be supported on lower grade agricultural land where this is genuinely shown to be the most sustainable option, bearing in mind possible impacts on local nature and food production, providing all other opportunities for solar photovoltaics have been fully explored.\nIn the wider local area sustainable biogas production from anaerobic digestion and tidal power (for instance from the Severn Estuary in the form of lagoons rather than the more environmentally disruptive barrage) could also make a contribution to local renewable energy supply and the SLP should explicitly support infrastructure improvements including grid upgrades to enable and support these should proposals come forward.","Yes","We are not aware if exceptional circumstances that would justify deviating from the standard method.","Yes","The SLP needs to properly recognise the environmental and spatial limits on development in the SLP area, and specifically in and around Cheltenham.  Development is constrained by:\n•\tThe Cotswolds National Landscape\n•\tUndesignated valued landscapes including the valued landscape at Leckhampton, the status of which under NPPF Paragraph 180 was reinforced in the recent inspector’s appeal decision APP/B1605/W/23/3317851 (CBC reference 21/02750/FUL)\n•\tThe vital remaining Green Belt which was already one of the smallest in the UK before the JCS reduced it by more than 700ha.  Green Belt, under planning law and the NPPF, is not a strictly environmental or landscape designation but is intended to prevent urban sprawl. It should have permanent boundaries capable of enduring beyond the plan period.\n•\tFlood plain which includes some areas of very high flood risk, although, as we point out above, rejecting any development in areas of flood risk in the era of climate change is unrealistic and should be replaced with an approach that builds flood resilience into any new development. \n•\tExisting dense urban development.  The town of Cheltenham and the city of Gloucester are already densely populated with very severe pressure on local road and transport infrastructure in particular and local services such as primary care, NHS dentistry and local acute hospitals. Leckhampton and Warden Hill already suffer severe daily traffic congestion on the Shurdington Road and Church Road.","Yes","Yes.  We should make particular provision in policy for housing for rent, particularly for those most at risk of homelessness on Cheltenham’s housing waiting list and for young people for whom the affordability gap in Warden Hill is high and in Leckhampton is particularly severe.  Annex 3 of our draft Neighbourhood Plan cites ONS data: the housing affordability gap is an estimate of the gap between the cost of local houses and the amount residents can borrow. The national average housing affordability gap is £42,272. In Warden Hill it is £52,910. In Leckhampton it is a staggering £226,948 - more than four times greater.  \n[The housing affordability gap estimates the gap between the cost of local houses and the amount residents can borrow, defined as the difference between the local median or lower quartile house price and 4.5 times local annual earnings (typical mortgage lending multiplier). Sources: ONS House Price Statistics for Small Areas Oct16-Sep17; ONS earnings data 2015/2016]\nThe SLP should also include policy in relation to short-term rental of domestic properties (Class C1; airbnbs) as this has the clear potential to take suitable homes out of the local housing market in areas of high tourist demand like ours. This issue is increasingly being recognised in national policymaking including the NPPF.","","This council has no strong position on how the need for traveller sites should be delivered although we do believe there is a moral obligation to provide adequate sites for traveller communities vulnerable to poverty, poor educational and health outcomes and discrimination.","","This council believes it is important to reflect the fast changing nature of work and employment taking the emphasise away from town centre employment and large retail sites served by commuter suburbs and towards an increasingly decentralised and dispersed model of work and shopping, with many more people able to work and shop remotely and from home without car travel and in ways that support health and wellbeing. This allows us to contemplate more dispersed development than ever before with people living in attractive communities with good access to local facilities in their own neighbourhoods, including flexible workspaces and good access to green spaces, served by good public transport and good quality ICT services, with major town centres that thrive on quality of live experience over retail volume with live entertainment, events and hospitality essential elements of the mix. We welcome the SLP’s emphasis on high speed broadband connectivity. Regeneration efforts should directed at urban areas with poor quality housing, poor access to green spaces and high levels of deprivation. Potential to measurably improve the wellbeing of local residents should inform economic and regeneration strategy rather than the pursuit of growth for its own sake.\nThe SLP should build on Gloucestershire’s strong tradition in high quality engineering and manufacturing to make sure there are sufficient light industrial sites to enable this sector to thrive.","Gloucestershire’s attractiveness as a business location has historically benefitted from its beautiful countryside, good transport links to all parts of the UK, rich sporting and cultural festivals and events and high quality schooling which have all contributed to a virtuous circle of prosperity.  We should resist the temptation to damage any of these pull factors for inward investment and location with reckless development and urban sprawl and focus instead on newer demands such as outstanding green energy and ICT infrastructure and flexible workspaces while ensuring that economic development is supported by improved public transport and that all communities benefit equally from our county’s prosperity.",""," Again, the SLP should resist further urban extensions to Cheltenham and Gloucester which have proved to be completely car-centred not sustainable in practice and threaten to hollow out our town centres in the long-term. The SLP should support more town centre living to rebuild town centres as places to live and enjoy as well as work. We recognise the challenges of delivering more town centre living in a sensitive built environment like Cheltenham’s but believe that other world cities offer many examples of imaginative concentrated urban development that has respected historic heritage and delivered environmental gains at the same time. The repurposing and rebuilding of increasingly redundant town centre retail and commercial space would reflect the changing nature of work and shopping and encourage \nLarge-scale supermarket sites have proliferated in recent decades to the detriment of local retailers and High Streets. As shopping habits for groceries in particular have also changed to much more home delivery, the SLP should anticipate reclaiming some of these sites for homes and local retail and support this transition in policy. This will also help local retailers.\nIf planning policy can designate some areas for local independent and small retail and hospitality businesses it should do so, further encouraging distinctive commercial zones like the Bath Road and the Suffolk Road area.","","","","As the Taylor Review said back in 2008: “without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them.”\nThe SLP should resist further urban extensions to Cheltenham and Gloucester and support small-scale development at dispersed rural locations supported by good public transport links that will support the viability of rural shops, pubs and schools and thereby strengthen communities and make them attractive locations for flexible high value businesses.","","Yes","One important point to make is that the Pros and Cons in the SLP document imply that all these scenarios are mutually exclusive (eg ‘Con’ listed several times: “On its own, along with baseline\ncapacity, would not deliver sufficient new homes and jobs”). In reality the best scenario is likely to be a combination.\nAlongside similar options to those listed in the SLP document, including dispersed development and urban concentration around main centres, the West Oxfordshire Local Plan Focussed Consultation (August 2023) also offered a scenario called ‘Village clusters’ which could also be adopted by the SLP. The document describes how this village cluster option (its Scenario 6) differs from dispersed development (its Scenario 5):\n“Like Scenario 5, Scenario 6 is based on a dispersed approach to the future pattern of growth but, instead of villages being treated separately, they would be considered collectively in small groups or ‘clusters’ based on the services and facilities they are able to cumulatively offer.\nEach village ‘cluster’ would then be the focus for an appropriate and proportionate amount of growth.\nThe logic of this approach is rooted in the NPPF which emphasises that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services and that where there are groups of smaller settlements, development in one village may support services in a village nearby.”\nThis additional scenario should be considered here.","No","The listed ‘Pros’ and ‘Cons’ are very unbalanced and many are very contentious, giving the impression of pre-determined preferences and arguments being made rather than views being genuinely consulted on:\n\n•\tScenario 1, urban concentration, has 5 pros and 7 cons, one of which is that ’on its own, along with baseline capacity, would not deliver sufficient new homes and jobs’ which is probably true of every scenario.  Its other cons are very dubious - why should urban concentration harm heritage settings, provide only a limited mix of tenure type and opportunities to tackle climate change and divert economic growth to locations outside the SLP area? And pros listed for other urban options like ‘Would provide opportunity to be supported by high quality public transport infrastructure such as Mass Rapid Transit’ are left out for this scenario despite applying equally well.\n•\tScenario 2, urban extensions, has 6 pros and only 3 cons, not including urban sprawl, the increased dependence on car use that has characterised these developments in recent decades and their toxic unpopularity (because evidence predictably shows the most regularly used countryside is obviously that closest to the largest urban populations).\n•\tScenario 3 again repeats the Con that ’on its own, along with baseline capacity, would not deliver sufficient new homes and jobs’ which is almost certainly true of all scenarios.\n•\tScenario 4 again has an unbalanced list implying this scenario rules out others (‘Investment in rural shops, services and facilities would not be supported’ ‘may not support the vitality and viability of larger city and town centres’) and including several highly contentious arguments (‘unlikely to provide for all of the new homes and jobs needed resulting in worsening housing unaffordability and constrained economic growth’!)\n•\tScenario 5, rural dispersal, has only 5 short pros and 9 lengthy cons!  Some of the cons are again highly contentious that could apply equally to other scenarios (eg ‘May not provide a suitable range of locations and types of employment space’ and ‘Would likely harm the character and setting of existing settlements and surrounding countryside’ - as do urban extensions!)\n•\tScenario 6, by contrast, has 7 long pros and 5 short cons!","Scenario 1: Urban concentration; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","",{"$cut":{"chars":19035,"head":"[Q1] This council supports a long-term plan of at least 20 years, if not 25 years, that provides certainty for local communities and a breathing space for volunteer-led organisations like ours. This revision of the 2017 JCS and 2020 Cheltenham Plan after such a short period will consume years of effort and resources councils can ill afford and undermines trust amongst local people who perceive almost constant battles over planning policy.\n\n[Q8] The Government’s own impact assessment (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/839610/net-gain-ia.pdf) acknowledges that 10% BNG may not go beyond “no net loss”.  Two local authorities have already adopted targets above 10% and six are considering BNG targets of 20% (https://cieem.net/new-briefing-says-10-percent-bng-not-enough/). This is a high demand area with intense pressure from commercial developers for new development.  We have shown in Leckhampton already that new development can be delivered to very high environmental standards with substantially more than 10% biodiversity net gain (as well as tough affordability components and very high net zero standards).  If we can’t do it here, who can? \n[Q26] Regardless of the size of specific new settlements, the following infrastructure is already urgently needed and sites and routes should certainly be supported in the SLP:\n•\tStronger natural green and blue infrastructure including brook and river lines and banks, hedgerow and woodland and important habitats and connectivity.\n•\tPublic transport including mass transit to relieve the pressure of cars on major arteries like the Shurdington Road. The SLP should map and protect key potential routes.\n•\tRenewable energy infrastructure including local heat networks and ground loops and potentially local solar and wind generation\n•\tBetter quality and better connected walking and cycling routes for both existing and new developments including physically distinct cycle lanes of the kind that are increasingly becoming the norm in central London and other major cities\n•\tLocal shops within easy walking distance, in contrast to development here in Leckhampton in the area of Kidnappers Lane and Farm Lane where over a thousand new houses have been built or planned in recent decades without a single new local shop, encouraging far more car use than was necessary.\n•\tHealth facilities, especially  NHS dentistry and GP/primary care, reflecting the increased demand for primary care since the pandemic which has placed local GP surgeries under unmanageable pressure. \nYes.  See subsequent sections that address some important policy areas covered by the existing JCS and Cheltenham Plan and some directly relevant to Leckhampton which should be considered.\n\nII. Current Joint Core Strategy policies \n\nAs well as those which refer to issues dealt with in the specific consultation questions above, the council would draw attention to the following JCS policies which address issue of particular importance to Leckhampton and Warden Hill:\n\nJCS Policy SD3: Sustainable Design and Construction addresses the important issue of design standards in new development to increase energy efficiency, minimise waste and avoid unnecessary air and other pollution but has proved much too weak in practice.  \n\nPolicy should be included in the SLP in this area but set a clear expectation of net zero carbon impact, no fossil gas connection, a specific and significant biodiversity net gain (eg 20%) and Building with Nature or similar standard.  Design should facilitate local best practice in recycling and waste collection (eg multiple separated kerbside waste in Cheltenham borough) and promote stringent air quality targets (eg smoke control zone standard in Cheltenham)\n\nJCS Policy SD4: Design Requirements addresses character and sense of place and urban design, landscape and connectivity, amongst other issues. It includes a great deal of very positive policy but has had very little impact on decision-making in practice with many new estates seemingly from off the peg design manua"}}]
["Local Councillor","Local Councillor",20,"The list at 2.4 is comprehensive but we should separately identify ‘climate change and adaptation’ as\n•\tclimate change mitigation (ie carbon reduction, renewable energy, EV charging etc)\n•\tclimate change adaptation (including for more & regular flooding, extreme summer heat etc)\nwhich are different concepts.  We should also specifically mention \n•\thousing for rent as well as ‘affordable’ housing for purchase, and \n•\tnature recovery which is as urgent a priority as climate change. ","We should practice the principle of subsidiarity.  \n\nIn other words, as a general principle, policymaking and decision-taking should happen at the lowest possible level.  The JSP should focus at strategic level on issues that inevitably cross district boundaries - most obviously large scale housing provision and transport infrastructure - and recognise and allow more local policies within the SLP to determine issues that can be distinctively determined locally such as community facilities and the conservation and enhancement of the built and natural environment as well as those more obviously location-specific policies covering particular local areas.  There will clearly be cross-cutting themes like climate change and some environmental policies like the holding of water in the landscape that should be looked at on a landscape scale, but we should not force districts into an agreed policy straitjacket just for the sake of it. \n\nAs an example, if one district feels justified in applying stricter environmental or social housing policies on new developments, we should be able to do so.","No","I hope the draft vision and objectives will be significantly improved as the SLP progresses.It could do worse than return to the much better wording used in the existing JCS.\n\nThe draft SLP vision immediately opens with statements about large scale developments and growth and repeatedly sets every subsequent paragraph in the context of growth, including references to “large-scale comprehensively-planned new developments” and “growth in sustainable locations” which has in the past been code for unpopular urban extensions which, in practice, have delivered car-centred housing estates without any local or community facilities which have failed to reduce Cheltenham’s housing waiting list and often failed to provide appropriate new dwellings for younger residents.  \n\nGrowth as an overarching objective is not sustainable and sends entirely the wrong message about the purpose of a local plan in the 21st century. These should be about the wellbeing, happiness and quality of life of its current and future inhabitants within a sustainable environment and a new, decentralised and sustainable model of prosperity. \n\nInstead the Vision barely mentions the environmental challenges of climate change mitigation and adaptation or the crisis in the natural environment (the first two key issues rightly identified in para 3.3 of the consultation document).   The paragraph “People’s housing needs” needs to reflect the urgent need to provide social housing for rent and genuinely affordable housing for people aspiring to buy.  But it is right in emphasising the priority on brownfield sites, the preservation of valuable green spaces and the vital role of city centres, town centres and high streets.  \n\nThe vision set out by the current JCS is much better: it begins with a vision of Gloucester, Cheltenham and Tewkesbury as “attractive and accessible places in which to live, work and socialise”.  It promises a “vibrant, competitive economy with increased job opportunities” attractive to investors. It promises to retain the “individual character” of communities and that these will be reflected in high quality new developments and improved infrastructure. Although the current JCS vision also neglects the environmental dimension.\n\nReplace constant references to growth with a vision of an area in which the health, wellbeing, happiness and quality of life of inhabitants is increased, in which communities will be better served by active travel and good public transport links and infrastructure, economic development has created sustainable prosperity reflecting new decentralised ways of working and the distinctiveness of local communities has been enhanced and not just protected.\n\nThe vision should much more clearly reflect the contribution the area should have made to climate change mitigation including a huge increase in local renewable energy and the planning of new mass public transit, better adaptation to the impacts of climate change specifically inevitable increases in flooding and a substantial and measurable recovery in the natural environment with increased biodiversity, strengthened ecological networks and better protected green and blue infrastructure.\n\nThe assumption that there will be focus on “large-scale development” in “sustainable locations” should be replaced with a commitment to human-scale environmentally-friendly development to meet identified needs, utilising the existing built-up area better and prioritising dispersed smaller, human-scale development. The commitments to the use of brownfield sites and improvement of town and city centres should be retained. The vision should say that where large-scale development has taken place, it will have delivered accessible local community facilities in the same location and have met the highest possible environmental standards including net zero carbon impact and significant nature biodiversity net gain on site.\n\nThe opaque language of “cultural offer” should be replaced with a clear commitment to respect and enhance the area’s distinctive built heritage of different eras, support local sport and outdoor activities both at major venues and in the community and provide a supportive environment for our important community and cultural festivals.","","Although many of the specific contents including references to decarbonisation, biodiversity net gain, low and zero energy development are welcome, again there is too much constant emphasis on growth and some significant omissions detailed below.\n\nRemove constant references to growth as the reference point for other objectives like meeting the objectives of climate change which must be clear objectives in their own right.\n\nThe draft strategic objectives (DSOs) include very good sections on business and healthy and resilient communities but others need a lot of work, eg\n\n\n•\tClimate  DSOs 1-8 mix up climate mitigation and adaptation which are quite separate and need to be separate sets of strategic objectives. And flooding is not the only reason we need to urgently adapt to climate change: extreme storms, extreme summer heat and the need to provide migration pathways for species are amongst the many others. So policies will need to plan for more sheltered pathways and public spaces, external shutters, natural through ventilation and planting to reduce urban heat and so on.\n•\tClimate DSO 1 should be clearly setting the expectation that all new development achieves at least net zero emissions in operation, not ‘low carbon’; \n•\t4 is quite muddled. How can shops, services etc be delivered ‘through’ walking, cycling or public transport? I think what it means is that shops, services etc must be provided and/or easily accessible by walking, cycling and public transport and it should say this.\n•\t5 could more specifically set the pro-active delivery of renewable energy and local energy networks as a strategic objective.\n•\t6 is unrealistic.  All areas are increasingly liable to flooding. Many urban areas around the world have learned to adapt to higher flood risk from good storm drains in Delhi to floating houses in New Orleans to stilts in Dhaka (see also https://www.re-thinkingthefuture.com/designing-for-typologies/a2295-10-examples-of-flood-resistant-architecture-around-the-world/). As with the welcome emphasis on natural flood management in this para, the point is to work with nature not against it.   Natural flood management techniques, including planting to hold much more water in the landscape uphill, are particularly important to protect downhill/downriver areas like Warden Hill and Hesters Way in Cheltenham as well as Tewkesbury and Gloucester.  Floodwater flows should be pro-actively mapped at landscape scale not just on a site by site basis so that active natural management can take place uphill to protect areas like these. \n•\t7 could be much clearer and emphasise the importance of low-waste and recycling-friendly design even in compact urban locations \n•\t8 is great!\n\nThe business and city and town centre objectives are much better although business DSO 1 refers rather incongruously to “the green growth”. Making sure that new commercial development is properly sustainable with net zero emissions and ideally renewable energy generation onsite, has good transport-friendly options (for instance showers for cyclists) and delivers significant biodiversity net gain could be an important separate DSO.  Business DSO 5 is a bit thin given the extraordinary range of visitor destinations from neolithic sites like Belas Knapp and Crickley Hill, medieval Tewkesbury,  Roman, medieval and Georgian Gloucester and Regency Cheltenham and the variety of sporting and cultural festivals of national significance, as well as a thriving live music scene - all of which could benefit from sympathetic planning policies. City & town centre DSAs could include pro-actively adapting to the nature and climate emergencies even in heritage areas   with a clear focus on finding solutions rather then erecting obstacles.\n\nThe housing DSOs should specifically reference young people as well as older persons and mention the importance of high quality housing for rent as well as affordable housing for ownership.\n\nThe design DSOs are good. The emphasis on beauty and sustainability is very welcome.\n\nThe transport DSOs do not include the critically important objective of facilitating mass transit as the only feasible way to tackle increasingly intolerable and unsustainable congestion and car pollution in urban areas and centres of population including urgently identifying, mapping and safeguarding mass transit routes (eg Quedgelely - Gloucester - Churchdown - GCHQ - Cheltenham - Prestbury Park - Bishop’s Cleeve).\n\nThe DSAs relating to the conservation and enhancement of the natural and historic environments should be separated and improved:\n•\tThe ‘historic’ environment DSO 1 should specifically mention the range from the great historic buildings like the Cathedral and Pump Room through to local character areas reflecting periods in time.  A separate DSO should spell out the ambition to sensitively introduce low and zero carbon technology wherever possible in harmony with these historic settings.   Another DSA could emphasise separately the protection of our many archaeological and ancient historic sites and also their significant surrounding landscapes (now being much more effectively mapped than in previous eras through increasing use of GIS, lidar, satellite imagery and other new technologies).\n•\tThe natural environment DSOs should be a separate set emphasising the existential nature emergency and the importance of ecology and nature recovery as well as biodiversity net gain.\n•\tThis is not simply a matter for specific designated sites like the the AONB and SSSIs and new developments as the natural environment objectives imply.  The crisis in the natural environment is well understood now.  The UK is one of the most nature-depleted countries in the world and local plans can make an important contribution to helping nature recover, including by protecting and enhancing existing green and blue infrastructure such as brook lines and river banks and established hedgerows, biodiversity net gain on site where new development does take place and the reinforcement of nature recovery networks and other ecological connectivity (already well mapped by the Gloucestershire Natural Capital Mapping Project).\n•\tThere is no reference to growing and enhancing the network of Local Green Spaces (currently 16 in Cheltenham) which provide an important range of ecosystem services including mental and physical health benefits, cleaner air, reduced carbon dioxide, free access to recreation, tranquility and darker skies and more gentle visual landscapes.\n\nThe DSOs under ‘healthy and resilient communities’ are positive but could even more strongly emphasise that every new large- and even medium-size (50-300 dwellings) scale development should not just be supported by but must add to community facilities (the tendency today is to measure walking distances to an existing community facility and resist providing anything new). \nA commitment to make all new developments permeable to walking and cycling not a collection of car-led cul-de-sacs would be very welcome.","The SLP should more clearly distinguish between climate change mitigation measures (net zero carbon impact in development, renewable energy and transition to low carbon travel and transport) and climate change adaptation (flood resilience in new and existing built environment, natural water management in the landscape, flood defences, heat resilience in new development and retrofitting of anti-heat measures such as natural planting, covered car parks and walkways).  \n\nEcological matters are not a subset of climate change. Nature recovery should be treated as an objective and strategic area in its own right including protecting and enhancing existing green and blue infrastructure and natural networks in the urban area, delivering a measurable improvements in a range of local ecosystem services.","All new development in the SLP area must now be net zero in its greenhouse gas impact once in use and the achievement of this onsite rather than through offsetting should be the norm and only departed from in specific exceptional circumstances such as listed building sites. Although guidance such as Cheltenham’s climate supplementary planning document (SPD) is helpful, The SLP should be wary of prescribing exactly how this should be achieved as this is an area of fast improving and fast changing costs and technology.\n\nThe embedded carbon footprint of construction should also be net zero although we recognise there is a limit to the extent a local plan can mandate this and that offsetting may continue to be an important element of this for some time to come.","The reuse of existing building infrastructure and the reuse, recycling and use of local materials should be imperatives, not only for environmental reasons but to contribute to local senses of place and history.","Yes","Yes","The Gloucestershire Natural Capital Mapping Project (GNCMP) has already mapped local areas of opportunity for biodiversity, carbon storage, food provision, local climate regulation, nature connectivity, soil health and water quality as well as the the Cotswold Nature Improvement Area (NIA) and the local Nature Recovery Network. This mapping should provide the important baseline data for planning decision-making and be specifically supported in policy.  The SLP should not create a more limited listing or mapping that undermines the important work of the GNCMP and weakens its status in decision-making.\n\nThe already designated Local Green Spaces in Cheltenham and other privately owned green spaces like Timbercombe Lane include areas significant in the mapping referred to above and offer clear opportunities for enhancement in support of Biodiversity Net Gain and flood risk management (eg by new planting and better management by landowners) and recreation (through better signage and sensitively enhanced walkways).  \n\nLeckhampton Hill in my own ward is already very well used for recreation and agricultural food production, very important as a pre-Roman historic site and rich in biodiversity including a large SSSI.  I am cautious about the the use of Leckhampton Hill to enable major developments elsewhere to achieve Biodiversity Net Gain or offset visitor impact on the SAC which they should be delivering in their own local neighbourhoods. But I do obviously support biodiversity gain on the hill in principle and I would support better visitor facilities for instance at the partly derelict and neglected Hill Farm (an engagement centre and café and perhaps restaurant as well as possible work spaces for rangers and local community organisations like FOLK would be very appropriate).\n\nSeveral new Local Green Spaces should be included, including:\n•\tSouthcourt Green in Leckhampton (connecting Southcourt Drive and Southcourt Close GL53),\n•\tHardwick Green, part of Hardwick campus at Marsh Lane\n•\tThe Green at Westdown Gardens\n","Public transport access points; accessible green space for walking, pet exercise and informal sports; local shops; primary care facilities, particularly GP surgeries but also local pharmacies; community facilities such as village halls; pubs and other small-scale commercial hospitality.","","SLP policy should strongly support the provision of local renewable energy as a general principle and this should not be restricted to specific sites identified in the plan, especially as likely huge increases in government grants for community energy may unlock sites not anticipated to date.  Local renewable energy should certainly include local district heating networks and ground loops, household and community solar photovoltaics and solar thermal energy and air, ground and water source heat pumps.\n\nPlanning policy should actively support the installation of household photovoltaics, heat pumps and solar thermal panels including in conservation areas and on listed buildings where a positive solutions-based approach should be taken.\n\nSolar photovoltaic farms on agricultural land could be supported where this is genuinely shown to be the most sustainable option, bearing in mind possible impacts on local nature and food production.\n\nHighly efficient onshore wind in the most appropriate locations based on wind mapping should be strongly supported.  Given the climate emergency, this should include areas of landscape value.\n\n‘Energy from waste’ is at the bottom of the waste hierarchy (reduce/reuse/recycle) and should not be supported except in the case of more sustainable anaerobic digestion using organic waste and producing biogas. Incineration for instance is not sustainable as it diverts waste from recycling and reuse and produces highly toxic residue.\n\nIn the wider local area tidal power (for instance from the Severn Estuary in the form of lagoons rather than the more environmentally disruptive barrage) could also make a valuable contribution to local renewable energy supply and the SLP should explicitly support infrastructure improvements including grid upgrades to enable and support these should proposals come forward.","Yes","Yes. I’m not aware of exceptional circumstances that would justify deviating from the standard method.","Yes","Yes. It is better to have realistic targets that are actually met than a repeat of the unrealistic JCS targets which have not been consistently met and have led to planning by appeal.\n\nThe SLP needs to properly recognise the environmental and spatial limits on development in the SLP area, and specifically in and around Cheltenham.  Development is constrained by:\n•\tThe Cotswolds National Landscape\n•\tUndesignated valued landscapes including the valued landscape at Leckhampton, the status of which under NPPF Paragraph 180 was reinforced in the recent inspector’s appeal decision APP/B1605/W/23/3317851 (CBC reference 21/02750/FUL)\n•\tThe vital remaining Green Belt which was already one of the smallest in the UK before the JCS reduced it by more than 700ha.  Green Belt, under planning law and the NPPF, is not a strictly environmental or landscape designation but is intended to prevent urban sprawl. It should have permanent boundaries capable of enduring beyond the plan period.\n•\tFlood plain which includes some areas of very high flood risk, although, as mentioned above, rejecting any development in areas of flood risk in the era of climate change is unrealistic and should be replaced with an approach that builds flood resilience into any new development. \n•\tExisting dense urban development.  The town of Cheltenham and the city of Gloucester are already densely populated with very severe pressure on local road and transport infrastructure in particular and local services such as primary care, NHS dentistry and local acute hospitals.  ","Yes","Yes.  We should make particular provision in policy for housing for rent, particularly for those most at risk of homelessness on Cheltenham’s housing waiting list and for young people.","","There is a moral obligation to provide adequate sites for traveller communities vulnerable to poverty, poor educational and health outcomes and discrimination.","There is a moral obligation to provide adequate sites for traveller communities vulnerable to poverty, poor educational and health outcomes and discrimination.","The SLP should reflect the fast changing nature of work and employment taking the emphasis away from town centre employment and large retail sites served by commuter suburbs and towards an increasingly decentralised and dispersed model of work and shopping, with many more people able to work and shop remotely and from home without car travel and in ways that support health and wellbeing. \n\nRural villages and communities will become more viable with modest development, adding vital numbers to local schools and primary care, and vital footfall to local shops, post offices, pubs and other services.\n\nThis should allow the SLP to support more dispersed development than ever before with people living in attractive communities with good access to local facilities in their own neighbourhoods, including flexible workspaces and good access to green spaces, served by good public transport and good quality ICT services, with major town centres that thrive on quality of live experience over retail volume with live entertainment, events and hospitality essential elements of the mix. Regeneration efforts should directed at urban areas with poor quality housing, poor access to green spaces and high levels of deprivation. Potential to measurably improve the wellbeing of local residents should inform economic and regeneration strategy rather than the pursuit of growth for its own sake.","Gloucestershire’s attractiveness as a business location has historically benefitted from its beautiful countryside, good transport links to all parts of the UK, rich sporting and cultural festivals and events and high quality schooling which have all contributed to a virtuous circle of prosperity.  We should resist the temptation to damage any of these pull factors for inward investment and location with reckless development and urban sprawl and focus instead on newer demands such as outstanding green energy and ICT infrastructure and flexible workspaces while ensuring that economic development is supported by improved public transport and that all communities benefit from that prosperity the benefits of which have not always been evenly distributed.","As the Taylor Review said back in 2008: “without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them.”\n\nThe SLP should resist further urban extensions to Cheltenham and Gloucester and support small-scale development at dispersed rural locations supported by good public transport links that will support the viability of rural shops, pubs and schools and thereby strengthen communities and make them attractive locations for flexible high value businesses.","Again, the SLP should resist further urban extensions to Cheltenham and Gloucester which have proved to be completely car-centred not sustainable in practice and threaten to hollow out our town centres in the long-term. The SLP should support more town centre living to rebuild town centres as places to live and enjoy as well as work. We recognise the challenges of delivering more town centre living in a sensitive built environment like Cheltenham’s but believe that other world cities offer many examples of imaginative concentrated urban development that has respected historic heritage and delivered environmental gains at the same time. The repurposing and rebuilding of increasingly redundant town centre retail and commercial space would reflect the changing nature of work and shopping and encourage \n\nLarge-scale supermarket sites have proliferated in recent decades to the detriment of local retailers and High Streets. As shopping habits for groceries in particular have also changed to much more home delivery, the SLP should anticipate reclaiming some of these sites for homes and local retail and support this transition in policy. This will also help local retailers.\n\nIf planning policy can designate some areas for local independent and small retail and hospitality businesses it should do so, further encouraging distinctive commercial zones like the Bath Road and the Suffolk Road area.","As the Taylor Review said back in 2008: “without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them.”\n\nThe SLP should resist further urban extensions to Cheltenham and Gloucester and support small-scale development at dispersed rural locations supported by good public transport links that will support the viability of rural shops, pubs and schools and thereby strengthen communities and make them attractive locations for flexible high value businesses.","Regardless of the size of specific new settlements, the following infrastructure is already urgently needed and sites and routes should certainly be supported in the SLP:\n•\tStronger natural green and blue infrastructure including brook and river lines and banks, hedgerow and woodland and important habitats and connectivity.\n•\tPublic transport including mass transit to relieve the pressure of cars on major arterial roads. The SLP should map and protect key potential routes.\n•\tRenewable energy infrastructure including local heat networks and ground loops and potentially local solar and wind generation\n•\tBetter quality and better connected walking and cycling routes for both existing and new developments including physically distinct cycle lanes of the kind that are increasingly becoming the norm in central London and other major cities\n•\tLocal shops within easy walking distance, in contrast to the development that has taken place in areas like Leckhampton where over a thousand new houses have been or are being built without a single new local shop, encouraging far more car use than was necessary.\n•\tHealth facilities, especially  NHS dentistry and GP/primary care, reflecting the sustained increase in demand for primary care since the pandemic which has placed local GP surgeries under unmanageable pressure. ","Regardless of the size of specific new settlements, the following infrastructure is already urgently needed and sites and routes should certainly be supported in the SLP:\n•\tStronger natural green and blue infrastructure including brook and river lines and banks, hedgerow and woodland and important habitats and connectivity.\n•\tPublic transport including mass transit to relieve the pressure of cars on major arterial roads. The SLP should map and protect key potential routes.\n•\tRenewable energy infrastructure including local heat networks and ground loops and potentially local solar and wind generation\n•\tBetter quality and better connected walking and cycling routes for both existing and new developments including physically distinct cycle lanes of the kind that are increasingly becoming the norm in central London and other major cities\n•\tLocal shops within easy walking distance, in contrast to the development that has taken place in areas like Leckhampton where over a thousand new houses have been or are being built without a single new local shop, encouraging far more car use than was necessary.\n•\tHealth facilities, especially  NHS dentistry and GP/primary care, reflecting the sustained increase in demand for primary care since the pandemic which has placed local GP surgeries under unmanageable pressure. ","As the Taylor Review said back in 2008: “without change we will simply repeat the mistakes of recent decades, creating unattractive developments of housing estates encircling our rural towns and larger villages, and we will fail to stem the trend of smaller villages becoming dormitory settlements of commuters and the retired, ever less affordable for those who work within them.”\n\nThe SLP should resist further urban extensions to Cheltenham and Gloucester and support small-scale development at dispersed rural locations supported by good public transport links that will support the viability of rural shops, pubs and schools and thereby strengthen communities and make them attractive locations for flexible high value businesses.","","Yes","One important point to make is that the Pros and Cons in the SLP document imply that all these scenarios are mutually exclusive (eg ‘Con’ listed several times: “On its own, along with baseline\ncapacity, would not deliver sufficient new homes and jobs”). In reality the best scenario is likely to be a combination.\n\nAlongside similar options to those listed in the SLP document, including dispersed development and urban concentration around main centres, the West Oxfordshire Local Plan Focussed Consultation (August 2023) also offered a scenario called ‘Village clusters’ which could also be adopted by the SLP. The document describes how this village cluster option (its Scenario 6) differs from dispersed development (its Scenario 5):\n\n“Like Scenario 5, Scenario 6 is based on a dispersed approach to the future pattern of growth but, instead of villages being treated separately, they would be considered collectively in small groups or ‘clusters’ based on the services and facilities they are able to cumulatively offer.\n\nEach village ‘cluster’ would then be the focus for an appropriate and proportionate amount of growth.\n\nThe logic of this approach is rooted in the NPPF which emphasises that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services and that where there are groups of smaller settlements, development in one village may support services in a village nearby.”\n\nThis additional scenario should be considered here.","No","The listed ‘Pros’ and ‘Cons’ are very unbalanced and many are very contentious, giving the impression of pre-determined preferences and arguments being made rather than views being genuinely consulted on:\n\n•\tScenario 1, urban concentration, has 5 pros and 7 cons, one of which is that ’on its own, along with baseline capacity, would not deliver sufficient new homes and jobs’ which is probably true of every scenario.  Its other cons are very dubious - why should urban concentration harm heritage settings, provide only a limited mix of tenure type and opportunities to tackle climate change and divert economic growth to locations outside the SLP area? And pros listed for other urban options like ‘Would provide opportunity to be supported by high quality public transport infrastructure such as Mass Rapid Transit’ are left out for this scenario despite applying equally well.\n•\tScenarios 2, urban extensions, have 6 pros and only 3 cons, not including urban sprawl, the increased dependence on car use that has characterised these developments in recent decades and their toxic unpopularity (because evidence predictably shows the most regularly used countryside is obviously that closest to the largest urban populations).\n•\tScenario 3 again repeats the Con that ’on its own, along with baseline capacity, would not deliver sufficient new homes and jobs’ which is almost certainly true of all scenarios.\n•\tScenario 4 again has an unbalanced list implying this scenario rules out others (‘Investment in rural shops, services and facilities would not be supported’ ‘may not support the vitality and viability of larger city and town centres’) and including several highly contentious arguments (‘unlikely to provide for all of the new homes and jobs needed resulting in worsening housing unaffordability and constrained economic growth’!)\n•\tScenario 5, rural dispersal, has only 5 short pros and 9 lengthy cons!  Some of the cons are again highly contentious that could apply equally to other scenarios (eg ‘May not provide a suitable range of locations and types of employment space’ and ‘Would likely harm the character and setting of existing settlements and surrounding countryside’ - as do urban extensions!)\n•\tScenario 6, by contrast, has 7 long pros and 5 short cons!","Scenario 1: Urban concentration; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal","","","[Q8] Yes.  The Government’s own impact assessment (https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/839610/net-gain-ia.pdf) acknowledges that 10% BNG may not go beyond “no net loss”.  Two local authorities have already adopted targets above 10% and six are considering BNG targets of 20% (https://cieem.net/new-briefing-says-10-percent-bng-not-enough/). This is a high demand area with intense pressure from commercial developers for new development.  We already have new development in Cheltenham being delivered to very high environmental standards with substantially more than 10% biodiversity net gain (as well as tough affordability components and very high net zero standards).  If we can’t do it here, who can?  \n\n[Q26] Regardless of the size of specific new settlements, the following infrastructure is already urgently needed and sites and routes should certainly be supported in the SLP:\n•\tStronger natural green and blue infrastructure including brook and river lines and banks, hedgerow and woodland and important habitats and connectivity.\n•\tPublic transport including mass transit to relieve the pressure of cars on major arterial roads. The SLP should map and protect key potential routes.\n•\tRenewable energy infrastructure including local heat networks and ground loops and potentially local solar and wind generation\n•\tBetter quality and better connected walking and cycling routes for both existing and new developments including physically distinct cycle lanes of the kind that are increasingly becoming the norm in central London and other major cities\n•\tLocal shops within easy walking distance, in contrast to the development that has taken place in areas like Leckhampton where over a thousand new houses have been or are being built without a single new local shop, encouraging far more car use than was necessary.\n•\tHealth facilities, especially  NHS dentistry and GP/primary care, reflecting the sustained increase in demand for primary care since the pandemic which has placed local GP surgeries under unmanageable pressure. \n\nSee subsequent sections that address some important policy areas covered by the existing JCS and Cheltenham Plan which should be considered. II. Current Joint Core Strategy policies \n\n\nJCS Policy SD3: Sustainable Design and Construction addresses the important issue of design standards in new development to increase energy efficiency, minimise waste and avoid unnecessary air and other pollution but has proved much too weak in practice.  \n\nPolicy should be included in the SLP in this area but set a clear expectation of net zero carbon impact, no fossil gas connection, a specific and significant biodiversity net gain (eg 20%) and Building with Nature or similar standard.  Design should facilitate local best practice in recycling and waste collection (eg multiple separated kerbside waste in Cheltenham borough) and promote stringent air quality targets (eg smoke control zone standard in Cheltenham)\n\n\nJCS Policy SD4: Design Requirements addresses character and sense of place and urban design, landscape and connectivity, amongst other issues. It includes a great deal of very positive policy but has had very little impact on decision-making in practice with many new estates seemingly from off the peg design manuals, poor connectivity and poor contributions to the public realm.  \n\nThe SLP should support the creation and recognition in decision-making of local design codes, for instance in Neighbourhood Plans or locality-specific policies, which may not require stringent conservation area standards to be met but will require local characteristics (such as pitched roofs, use of red brick or other particular materials) to be reflected in new developments, including individual new dwellings and extensions, avoiding the classic jarring ‘sore thumb’ scenario.\n\nThe SLP should mandate the permeability of new developments to cycling and walking (meeting the standards set out in Making Space for Cycling 2014 and recommended by the Cheltenham & Tewkesbury Cycling Campaign).\n\nNew policy should mandate specific connectivity requirements to avoid developments like the Kendrick and Miller developments in Leckhampton which will each be adding their own access road only a few metres apart instead of combining intelligently on a masterplan scale. Requirements for new bus stops, physically distinct cycle lanes and pedestrian and cycle crossing points for every X metres or X number of dwellings should be as unambiguous as possible.\n\n\n\n/…\n\n\n\nJCS Policy SD5 on Green Belt promised review of the ‘permanently open’ Green Belt only in exceptional circumstances’ before 2031. It is already one of the smallest in the UK and was reduced by more than 700ha in the JCS. The SLP should support the maintenance of its permanent boundary capable enduring beyond the plan period as required by the NPPF.\n\n\nJCS Policy SD6 on landscape makes an important commitment to ‘protect landscape character for its own intrinsic beauty and for its benefit to economic, environmental and social well-being’ which should be retained in the SLP.  The equivalent SLP policy should reflect NPPF paragraph 180’s reference to valued landscape. This is of particular importance to Leckhampton which has valued landscape recognised as such in repeated inspectors’ reports but I imagine it is also important to other areas bordering on the escarpment in Cheltenham and Tewkesbury boroughs.\n\nIt has proved difficult to persuade case officers and even counsel to pay proper attention to valued landscape policy during application processes and appeal hearings and it would be helpful if this was specifically referenced in SLP policy.\n\n\nJCS Policy SD7 on the Cotswolds Area of Outstanding Natural Beauty (AONB), now referred to as the Cotswold National Landscape should be retained with its important commitment that ‘proposals will be required to be consistent with the policies set out in the Cotswolds AONB Management Plan’. This commitment must be retained in line with political commitments made in response the the latest version of the Management Plan.  \n\nThe SLP policy could go further and specifically reference the importance of Management Plan Policy CE1 on landscape which specifies that ‘Proposals that are likely to impact on, or create change in, the landscape of the Cotswolds AONB, should have regard to the scenic quality of the location and its setting and ensure that views - including those into and out of the AONB – and visual amenity are conserved and enhanced.\n\nJCS Policy SD9 on Biodiversity and Geodiversity addresses an important area of policy which deserves separate treatment as a policy area in the SLP, either at strategic or locality level not simply as an adjunct to climate change policy. \n\nBut this policy can be significantly strengthened compared with the JCS policy, committing to a high level of Biodiversity Net Gain as mentioned above, and not restricted to specific designated biodiversity ‘hotspots’ but designed to make a practical priority of nature recovery across both the rural and urban environment, mandating planners not just to protect biodiversity but to identify positive opportunities for biodiversity gain and increased nature connectivity based on the opportunities identified by the Gloucestershire Natural Capital Mapping Project.\n\nThe wording of the JCS policy that ‘harm to the biodiversity or geodiversity of an undesignated site or asset should be avoided where possible’ is particularly weak and a specific protective policy or mandate attention to the Leckhampton Hill & Charlton Kings Common Management Plan would be welcome.\n\n\nJCS Policy INF4 on Social and Community Infrastructure required that “where new residential development will create, or add to, a need for community facilities, it will be fully met as on-site provision and / or as a contribution to facilities or services off-site” but this policy has - in this council’s experience - not been rigorously enforced even in developments as large as the proposed Miller development of 350 homes in Leckhampton. \n\nSLP policy should be more specific and stronger with a specific requirement for any significant new development - perhaps 50 new dwellings or more - to deliver at least one new community facility such as a new shop premise.  Attention should also be paid to the cumulative impact of repeated small developments without any community provision as we see in Leckhampton, and SLP policy developed to address this.\n\n\n\nIII.  Current Cheltenham Plan policies\n\nThis is not an exhaustive list and there are other locality-specific policies that we should review and look to retain, strengthen and improve, and also new ones that we could add, particularly in relation to the town centre and other significant areas of character.\n\n\nCheltenham Plan policy D1 on Design reinforces JCS Policy SD4 mentioned above and promises that an application will not be supported unless it “complements and respects neighbouring development and the character of the locality and / or landscape.” We reiterate our desire for design policy to be clearly and strongly included in the SLP but that this should enable local design codes, for instance in Neighbourhood Plans and/or locality-specific SLP policies, that will allow communities to effectively protect key characteristics of local neighbourhoods without necessarily meeting the onerous requirements of a Conservation Area.\n\nPolicy in this area and in Cheltenham Plan Policy L1 on landscape and setting could cross-reference and highlight policies equivalent to JCS Policy SD7 on the AONB with its commitment to the AONB Management Plan, including policy CE1that protects views into and out of the AONB.\n\nCheltenham Policy D3 on private green space is important and should be retained in the SLP.\n\nCheltenham Plan Policy HE1 on buildings of local importance and non-designated heritage assets should be retained and draw attention to the validity of more localised indices of buildings of local importance and heritage assets, particularly in areas of particular significance like Cheltenham town centre, the Suffolk Road and Bath Road areas and urban villages like Charlton Kings and Hatherley but also areas of particular character like the Lower High Street and St Paul’s.\n\nCheltenham Policy MD4 specifically addressed Leckhampton but focussed on a specific area for mixed use development in which ‘approximately 350’ homes could be built as well as a new secondary school. The secondary school is now open, Kendrick have already built 12 new homes (21/00045/REM) in the MD4 area and Miller have now been given permission for 350 more at appeal (APP/B1605/W/22/3309156).\n\nA new policy could build on the previous MD4 wording which drew attention to previous inspectors’ findings (of which there are now many) and the need to respect the semi-rural nature of this area in any further development.   Further development is possible as there are still some undeveloped fields outside the LGS and brownfield sites with the potential for further small-scale development.\n\nCheltenham Plan Policy GI1: Local Green Space specifies that ‘development will not be permitted within a Local Green Space, designated either within the Cheltenham Plan or an approved Neighbourhood Plan, unless there are very special circumstances which outweigh the harm to the Local Green Space. Particular attention will be paid to the views of the local community in assessing any development proposals that affect a designated Local Green Space.’\n\nThis policy must be retained in the future SLP and the current boundaries of the designated LGSs respected as all have been demonstrably and strongly supported by local people and tested by examination and legal challenge. Undermining this process and the permanence of these designations will make these valued local spaces permanent battlegrounds with developers. \n\nSeveral new Local Green Spaces should be included, including:\n•\tSouthcourt Green in Leckhampton (connecting Southcourt Drive and Southcourt Close GL53),\n•\tHardwick Green, part of Hardwick campus at Marsh Lane\n•\tThe Green at Westdown Gardens\n"]
["Planning agent or developer","SF Planning","","","","","","","Although the term ‘beautiful’ is used in national policy, it is such a subjective term as to be meaningless or confusing. A more objective term could be used instead to ensure well designed places (with that being the focus). We would welcome the opportunity to work with the Council as part of a wider group to define what beautiful, in the context of Gloucester means","The plan could include policies which are in favour of replacement buildings where this will achieve a more energy efficient, lower carbon and future proofed development than the existing. Energy efficiency is only one part of the plan to address climate change issues. We would also like to see greater inclusion of broader measures that impact climate change such as waste, water usage, pollutants and biodiversity in the\ncontext of climate change, aligned with the draft strategic objectives set out in the consultation document.","","","","","","","","","Yes","there does not appear to be any reasons not to use the standard method.","","","","","","","","","","","","","","","","","","","","[Q28 and Q29] GCH sites tend to be within the urban area of Gloucester so the most pertinent scenario for them is Scenario 1: Urban concentration. GCH are in favour of the inclusion of policies which promote a version of this approach. However, some aspects of that suggested strategy (as drafted in the consultation document) are not necessarily going to create the best places. For example, high density developments may not result in the most desirable places to live unless there is a focus on balancing this with good design and providing homes which people want to live in. Nor will it meet the broad housing need we have in our city.\n\nIn addition, GCH supports a policy which advocates for the conversion, redevelopment and re-use of existing brownfield sites. \n\nGCH notes that the urban concentration approach and the reuse and redevelopment of brownfield sites will not necessarily result in harm to conservation areas with the city, contrary to some of the comments made within the consultation document; much depends on the design of the development (and some could even result in an enhancement). Nor will it rule out the ability to deliver any climate change mitigation, particularly if the new buildings are designed to be more energy efficient than those they replace. Planning policy is one of the greatest catalysts for change and once again, a positively worded policy incentivising climate change mitigation as part of a development could be used to maximise the opportunity for this.","","","","[Q1] Although it can be helpful to have a local plan which covers a longer period of time, a great deal of change is expected over the next 10-15 years such that a local plan going beyond 15 years risks becoming irrelevant.\n\n[Q8] - It is extremely challenging to meet this target on constrained urban sites, but there could be positively worded policies to incentivise providing more than 10% BNG. Or potentially different requirements in different areas.\n\nABOUT GLOUCESTER CITY HOMES\n\n1.\tGloucester City Homes (GCH) is an independent Housing Association in the City of Gloucester and surrounding area. They currently support approximately 12,500 customers living in around 5,000 homes comprising;\ni)\t4,522 Rented Homes\nii)\t323 Leasehold Homes\niii)\t126 Shared Ownership\niv)\t104 Homeless Units\n\n2.\tAs a social business they are committed to investing locally to create jobs and opportunities and want everyone to have a home they can be proud of, where they can thrive and be healthy. Their objectives align with those of the SLP as outlined in the consultation document and they contribute significantly to affordable housing stock within the SLP area.\n\n3.\tLike all affordable housing providers, their income is not unlimited. However, all GCH homes meet the Government’s decent homes standard and there is a 30 year financial business plan to deliver around £250 million investment in existing and new homes. They are passionate about their role in tackling the housing crisis by bringing quality, affordable new homes in and around Gloucester.\n\nTHE ADOPTED DEVELOPMENT PLAN\n\n4.\tThe current local plan comprises the Joint Core Strategy and the Gloucester City Plan. Through recent planning applications, GCH has identified some issues in the interpretation and application of the policies within these documents which it hopes could be addressed through revised policies in the emerging Strategic and Local Plan (SLP). A detailed analysis of the main concerns is provided below so that GCH and work with the Council to resolve them.\n\n5.\tApplication of policies for affordable housing –\n\n5.1\tPolicy A6 of the Gloucester City Plan requires (at A6 (2))\n\n(four) % of the affordable housing component of every housing development should meet Building Regulations requirement M4 (3) ‘wheelchair user dwellings’.\n\n5.2\tPolicy SD12 (1) (ii) of the JCS requires;\n\nii. Outside of the Strategic Allocation sites, on sites of 11 dwellings or more, or sites with a maximum combined gross floor space of greater than 1000 sqm; a minimum of 20% affordable housing will be sought on developments within the Gloucester City administrative area…\n\n5.3\tTherefore, in relation to a policy compliant development of 100 homes, 20 of those should be affordable and 1 of those 20 (rounding up) would need to meet the accessibility requirement M4 (3). Unfortunately, GCH are experiencing issues with the application of these policies. They are often being asked to provide 4% of all homes on site (because the schemes are 100% affordable) so 4 homes out of 100 rather than just 1. The potentially unintended result is that GCH are held to more stringent requirements than other developers who are only providing a policy compliant level of affordable housing. Future local plan policies could correct this, ensuring that the application of the policies is clear.\n\n6.\tRequirements to fund education on grant funded schemes\n\n6.1\tThe Community Infrastructure Levy (CIL) in the Joint Core Strategy was formulated on the basis of education infrastructure needs across the plan area. However, the CIL monies collected are not being paid across to Gloucestershire County Council so the County Council are seeking education funding on top of CIL payments.\n\n6.2\tHowever, in the case of registered providers such as Gloucester City Homes, their developments which rely on grant funding are exempt from\n \nCIL payments. This makes sense because it would appear illogical to use public money to fund other public services.\n\n6.3\tLikewise, it is also illogical to use money intended for affordable housing (i.e. the grant funding) towards funding the provision of education (another public service). Unfortunately, despite this, GCH are being asked to pay an education contribution on their applications.\n\n6.4\tOn the occasions when this issue has come up, GCH has employed viability consultants (at additional cost, taking funding away from the provision of affordable housing) and covered the cost of the Council’s viability expert, in order to demonstrate that payment of the contribution would not be viable.\n\n6.5\tThe unforeseen consequences of the additional expenses could be a reduction in the social housing which GCH are able to provide on the site which all parties wish to work together to avoid.\n\n6.6\tThis emerging plan represents a good opportunity to develop a policy which ensures that schemes which are being funded by public money will not then be required to contribute that public money to fund other public services.\n\n7.\tRequirements as to tenure and mix of GCH housing\n\n7.1\tOrdinarily, when an application for housing is submitted by a developer proposing open market homes, the affordable housing team would consider the tenure and mix of the affordable homes being provided as part of that scheme. As set out above (see policy SD12 of the JCS), in a policy compliant scheme they would therefore give their views in relation to 20% of the houses being provided on site.\n\n7.2\tIn the case of GCH schemes, the affordable housing team provides comments on tenure and mix on all proposed homes. This is the case even when:\n\ni)\tthe application falls below the affordable housing threshold (in that it relates to a small number of houses).\nii)\tthe application falls above the threshold, but the scheme is 100% affordable.\n\n7.3\tThis once again (potentially unintentionally) results in more stringent requirements for GCH than for developers proposing only a policy compliant level of affordable homes.\n\n7.4\tThe local planning authority then has unrealistic expectations about what\n \nGCH can achieve. This local plan represents an excellent opportunity to introduce clear parameters for when the housing team will be consulted on an application and the extent of what can be considered by planning officers.\n\n7.5\tWe propose the following, unless there is a need to secure 100% of the houses as affordable (and of a specific type or tenure) such as in relation to an exception site, or where the provision of affordable housing provides a public benefit which outweighs adverse heritage impacts;\n\ni)\tThe housing team are consulted on GCH schemes over the threshold for providing affordable housing.\nii)\tThe housing team are made aware that their suggested requirements in relation to tenure and mix of affordable housing relate only to 20% of the scheme (unless clear reasons justify requiring more).\n\n8.\tApplication of ‘Estate Regeneration’ policy –\n\n8.1\tPolicy A3 of the Gloucester City Plan relates to Estate Regeneration. Briefly, the policy supports estate regeneration where the physical condition of the housing stock is poor and there is a socio-economic justification for the regeneration. The policy also includes a number of requirements for estate regeneration proposals including the requirement that the proposal needs to have been properly masterplanned and should provide community and commercial facilities. Estate is not defined in the glossary and the explanatory text for the policy (paragraphs 4.1.24 to 4.1.27) does not provide a definition of ‘estate’. Explanation is limited to references to ‘several former local authority housing developments in\nGloucester’ and Matson and Podsmead are given as examples of areas where this policy might be relevant.\n\n8.2\tThere have been cases where GCH has been required to demonstrate compliance with this policy even where the redevelopment is occurring in a small part of a neighbourhood (several buildings on one street for example). The result of this is additional reporting requirements, resulting in increased costs. The policy was raised in relation to the replacement of Clapham Court which does not function as a standalone ‘estate’ in the normal sense of the word. The Collins English dictionary defines ‘Estate’ as; “a large area of property development, esp of new houses or (trading estate) of factories”.\n\n8.3\tIn cases such as Clapham Court, GCH was not easily able to meet the requirements, for example there was an overall site plan with a clear indication as to the location of gardens, landscaping and the different residential units but not a ‘masterplan’ as one would ordinarily recognise in a larger housing development scheme. Also, as in the case of Clapham\ncourt, it may not be practical to introduce community and commercial facilities within the confines of the site. Also, such facilities may well be provided elsewhere within the neighbourhood, and there may not be a specific need in this location (because it forms a small part of a wider community). This isn’t to say that GCH wouldn’t consider providing these\nfacilities independently of this policy, but a realistic approach is needed.\n\n8.4\tOur proposal, if the estate regeneration policy is to be retained, is to include a clear definition of what constitutes an estate for the purpose of the policy and provide additional explanatory text to make the application of this policy clearer. This should ensure that the policy is not applied to schemes which are not estate regeneration. The Collins English dictionary definition of estate could be used as a starting point for this.\n\n9.\tIt is clear that the emerging local plan presents an excellent opportunity to ensure that policies are applied fairly and consistently for registered and other affordable housing providers across the SLP area in the ways suggested above. \n\nPlease contact me should you find it helpful to discuss the information included in this submission."]
["Planning agent or developer","SF Planning","","","","No","","No","Although the term ‘beautiful’ is used in national policy, it is such a subjective term as to be meaningless or confusing. A more objective term should be used instead to ensure well designed places (with that being the focus).","","","","No","No","","It should be accepted that not all settlements accommodating new housing will have access to a full list of all services and facilities you would expect in a large town. Policy could be drafted to support developments which meet certain criteria such as being within a specified travelling time of at least 3 services on foot or public transport. Note that this shouldn’t mean development outside of settlements offering the level of services outlined in the policy would be refused. The policy should be permissive. \n\nSome of the criteria could include; \n• employment area(s) offering 500+ jobs; \n• secondary school \n• Allotment \n• Bank \n• Café / other food outlet • Community hall \n• Dentist \n• Further education \n• GP surgery or pharmacy \n• Hospital \n• Leisure centre \n• Library \n• Nursery / pre-school \n• Place of worship \n• Play area or sports field \n• Post office \n• Primary school \n• Pub \n• Public open space \n• Town centre, supermarket or convenience store selling fresh food. \n\nThis means that as settlements grow and evolve and bring with them new developments (and potentially new services as a result) the policy can still be applicable rather than becoming out of date. This avoids the potential issue created by designating specific villages as service villages as was done with the JCS and means that a similar policy can apply consistently across the SLP area to any location which perhaps does not have a long list of services in the immediate location, but which has a good regular public transport service to a location which does.","No","","Yes","Yes, there do not appear to be any reasons not to use the standard method.","No","","No","","","","","","","","","By ensuring that there are enough people living in the villages (and surrounding smaller settlements) to utilise the services and facilities. \n\nA flexible approach to the location of development assists with this. Although this does not apply specifically to the site, the removal of settlement boundaries, or boundaries which are deliberately drawn to allow expansion of a settlement will also ensure that a business can grow rather than experiencing stagnation in profits as prices rise and the economic climate becomes more challenging. Settlement boundaries are often drawn relatively tight to existing settlements which does not allow for the additional customers these businesses and services need. \n\nPolicy criteria could apply in place of settlement boundaries. See response to Q10 for potential ideas about some of the criteria which could be applied. \n\nDevelopment which accords with the criteria should be supported, other development should not necessarily be refused but material considerations will need to come into play to support such development.","","","See response to Q10. The question isn’t as simple as just looking at how many services a rural settlement has. Account should be taken of the ability to easily access services via public transport too. A settlement could have no services whatsoever but could be on an excellent public transport route with a relatively short journey time to a larger settlement. This should still be considered acceptable.","","","","","Development at the site most closely aligns with the Rural Dispersal scenario (5). However, this scenario advocates for development at the smallest of hamlets. There does not appear to be a scenario which directs growth to locations which have access to a base level of facilities such as those outlined in response to Q10 above(whether or not that is a small village with good transport links or a larger villages with more services in the village itself). \n\nWe agree that scenario 5 would help to support thriving communities by supporting shops services and facilities and with the other pros identified in relation to this scenario. \n\nIn terms of the cons for scenario 5, we do not consider it is ‘likely’ that the character and setting of existing settlements will be harmed by development in more rural locations. Much will depend on the scale and size of the development and, more critically, how it is designed. \n\nAlso, policies which incentivise certain types of housing which are needed could overcome some of the more significant impacts of the reduced ability to provide a full range of housing sizes, types and tenures. \n\nWe are not aware of any rural services or facilities which would experience undue pressure as a result of a small amount of additional housing in the vicinity. ","Scenario 5: Rural dispersal","","As indicated above (see response toQ10) a hierarchy of settlements is not necessarily the most appropriate way  to ensure that policies remain applicable and relevant (i.e. up to date) across the whole plan period. \n\nInstead, each application should be considered with reference to accessibility to different services. This \nensures that the situation at the time the decision is made can be taken into account rather than being based on information which, at some stage, could become 10 years out of date. Permission should be granted where the site has access to a certain level of services on foot or public transport. Where a site does not meet this criteria, this shouldn’t necessarily mean that permission should be refused but then other considerations would become relevant. \n\nWhere the Council still considers it appropriate to have a settlement hierarchy, notwithstanding the above, \nGretton should be included on the list, as should a number of other settlements scoring 8 or more on \nwhat was the settlement audit (2014) produced as part of the JCS evidence base (although a new audit should be conducted to inform the SLP). An additional tier may be appropriate if the concept of a rural settlement hierarchy is to be retained so that those villages scoring very highly are assessed for a more significant level of growth than the smaller settlements","Please see paragraphs 3 – 6 of this letter.\n\n3. Site Description \n\n3.1 Our client owns land towards the eastern edge of the village of Gretton, on the southern side of Gretton Road which comprises garden land and a collection of outbuildings to the rear of the dwellinghouse known as Myrtle Cottage.\n\n3.2 Current access to the site is available via an existing stone track to the west of Myrtle Cottage which leads to an area of hardstanding, six outbuildings and grassed area.\n\n3.3 Gretton has a reasonable number of services and facilities for its size (including a primary school, village hall and public house) and the site is well connected to these along existing footpaths that run through the village. \n\n3.4 The nearby rural service centres of Winchcombe (circa 1.8km to the east) and Bishops Cleeve (circa 7.2km to the west) are easily accessible from the site. The bus stops along Gretton Road provide direct links to Winchcombe, Cheltenham, Broadway and Chipping Camden through the week.\n\n3.5 The site is not located within any designated conservation area and there are no listed buildings either within or immediately adjacent to the site. The site lies wholly within the Cotswold AONB and has a low risk of flooding (flood zone 1). The site has limited special qualities other than partly comprising grassland and trees.\n\n4. Suitability of the Site\n\n4.1 The Site is considered suitable for residential development for the reasons \nset out below. \n\n4.1.1 The consultation document indicates that Tewksbury will need to provide 557 homes annually and 11,140 over the next 20 years. The allocation of the site would make a contribution to housing supply and at a time when the Council has struggled to demonstrate one since the \nadoption of the Joint Core Strategy (JCS).\n\n4.1.2 The site was granted permission in principle in respect of a single dwelling (reference 23/00637/PIP, dated 14 December 2023). However, the site is capable of taking more dwellings and providing much needed housing in this area.\n\n4.1.3 The NPPF and the consultation document both rightly focus on the need for development in village locations to help to maintain the vitality of these communities and foster community wellbeing. The Site can do this by providing a proportionate increase in the village \npopulation on a previously developed site will result in more people using the village services in a sustainable way. It will also bring an underused site into active use. \n\n4.1.4 The site is well related to existing buildings (see below) and could be considered under-developed relative to its size but clearly capable of hosting housing development, given the current outbuildings and vehicle hardstanding. At present the site is arguably not being \noptimally used. Use of this land for housing is supported by the NPPF and other Government policy which promotes the effective use of land in meeting housing need and the use of as much previously developed land as possible.\n\n4.1.5 Furthermore, development at the Site is clearly capable of respecting the character of Gretton and local distinctiveness if suitably designed.The site does not currently make any significant contribution to the character and setting of the settlement.\n\n4.1.6 The AONB designation can be addressed through a planning application and should not be considered a barrier at this stage, particularly as a significant proportion of the site should be considered to be previously developed land. There is potential for greening the site in such a way \nas to provide visual, landscape and ecological enhancements. \n\n5. Availability and achievability \n\n5.1 The Site is presently available for residential development, and there is no impediment to its delivery within the next five years.\n\n5.2 We note that paragraph 70 of the NPPF places emphasis on the importance of small to medium housing sites such as this as they can make an important contribution to local housing requirements and are often built out relatively quickly. This site is no exception.\n\n5.3 The Site is of a reasonable size that could be advanced quickly following the grant of permission, and therefore could aid with housing supply in the short to medium term, thereby helping to sustain a five-year housing land supply of deliverable sites. \n\n6. Call for sites summary\n\n6.1 The Site is ideal for residential development due to its sustainable location. It is available for development to be achieved in the short to medium term. \n\n6.2 Any potential harm that might be identified can be mitigated through a carefully considered, appropriate design and landscaping.\n\n\nHow far into the future should the Strategic and Local Plan cover?\n\nAlthough it can be helpful to have a local plan which covers a longer period of time, a great deal of change and growth is expected over the next 10-15 years such that it would not be sensible to extend beyond 15 years at this point.\n\nShould the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nNo as it can be very difficult to meet this target on constrained sites, but there could be positively worded policies to incentivise providing more than 10% BNG.\n\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nDevelopment at the site most closely aligns with the Rural Dispersal scenario (5). However, this scenario advocates for development at the smallest of hamlets. There does not appear to be a scenario which directs growth to locations which have access to a baselevel of facilities such as those outlined in response to Q10 above (whether or not that is a small village with good transport links or a larger villages with more services in the village itself). \n\nWe agree that scenario 5 would help to support thriving communities by supporting shops services and facilities and with the other pros identified in relation to this scenario.\n\nIn terms of the cons for scenario 5, we do not consider it is ‘likely’ that the character and setting of existing settlements will be harmed by development in more rural locations. Much will depend on the scale and size of the development and, more critically, how it is designed. \n\nAlso, policies which incentivise certain types of housing which are needed could overcome some of the more significant impacts of the reduced ability to provide a full range of housing sizes, types and tenures. \n\nWe are not aware of any rural services or facilities which would experience undue pressure as a result of a small amount of additional housing in the vicinity. "]
["Planning agent or developer","SF Planning","","","","","","No","Although the term ‘beautiful’ is used in national policy, it is such a subjective term as to be meaninglessor confusing. A more objective term should be used instead to ensure well designed places (with that being the focus).","","","","No","","","It should be accepted that not all settlements accommodating new housing will have access to a full list of all services and facilities you would expect in a large town. Policy could be drafted to support developments which meet certain criteria such as being within a specified travelling time of at least 3 services on foot or public transport. Note that this shouldn’t mean development outside of settlements offering the level of services outlined in the policy would be refused. The policy should be permissive. Some of the criteria could include;\n• employment area(s) offering \n500+ jobs;\n• secondary school\n• Allotment\n• Bank\n• Café / other food outlet\n• Community hall\n• Dentist\n• Further education\n• GP surgery or pharmacy\n• Hospital\n• Leisure centre\n• Library\n• Nursery / pre-school\n• Place of worship\n• Play area or sports field\n• Post office\n• Primary school \n• Pub\n• Public open space\n• Town centre, supermarket or\nconvenience store selling fresh\nfood.\nThis means that as settlements grow and evolve and bring with them new developments (and potentially new services as a result) the policy can still be applicable rather than becoming out of date. This avoids the potential issue created by designatingspecific villages as service villages as was done with the JCS and means that a similar policy can apply consistently across the SLP area to any location which perhaps does not have a long list of services in the immediate location, but which has a good regular public transport service to a location which does.","","","","","","","","","","","","","","","","By ensuring that there are enough people living in the villages (and surrounding smaller settlements) to utilise the services and facilities. This starts with removing settlement boundaries as a barrier to the managed growth of villages and instead having policy criteria (see Q10 for an example of such criteria). Constrained villages with settlement boundaries do not allow for the growth of businesses. Generally, most businesses will want to seegrowth rather than remaining stagnant as prices rise and the economic climate becomes more challenging. Settlement boundaries are often drawn relatively tight to existing settlements which does not allow for the additional customers these businesses and services need.Development which accords with the criteria should be supported, other development should not necessarily be refused but material considerations will need to come into play to support such development. Where settlement boundaries are still considered to be necessary, they should be drawn with population growth over the next 15-20 years, and the need to maintain services across that period in mind and should not be tight to existing development.","","","See the list provided in response to Q10.","","Yes","There does not appear to be a scenario which directs growth to locations which have access to a base level of facilities such Woodmancote or indeed any which would fit with the response to Q10 above (whether or not that is a small village with good transport links or a larger villages with more services in the village itself).","No","We agree that scenario 5 would help to support thriving communities by supporting shops services and facilities and with the other pros identified in relation to this scenario. In terms of the cons for scenario 5, we do not consider it is ‘likely’ that the character and setting of existing settlements will be harmed by development in more rural locations. Much will depend on the scale and size of the development and, more critically, how it is designed. In a settlement like Woodmancote with a site of this size, there should be no barrier to providing a full range of types and sizes of homes. Again,this may be a result of the fact there does not appear to be a suitable ‘in between’ scenario for villages with some services.","Scenario 5: Rural dispersal","Yes","As indicated above (see response to Q10) a hierarchy of settlements is not necessarily the most appropriate way to ensure that policies remain applicable and relevant (i.e. up to date) across the whole plan period. Instead, each application should be \nconsidered with reference to accessibility to different services. This ensures that the situation at the time the decision is made can be taken into account rather than being based on information which, at some stage, could become 10 years out of date. Permission should be granted where the site has access to a certain level of services on foot or public transport. Where a site does not meet this criteria, this shouldn’t necessarily mean that permission should be refused but then other considerations would become relevant. Where the Council still considers it appropriate to have a settlement hierarchy, notwithstanding the above, a number of other settlements (i.e. those scoring 8 or more on what was the settlement audit (2014) produced as part of the JCS evidence base(although a new audit should be conducted to inform the SLP)) should be added to the list. An additional tier may be appropriate if the concept of a rural settlement hierarchy is to be retained so that those villages scoring very highly are assessed for a more significant level of growth than the smaller settlements.",""]
[null,null,null,null,null,null,null,null,"As a resident of Up Hatherley, I have a particular interest in the inclusion of land south of Up Hatherley Way and land at Oak Farm, Chargrove Lane, in the SLP.  I wish to comment in relation to the Draft Strategic Objective “Promoting Healthy & Resilient Communities”\nChargrove Lane is much valued locally as a quiet country lane for taking exercise.  There are pleasant views, little traffic, high biodiversity and the lane has an unspoilt feel about it.  This is rare, so close to Cheltenham.  As a Health Walk Leader, I lead a weekly Health Walk of 30 to 40 people, often along Chargrove Lane and across the adjacent fields.  You acknowledge the value of access to nature and green spaces and indeed my walkers really look forward to, and appreciate the benefit of, these excursions.  We used to explore the fields which have now disappeared under the Brizen Park development and I sincerely hope we will not be deprived of another local area so conducive to the well-being of so many Cheltenham residents."]
["Resident",null,"","","","No","There needs to be a balance struck between establishedcommunities, where people come to live and stay (forever) and other housing stock which can provide short term accommodation for younger and potently mobile workforce.  Affordabe too","No","As above","Where is any mention of investment on canal network?  What about re-instatement of Gloucester to Newent railway- perhaps as a tram?","Provision of basic utilities - roads initially, electricity and gas, sewage, 5G bandwidth, but also employment opportunities in the same area are essential pre-requisites","Enhanced exploitation of brownfield sites a must do","Yes","No","","Employment, recreation/ sports centres, community / civic halls, community run cafes and pus=bs","Yes","Green electricity - solar power production AND storage in battery farms ","No","Think local to act (support) global aspirations.","Yes","Geography of Highnam parish:  rivers (plural) which flood; no highway through E-W nor N-S.  Where is the new Severn Bridge crossing?","Yes","AFFORDABLE, potentially short term lets","Yes","Provision of clearly delineated, well serviced areas","As above, but also with extensive distance and space away from settled communities","Availability of employment is essential. Jobs first then accommodation. New houses do not generate jobs - once they have been built!","Latch onto cyber growth","Where possible expand existing business parks that have been established in farmyards","High street shop rates need to be cut; more centre if own FREE parking.  Witney (Oxon) offers so much up to 2 hours free parking !!","Review rates","transportation network - not just roads, but cycle paths, tramways, canals and a new bridge over the river severn between Gloucester and Bristol; Robust and future proofed utilities - power requirements need to be met BEFORE houses are built. Ditto sewerage needs and flood defences","As above","As above","Yes","No","","No","Not enough focus on pre-requisites of utility/ transportation; flooding needs - these have to be in place before houses are built","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","No","","Before any new houses (etc) are planned, the following fundamentals have to be considered:\nAre there jobs now or in imminent future that require new accommodation?  = New houses do not generate new jobs\nis the essential support infrastructure in place?\n= Utilities, transportation, flood defences to nam but 3\nWhat thought has there been given to the western end of The Missing link?\n= its all well and good getting folk from Cheltenham/ Gloucester to Swindon and London... but what about the folk from the Forest of Dean/ Monmouth and Newport to Gloucester in the first place? \n  "]
[null,null,"","","","No","My overriding concern in my response to this consultation is the impact of any proposals on the environment. \nThe whole vision is far too focussed on the needs and wants of people. People are part of a wider ecosystem and the SLP must pay due attention to that. The focus needs place the environment at the centre of any policy. There is insufficient detail in the vision on aspects such as nature recovery for example.","No","As above, more emphasis on the environment","The climate and ecological crises are inextricably linked. We must address them both together. Climate change is driving nature’s decline and the loss of wildlife and wild places is leaving us ill-equipped to reduce carbon emissions and respond to climate change. \nThe councils involved in the SLP must declare both a climate and nature emergency. Declaring a nature emergency demonstrates that councils know that wildlife is in trouble and that they have a responsibility to do something about it. Declaring a nature emergency motivates councils to take action. It can also attract new funding and ensure that everyone in the council area understands why nature is important. \nA declaration like this also leads to nature being considered in all activities that the Council undertakes. It acknowledges the needs of people and nature to be in balance. It’s the first step to making sure Local Authorities are working to bring nature back","All new buildings should be required to have either rooftop solar panels and/or air or ground-source heating as feasible.","","Yes","","Emphatically yes. The UK is one of the most nature-depleted countries in the world. According to the State of Nature report 2023 species have declined by 19%. In Gloucestershire we have already lost 70% of traditional orchards and only 1.5% wildflower-rich meadows remain. It is the duty of the three councils to ensure that the decline in nature is halted and reversed.","","No","Energy generation and storage is best done at a local level. All new building should be required to install rooftop solar panels, air or ground-source pumps as feasible. There may be some brownfield (previously developed) sites which could be suitable for energy generation/storage. These would need to be assessed on their suitability. Greenfield sites should not be used.","No","There appears to be no explanation as to how this calculation is made. I am alarmed at the number of houses which apparently need to be built.","Yes","Gloucestershire is essentially a rural county. It is very important to me that we retain and safeguard the rural nature of the Gloucestershire countryside as it has been for centuries, alongside making improvements to the way it is managed to increase biodiversity net gain.","Yes","There is definitely a need for more affordable housing. There should be severe restrictions on the ability of people to buy second homes in the county. Many of our small villages and towns like Winchcombe, for example, have high numbers of second/holiday homes which stand empty for large parts of the year. We need to ensure existing homes are lived in rather than build new housing. \nCPRE (The Countryside Charity) has long led calls on the government to introduce a second home and short-term lets register, with local authorities having the power to regulate the provision of them Their analysis of data on properties on Airbnb and similar sites shows that a massive 148,000 homes that could have otherwise been used as homes by local families were instead put up on short-term and holiday lets.\n‘There simply has to be a government response to the fact that our rural housing supply is disappearing into an unregulated short-term rentals market that simply didn’t exist six years ago.’ We’re calling for tighter controls on second home ownership, including higher council tax on second homes and the requirement for short term lets to have planning permission. CPRE Nov 2023\n","","","","","","","More emphasis on urban renewal, including housing in town centres","","","","Only very small scale development should be considered in rural settlements. It would helpful to have a small shop/post office located in some of our larger villages, which could then serve other smaller villages nearby.","No","Yes","I note that paragraph 5:20 states that ‘It is important to note that the sites allocated for development in the JCS, district plans, and other sites with planning permission will deliver new homes in the new timeframe for the Plan (the JCS and district plans covering up to 2031). This includes large sites that have planning permission and are delivering new homes at Twigworth, Innsworth, Brockworth and Churchdown. A large number of homes required are therefore already accounted for’ \nThis being the case, I would favour urban densification. \nMore people living in and using shops, services and facilities in the main city and town centres. \nBringing more life and vitality to the city and town centres, including at night. \nConcentrated development in urban areas, supporting use of bus and rail, walking, cycling and car clubs. \nSupports maximum use of ‘previously developed land’ and urban regeneration. \nProtects the existing Green Belt and minimises the loss of greenfield sites and higher quality agricultural land.","","","Scenario 1: Urban concentration","","","The SLP must safeguard the rural integrity of Gloucestershire. \nHaving a binary yes/no response to a number of these questions was unhelpful and didn't allow an opportunity for a properly considered response. Neither was it helpful to have a survey which didn't allow one to go back and check through one's answers and comments. "]
[null,null,"","Yes. Under the strategic policy topic of infrastructure, emergency services infrastructure should be \nspecifically mentioned and addressed in the emerging SLP.","","Yes"," Paragraph 3.3 sub paragraph j) rightly identifies as a key issue that will shape the Vision the need for:\n“Identifying and facilitating infrastructure needed to support development, including (but not \nlimited to) education; transport, e.g. mass rapid transit routes; health; e.g. GP surgeries; green \ninfrastructure, and digital infrastructure, that are needed to support growth and our \ncommunities.“\nAlthough this is not an exclusive list, it should include emergency services and rescue infrastructure, \ngiven the statutory and NPPF context described in the introduction to these representations. The \nfirst sentence of the fifth paragraph of the vision should be amended as follows (blue text):\nGrowth will have been supported by the provision of a range of essential digital, transport, \ncommunity, emergency and rescue services and other infrastructure. \nIn addition, paragraph 3.3 should reference the definition of infrastructure set out in the Levellingup and Regeneration Act 2023.","","As above, paragraph 3.3 sub paragraph j) rightly identifies as a key issue that will shape the Vision \nthe need for:\n“Identifying and facilitating infrastructure needed to support development, \nincluding (but not limited to) education; transport, e.g. mass rapid transit routes; \nhealth; e.g. GP surgeries; green infrastructure, and digital infrastructure, that are \nneeded to support growth and our communities.“\nAgain, although this is not an exclusive list, it should include emergency services and rescue \ninfrastructure and reference the definition of infrastructure set out in the Levelling-up and \nRegeneration Act 2023.\nUnder the strategic objective of “Delivering well designed, beautiful and safe places”, point 1. should \nbe amended as follows (blue text):\n1. Supporting the creation of high quality, beautiful and sustainable buildings and places through \ngood design, incorporating secured by design principles. \nIncluding this amendment would have the significant benefit of aligning the strategic objective much \nmore closely with paragraphs 96 (b) and 135(f) of the NPPF and the following content of Planning \nPractice Guidance: “Planning provides an important opportunity to consider the security of the built \nenvironment, those that live and work in it and the servicesit provides. (our emphasis)\nSection 17 of the Crime and Disorder Act 1998 (as amended) requires all local, joint and \ncombined authorities (as well as National Parks, the Broads Authority and the Greater \nLondon Authority) to exercise their functions with due regard to their likely effect on \ncrime and disorder, and to do all they reasonably can to prevent crime and disorder. \nCrime for these purposes includes terrorism.”\nParagraph: 009 Reference ID: 53-009-20190722\nRevision date: 22 07 2019\nPoint 2 under strategic objective “Delivering well designed, beautiful and safe places” should be \namended as follows (blue text) in view of the statutory and NPPF context stated in the introduction \nto these representations.\n2. Ensuring that new development is integrated well with existing communities and providing welllocated infrastructure, including emergency services and rescue infrastructure, which meets the \nneeds of communities; \nUnder the strategic objective of “Promoting healthy and resilient communities, point 1 should be \namended as follows (blue text) given the statutory and NPPF context described in the introduction to \nthese representations. \n“1. Delivering new developments that are supported by the necessary social and community \ninfrastructure, including schools, emergency and rescue services, open space, playing fields, \ncommunity facilities and green and blue infrastructure and promote community cohesion. “\n","","","","","","","","","","","","","","","","","","","","","","","","","In reply to Questions 23 and 24, it is an indisputable fact that everyone, no matter the development \nscheme they are in, its size or where it is, expect and require the fire and rescue, ambulance and \npolice services to be available at all times when emergencies happen affecting them, their families or \ntheir friends. Whilst the emergency services will always endeavour to deliver help to those who need \nit when called upon, such provision must be planned and provided for in advance, as is the case with\nany other essential infrastructure type. Failure to plan for this would put peoples’ lives and property \nat a constantly higher risk of danger than would otherwise be the case.\nThe infrastructure needed takes the form of new on or off-site provision or improvements to the \ncapacity of existing emergency and rescue services infrastructure either on or off-site. \nIt is this context that explains why the Government has made it abundantly clear that it is entirely \nreasonable and proper for emergency services infrastructure to be delivered alongside new \ndevelopment. This is demonstrated by the following:\n• The Levelling-up and Regeneration Act 2023 states in its definition of ‘infrastructure’ for \nthe new Infrastructure Levy ‘facilities and equipment for emergency and rescue services’ \n(see Schedule 12 – Part 1 – Section 204N (3)).\n• The National Planning Policy Framework (December 2023) makes clear at paragraphs \n8(b), 16 (c), 20(b), 96 (b), 97, 101, 116(d) and 135 (f) that crime reduction, safety and the \ninfrastructure to deliver these are material considerations that should be fully accounted \nfor by planning policies and decisions.\n• Statutory Planning Practice Guidance states the following in relation to the current \nlegislative context and the spending of CIL receipts:\n“The Levy can be used to fund a wide range of infrastructure, including transport, flood \ndefences, schools, hospitals, and other health and social care facilities (for further details, \nsee section 216(2) of the Planning Act 2008 and regulation 59, as amended by the 2012 \nand 2013 Regulations). This definition allows the Levy to be used to fund a very broad \nrange of facilities such as play areas, open spaces, parks and green spaces, cultural and \nsports facilities, healthcare facilities, academies and free schools, district heating schemes \nand police stations and other community safety facilities. This flexibility gives local areas \nthe opportunity to choose what infrastructure they need to deliver their relevant plan (the \nDevelopment Plan and the London Plan in London). Charging authorities may not use the \nlevy to fund affordable housing. (our emphasis)\nLocal authorities must spend the levy on infrastructure needed to support the \ndevelopment of their area, and they will decide what infrastructure is needed.\nThe Levy can be used to increase the capacity of existing infrastructure or to repair \nfailing existing infrastructure, if that is necessary to support development. (our \nemphasis)\nIn London, the regulations restrict spending by the Mayor to funding roads or other \ntransport facilities, including Crossrail, to ensure a balance between the spending \npriorities of the London boroughs and the Mayor.”\nParagraph 144 Reference ID: 25-144-20190901\nRevision date: 01 09 2019\n• Although there is no statutory definition of ‘infrastructure’ for the purposes of Section \n106 agreements, there are 43 planning appeal decisions (see Appendix 1B) that support \nSection 106 contributions for police infrastructure of all kinds. Twelve of these decisions \nwere made by the Secretary of State. There are also 5 appeal decisions (see Appendix 2)\nthat support Section 106 contributions for fire and rescue infrastructure of all kinds, of \nwhich one of these decisions was made by the Secretary of State. There is clearly no \ndoubt from the sheer volume of these decisions that planning obligations to deliver \nemergency services infrastructure are compliant with the relevant statutory tests.\nIn view of the above, we recommend that paragraph 5.53 be amended as below (blue text):\n“New homes and employment will need to have new infrastructure, for example schools, \nroads, public transport, health services, emergency and rescue services and recreation \nprovision. This will need to be funded through central and local government funding streams \nand contributions from developers.”","","Yes","","","","","","","","Set out below are the Office of the Police & Crime Commissioner for Gloucestershire’s (OPCC’s) responses to the questions set out in the consultation document that are relevant to police and emergency services infrastructure provision within Cheltenham, Gloucester and Tewkesbury in the Strategic Local Plan (SLP) period. A total of 6 of the 31 consultation questions are responded to below, preceded by a summary of statutory and national planning context as relevant to these representations. \n\nStatutory context:\nPart 1 of the Police Reform and Social Responsibility Act 2011 states that a Police and Crime Commissioner (PCC) must secure the maintenance of the police force for their area, whilst ensuring that it is efficient and effective under the direction and control of the Chief Constable. \nUnder the Policing Protocol Order 2023 the PCC has a specific responsibility for the delivery of community safety and crime reduction. \nSection 17 of the Crime and Disorder Act 1998 (as amended by the Police and Justice Act 2006) requires local authorities to do all that they reasonably can to prevent crime and disorder including anti-social and other behaviour adversely affecting the local environment in the exercise of their various functions. \nThe Levelling-up and Regeneration Act 2023, in its definition of ‘infrastructure’ for the new Infrastructure Levy, includes ‘facilities and equipment for emergency and rescue services’ (see Schedule 12 – Part 1 – Section 204N (3)).\nNational planning context:\nIn line with NPPF (revised December 2023) guidance, emergency services are a crucial part of service delivery to sustainable communities. Paragraph 101 requires that “Planning policies and decisions should promote public safety and take into account wider security and defence requirements…”NPPF paragraph 135 f) states that:\n“Planning policies and decisions should ensure that developments……….create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users; and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.”\nWith regard to promoting healthy communities, paragraph 96 of the NPPF guides that “Planning policies and decisions should aim to achieve healthy, inclusive and safe places which…… are safe \nand accessible, so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.”\nNPPF paragraph 100 states that: “To ensure faster delivery of other public service infrastructure such as further education colleges, hospitals and criminal justice accommodation, local planning \nauthorities should also work proactively and positively with promoters, delivery partners and statutory bodies to plan for required facilities and resolve key planning issues before applications \nare submitted.”\nThe NPPF references at Paragraph 57 the three tests for planning obligations as set out in Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 (as amended). Developer contributions to policing infrastructure have been scrutinised by the High Court, Secretary of State and the Planning Inspectorate and found to be wholly in accordance with the statutory tests \nincluding the Community Infrastructure Levy Regulations 2010 (as amended), please see summary at Appendix 1A. Recent planning appeal case law nationally has confirmed that developer contributions towards policing infrastructure accord with the NPPF (please see summary atAppendix 1B). \n\n[Q26.]  If the SLP does not identify and safeguard land that is necessary for essential longer-terminfrastructure, then there will be risk to its future delivery which will be to the detriment on the proposed development and communities that will live and work in them. Infrastructure development and provision of land for it comes at a cost in the economics of property development. Understandably, developers will look to minimise costs were possible in order to maximise profitability. Unless the SLP Authorities safeguard essential infrastructure land then the delivery of planned infrastructure will be at risk.A current and very relevant example of what can happen if land for essential supporting infrastructure is not safeguarded is provided by Elms Park (North West Cheltenham Strategic allocation planning application reference 16/02000/OUT). In this case, despite the OPCC having submitted formal requests and JCS representations to Tewkesbury Borough Council and Cheltenham Borough Council and the developer for over 10 years seeking provision of on and off-site policing infrastructure, the developer has failed to include any on site provision in the masterplan for this scheme. Negotiations are still ongoing."]
[null,null,"","","","No","At the moment it’s just a series of potential options, and pending National plans anyway, so nothing really to agree/disagree with. The devil will be in the detail.","No","As above.","I agree with the plan stating that development needs to be served by genuine transport links - but let’s hope that is stuck to when planning applications from developers are submitted.","All new building, residential or commercial, should only be granted planning permission if they include sustainable features such as solar panels on roofs. If this was implemented it would have a dramatic impact on the amount of green energy usage in the county. It would also reduce the need for these ‘solar farms’ which unnecessarily use agricultural land.","Inclusion of sustainable energy production (solar/heat pumps/etc.). It would also be nice to see an encouragement of using sustainable materials in buildings.","","Yes","We need to stop building on agricultural land. The UK desperately needs to secure its ability to supply sufficient for the country. This is a serious national issue, but one which local governments can assist with by making smart choices about the location of developments.","GPs would be number one. All our surgeries across the county are basically on their knees. Huge waiting lists, phones ringing off the hook, all because they have too many patients on their books.\nSecond would be schools which are also oversubscribed in so many areas. There’s no ‘choice’ for parents, it’s just a case of hoping to be lucky.","No","","","","","","","","Yes","If we stopped allocating specific traveller sites and non-traveller developments, and found a way to integrate society more then you might find less cultural clashes and more acceptance and understanding of each other. It’s the ‘them and us’ approach that causes issues, basically racial segregation that is somehow still acceptable.","","","","","Stop granting permission for retail parks, this would force shops and businesses back to the high street and create more footfall for all. The high street became dead because the price of parking drastically increased, and so retail parks became more attractive for the consumer. (And I assume the business rates are better for retailers too out of town). We’ve now been left with high streets full of empty shops and a sprawling mess of retail parks which generally cause traffic misery around them at weekends.","","GPs.","GPs.","Flooding risk. Building of the flood detention basin (Twigworth Green) was a ridiculous decision. The site has barely started to become occupied and already the surrounding area have suffered significant flooding and access to the development was cut off. This is only going to get worse. Of course the new homes are unlikely to flood, it’s the existing homes that will suffer. Longford being a prime example.\nSUDS will only get you so far.","","","","","","","","",""]
["Statutory/Specific Consultee","Badgeworth Parish Council",15,"","","","The draft Vision is short and to the point, but we feel that there needs to be a preamble which states that the aims and achievements of the Vision will be subject to national Government policies covering investment, financial constraints and changes in planning and other policies covering services such as housing, transport, climate change, health and education.\n\nAlthough implied in the Vision statement, it may be appropriate to be more explicit on how all the accommodation issues surrounding an ageing population will be achieved over the next 5-15 years. We would suggest the need to mention the various types of accommodation and the need to strive to ensure independent living with easy access and support of local health and other services required by older people. Reference to the provision of more intergenerational homes on large development sites, in particular, should be made.\n\nWe would suggest the Vision avoids expressions such as ‘beautiful’, ‘flourishing circular economy’, ‘thriving cultural offer will have flourished’ etc.","","As it stands, the Strategic Objectives are fine, but we feel there should be a clear statement on how services, support and specialist accommodation will be achieved/planned for an ageing population. A reference to independent living/ sheltered accommodation, access to medical and health services and adult social care services should be referenced into the objectives. A reference to more intergenerational homes should be made.","Climate change is a significant technical and increasingly important subject.\nWe have purposely not answered Questions 6 to 11 but would like to suggest that the County Council and District Councils invest in a small central team of ‘Climate Advisers’ who can support the aims of the SLP by developing climate change policies, examine strategic and local development proposals covering housing and business etc. and develop planning conditions which require developers to play their part, through the planning process, in tackling climate change.\nThis is such an important and concerning subject that we feel that this sort of investment would be cost effective.","","","","","","","","","","We do not consider exceptional circumstances exist which would justify using a method for calculating housing needs other than the Standard Method. There is always the danger of moving away from a nationally recommended formula to one which is designed locally and subject to possible scrutiny and criticism.","","","","","","","","","","","","","Public transport, active travel infrastructure, primary/nursery/play-school education, GP/Health Services, recreation/play areas and possibly food store.","Public transport, active travel infrastructure, primary/nursery/play-school education, secondary education, GP/health services, recreation, food stores/post office, accommodation/support services for older people, community centre, library services, youth service.","","","","","","","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; ","","","[Q1 - We would support a Plan covering 15 years. Issues such as climate change, strategic housing developments, some business development, transport infrastructure all require this period of time.\n\nHowever, we would expect very rigorous reviews of the strategic aims at 5 yearly intervals. Local Plan developments of a non-strategic nature should be capable, in most cases, of being achieved in a 5-10 year period.\nWe perhaps need to bear in mind that other public sector organisations such as the County Council and Gloucestershire Hospitals have 5-year strategic plans. Many business organisations also tend to have 5-year plans.]\n\n[Q.29] We consider that ‘Development Scenario 3 - Urban Extensions excluding the Green Belt’ should be adopted together with ‘Development Scenario 4 (New Strategic Settlements)’. We feel that public consultation will, once again, indicate support for the retention of the Green Belt.\n\n We have now reached the stage where the Green Belt (the smallest in England) is even more critical in avoiding the coalescence of Gloucester and Cheltenham. It is so important that these unique and historic towns do not merge through ‘creeping’ development. If, as we believe, the SLP consultation will confirm the retention of the Green Belt without further development encroachment into the countryside then there would seem little point in undertaking, as proposed, a further review of the Green Belt. Over recent years there have been 5 reviews of the Green Belt culminating in the last comprehensive review undertaken by AMEC for the Joint Core Strategy.\n\nIt is perhaps worth quoting from the Planning Inspector of the TBC Local Plan who stated, (when dealing with proposed sites in the Shurdington/Badgeworth areas)’The undeveloped gap between Gloucester and Cheltenham lies astride the A46 between two urban areas. The extent of the Green Belt has already been reduced by the JCS through strategic allocations and land safeguarded for longer term development and any further reduction, even limited in nature, requires strong justification’.\n\nIn our opinion, there is a need to adopt Scenario 3 (combined with Scenario 4) and avoid the extensive work required in examining and reviewing the potentially developable 15 sites/parcels of land listed in the Housing and Economic Land Availability Assessment for Tewkesbury Borough Council covering the Green Belt areas of Shurdington and Badgeworth.\n\n[Q.31] Preamble\n\nBadgeworth Parish Council has fully considered the SLP consultation document and welcomes the opportunity to respond.\n\nWe have not answered all the questions asked, but the content and responses made in the following paragraphs follow the same sequence as the consultation document.\n\nIn order to ensure our responses are meaningful and in context we have not used the on-line questionnaire but have prepared this written response.\n\nThere are a number of references to Shurdington service village. This is because the Shurdington settlement area is, uniquely, totally surrounded by the Green Belt and shares a significant part of its southern and western boundary with Badgeworth. The latter is predominately in the Green Belt and/or the AONB.\n\nThe Strategic and Local Plan\n\nWe appreciate that the SLP will cover the Cheltenham, Gloucester and Tewkesbury areas and, very appropriately on this occasion, will cover both the strategic and local plan policies in one document.\n\nLooking forward to the preparation of future Plans, we would like to see one Plan covering the whole of Gloucestershire with the direct involvement of the Cotswold, Forest of Dean and Stroud District Councils. Issues such as public transport, roads, climate change, employment and housing need to be planned over the whole of the County.\n\nThe ‘Duty to Co-operate’ and the preparation of the ‘Gloucestershire Statement of Common Ground’ are clearly essential policies but, in our view, the direct involvement of all local authorities in the planning process is essential. The content of paragraph 2.4 of the consultation document would appear to confirm that this would be the most appropriate way forward."]
["","Bruton Knowles",15,"The NPPF requirement for ‘Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for:\n\na)\thousing (including affordable housing), employment, retail, leisure and other commercial   development;\nb)\tinfrastructure for transport, telecommunications, security, waste management, water  supply, wastewater, flood risk and coastal change management, and the provision of  minerals and energy (including heat);\nc)\tcommunity facilities (such as health, education and cultural infrastructure; and\nd)\tconservation and enhancement of the natural, built and historic environment, including  landscapes and green infrastructure, and planning measures to address climate change and  adaptation.’\nBruton Knowles agree that the SLP should oversee these items as a minimum.","Bruton Knowles are not aware of any locally specific issues that would need be addressed in only one council area.  There is an obvious need for housing within the three-authority areas which needs to be delivered and met within their respective areas and monitored accordingly","","The plan will need to deliver a range of housing sites providing a range of housing types, sizes and tenures. Bruton Knowles considers that it is appropriate for the council to identify housing, and the maintenance of the five-year supply (as a minimum) should form a key objective for the plan. ","","Bruton Knowles agree that it will be important for the Plan to deliver a wide choice of homes that meet the needs of our communities.  Bruton Knowles support the need for the Plan to delivering new homes in the right places to meet the needs of the communities, including market and affordable. Bruton Knowles also support the aim to deliver housing of the right size, type and tenure to create mixed and balanced communities, in sustainable locations (such as Gotherington) that have access to shops, services and facilities.  ","","","","","","","Bruton Knowles suggest that the spatial strategy should recognise that there may be clusters of villages that provide differing services that are within reasonable travelling distance of each other, and thus villages may need to be grouped together. \nHowever, growth in the first instance should be aimed toward villages and towns that have suitable facilities to accommodate new development. ","","","Yes","Standard method should be used unless exceptional circumstances justify an alternative approach.   There are no exceptional circumstances which would warrant a different approach than the standard method being used as the starting point for considering the housing requirements for the Cheltenham, Gloucester and Tewkesbury SLP. \n\nParagraph 61 of the newly revised (Dec 2023) NPPF says that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance. The outcome of the standard method is an advisory starting-point for establishing a housing requirement for the area”.  Paragraph 67 states that “The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment.”","No","","Yes","Bruton Knowles are supportive of the need for new homes.  The Plan should provide for a wide range of deliverable and developable sites across in order to provide competition and choice and a buffer to ensure that housing needs are met in full.  The Plan will also need to deliver a range of housing sites providing a range of housing types, sizes and tenures.","","","","The Council should consider the interaction between employment and housing.  An increase in the number of jobs can generate a requirement for additional housing.  It may be that a higher housing figure is needed for economic reasons and a higher housing number is also needed for housing delivery reasons.  ","Again, note the interaction between employment and housing.","","","The allocation of new housing sites within rural areas helps maintain support for the local facilities, shops and services that may otherwise struggle. Therefore, housing in rural areas is encouraged. ","Development can only be required to mitigate its own impacts and cannot be required to address existing issues and shortfalls.  It would be unreasonable and fail the CIL tests to request developers to pay to address existing deficiencies.  It is not appropriate for any methodology of site selection to increase the likelihood of a site being allocated on the basis of how it could address existing infrastructure problems, or over deliver against policy requirements.","New settlements and large urban extensions can have long lead times.  Reliance on one (or more) new settlements and/or urban extensions can often mean delivery from these sources will occur later on in the Plan period. This increases the importance of the need for a range of other sites to be provided to ensure a Five-Year Land Supply and early delivery of much needed housing. It will be important for policies and allocation in the Plan to provide for a range of housing sites, and as such the site selection methodology needs to reflect this.\n\nTherefore, growth of existing, sustainable settlements (Gotherington for example) should also be encouraged through the Local Plan.","New development in settlements that currently do not have particular service can creates circumstances where new developments supports the provision of new services and facilities in those locations, helping them to become more sustainable. The Local Plan will also need to recognise that settlements that currently do not have services could expand to include those services if new development is allocated in those areas. \n\nThere is a danger that any such criteria could being used negatively to become a way of preventing development in certain communities rather than promoting improved villages and neighbourhoods. The site selection methodology should reflect this position.","","No","","No","Bruton Knowles would suggest that each scenario should also be tested to see the implications it would have on the availability of small sites.  ","",null,"Gotherington has a range of facilities suitable to accommodate future growth.","[Q1.] The NPPF states that strategic policies should look ahead over a minimum 15-year period from adoption and that where larger scale developments form part of the strategy, policies should beset within a vision that looks further ahead (at least 30 years), to take in account the likely timescale for delivery. Bruton Knowles requests that the Council ensures that the Plan period will cover at least the 15-year post adoption of the Plan as required. \n[Q7.] Bruton Knowles would recommend against policies that seek to go beyond national policy changes. There is simply no need for Local Plans to include policies on matters that are adequately addressed through Building Regulations, other consenting regimes and other regulations.  Doing this creates confusion, duplication, misunderstandings, misalignments and sometime full out policy conflicts.\nThe Written Ministerial Statement in December 2023 was clear that this isn’t something Local Authorities should do without robust evidence and explanation.\n[Q8.] The Local Plan should reflect the change in PPG, which now states: \n‘Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified’. \n[Q27.] The consultation considers six distinct scenarios to consider the understand their ‘pros’ and ‘cons of each of them.  As para 6.8 of the consultation notes, none of these scenarios would, on their own, deliver sustainable development and the final strategy will be a combination of different elements. The six different development scenarios tested were:\n•\tUrban concentration\n•\tUrban extensions\n•\tUrban extensions, avoiding the Green Belt\n•\tNew strategic settlements\n•\tRural dispersal\n•\tSustainable transport\nBruton Knowles suggest that the above approach is suitable.\n[Q29.] The housing requirement in the SLP should be increased from the standard method baseline for a variety of reasons including addressing the current housing crisis, meeting housing need and providing affordable housing. A higher housing requirement may also be particularly important if development is to be of the scale necessary to support significant infrastructure projects in a way that is viable and deliverable.  \nThis means that it is likely that elements of all of the scenarios may be needed. Bruton Knowles suggests development within existing settlements, urban extensions and new settlements may all be needed to meet the housing requirements in full."]
["Resident",null,5,"","","No","Our natural population will begin to decline from next year. Immigration is meant to stabilise again after the COVID effect, students will return overseas and less people on humanitarian visas/Ukrainians/HK nationals. Will we end up with a surplus of housing and/or the wrong type of housing?","No","Build on sites that already have planning permission first, instead developers \"land bank\". The developers use land to their own advantage, waiting for best peofits. Is this the case in Gloucestershire? There's the equivalent of 1 million plots in the developers hands already. Don't let them take more green belt land if they have accumulated land already.\n\nDisused office space and brown field sites should be looked at before rural areas to build, especially if we want to be cutting down on traffic/commutes. Local economies in towns/cities thrive better than if houses are built further out. It's also much cheaper for devopers to build on Green than brown land.\n\nStop developers from \"land banking\". Lots of land already has planning permission on it but developers keep it for maximum profit. According to a Cardiff University study\" all three companies (Taylor Winpey, Barrett and Persimmon) were transparent with shareholders about using their market power to withhold housing supply, change the terms of agreements made with local authorities in their favour, and to bring about favourable government mortgage policies like Help to Buy.\n\nThese policies, the authors argue, inflated the price of new builds and disproportionately benefitted the larger housebuilders. The three companies were also open with shareholders about how little competition they faced in the land market, which allowed them to keep down the price they paid for land and therefore maximise profits.\"\n\nWe're an aging population, so better accommodation needs to be built for the older generations, freeing up family homes for families.\n\nEmpty homes need to tackled. There are over 1.5 m empty homes in the UK. 18% in the South West. Some are second homes, AirBnB properties. How many empty properties are in Gloucestershire.\n\nWe need affordable housing and a proper analysis of housing need. Not arbitrary figures which are profit driven for the developers. The answer isn't to just build more houses! Homes need to be built that people can afford to live in like they were before Thatcher sold them off. In the 1970s a third of the population loved in Social Housing. Now it's only 17%. We need more, good quality affordable social housing so that housing is seen as shelter not for landlords to accumulate houses for profit.\n\nCreating new jobs is not a benefit at a time when we have near full employment. Unless we're going to increase migration to make up for our fall in population. An aging population will probably need this to happen, like in Japan.\n\n","What about using green belt for tackling climate change and plant more trees, use it positively for mitigating urban heat islands etc. Growing local food to cut down on food transport miles.","","","Yes","Yes","Blackbridge Field should not have housing or a plastic pitch as it is essential to local cooling to mitigate urban heat island effect plus there is carbon storage in the grass. The site is already partly lost due to concrete car park and sports building. This does not bode well for future higher temperatures.","GP surgeries, schools, shops, libraries","Yes","Wind turbines at Alney Island as there is infrastructure already there","No","The original figures put out by the Government for 300,000 a year was elevated 35% for their manifesto. Where are these local projections coming from? The ONS got some population predictions wrong. Are they based on the 2021 census or the Glos Housing need analysis done in 2019?\n\nFrom 2011-2021 households in Glos rose by 24,800. Are they expected to rise an extra 35,700 by 2041 ? Projected Glos population growth by 2043 is 105,000. 35,7000 houses = av 2.9 persons per household. Is this how the number of houses has been worked out? The UK average is 2.4 persons\n\nAs mentioned before, our natural population will begin to decline from next year. Immigration is meant to stabilise again after the COVID effect, students will return overseas and less people on humanitarian visas/Ukrainians/HK nationals. Will we end up with a surplus of housing and/or the wrong type of housing?\n\nAlso we're an aging population, so better accommodation needs to be built for the older generations, usually sheltered accommodation type apartments, freeing up family homes for families. Family homes that are freed, therefore means less needing to be built.","","","Yes","Definitely houses need to be built for an aging population - sheltered housing/flats. These need to be within towns/brownfield sites so that cars are not needed and all the facilities are within walking distance.\n\nWe do not have enough Social Housing. We need to go back to good quality Council run housing as housing associations differ in quality and as I understand it, council houses are still being offered for sale, meaning that the stock is lessened further. People are too reliant on private rented which is often very expensive.\n\nWe need town living affordable flats for singles and couples so that people can get on the housing ladder. These could be converted over shops as many shop owners leave these empty.","Yes","","","We need to invest in Green energy, growing local food, cutting down on food miles","Creating new jobs is not a benefit at a time when we have near full employment. Unless we're going to increase migration to make up for our fall in population. An aging population will probably need this to happen, like in Japan. If Gloucestershire is planning on attracting people from other parts of the UK to migrate here, that's not of benefit to the UK economy as a whole because then there would be a shortfall elsewhere.","","Housing on brownfield sites and conversion of empty retail properties. Good public transport routes.","","","As mentioned in previous comments they don't need to be this big","GP, local shops, community centres, good public transport","","","","","","Scenario 1: Urban concentration; Scenario 5: Rural dispersal; Scenario 3: Urban extensions, avoiding the Green Belt","","","I think that it needs to be carefully considered that the population might not rise at the rate currently being planned for. We do not want to end up with a glut of housing or the wrong type of housing.\n\nSort out the problem of empty homes.\n\nBuild on land that already has planning permission and stop land banking.\n\nMake sure there is a proper analysis of what type of housing is needed and that houses are not profit led but needs led. It's clear that the big housing developers answer to their shareholders and not to what is actually needed.\n\n"]
["Statutory/Specific Consultee","Prestbury Parish Council",15,"Secondary health care – ie hospitals.","Cheltenham racecourse is in Prestbury parish.  Access for race traffic and local traffic.\nFlooding.\n","Yes","","Yes","But greater explanation is needed - it is too vague","Prioritise dealing with flooding and drainage.","Maximise re-usage of existing buildings.","Maximise re-usage of existing buildings.","","Yes","Add allotments sites to all new developments.","Schools.\nHealth care.\nCorner shops and Post Offices.","Yes","Maximise use of existing sites – eg Sainsbury’s car park at Oakley could be roofed over and solar panels added.","No","We understand the model used dates from 2014.  Much has changed since then – update?","","","Yes","More ‘starter homes.\nMore accommodation for older people.\nNot so many 4/5-bedroom houses.\n","","","","Integration is the key – infrastructure.","","Food security.  Encourage much greater level of food produced from British farms rather than relying so heavily on imports.","Free car parking in all car parks for the first hour.\nLower business rates for all businesses permanently.\nFree business consultation services available to all.","Keep existing car parks.  Cheltenham Borough Council – don’t sell Idsall Drive car park in Prestbury to developers.","An integrated transport policy that includes public transport of all types and provides enough car parking space.\nFailure to provide enough car parking space clogs up roads and causes huge problems for the emergency services.","See above.","See above.","Yes","No","","Yes","","","Yes","One size does not fit all.\nBits from all the development scenarios are required.\nFlexibility.\n",""]
["Resident",null,15,"","","No","Needs to be more detailed to show that the vision will be subject to national government policies including investment, financial constraints, changes in planning and other polices covering housing, transport, health and education","Yes","BUT should be a clear statement on planning for an ageing population.","I'm not sure it can. But continue to promote public transport, cycling.","Cycle paths as part of every housing development along with facilities for public transport.","","Yes","Yes","","schools, GP surgeries.","Yes","Solar, wind, tidal. We simply MUST make use of all the opportunities available locally for clean energy.","Yes","","No","","Yes","Properties to suit an ageing population. A huge barrier to downsizing is the lack of properties for people who wish to downsize. Many people do not wish to downsize to an apartment so there does need to be detached bungalows with small gardens on pleasant developments reserved for over 55's. Putting a few bungalows on a large housing estate along with young families is not going to work!","Yes","","Traveller sites need and must be away from other residential sites. This benefits everyone","","","","","","Public transport, specific segregated paths for cycling and walking, nursery/primary education, GP health services, recreation/play areas.","Shops, recreation facilities. Road infrastructure that does not worsen congestion (e.g. by passing existing residential roads)","School, road network, public transport","Yes","No","","Yes","","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement","No","","The Green Belt has already been compromised in the last JCS. \nGreen Belt sites were reviewed at that time and various areas were removed and are now either developed or allocated for development. Whilst there may be a few smaller sites in the Green belt that do not contribute to its openness, the large swathes of land adjoining existing settlements between Gloucester and Cheltenham should not be developed. \nIn most cases they DO contribute to the openness of the Green Belt. It is already a narrow area between Gloucester & Cheltenham. \nIf these areas are allocated for residential development, the Green Belt will become so narrow it will simply serve no purpose, and Gloucester & Cheltenham will coalesce."]
["Resident","","","I object to a Cheltenham / Gloucester / Tewkesbury megacity; https://www.glos2050.com/ideas/super-city/","","No","I don't want the heritage of Cheltenham, Gloucester & Tewkesbury being eroded by a megacity:\nhttps://www.glos2050.com/ideas/super-city/","No","Cheltenham, Gloucester and Tewkesbury are independent. The public voted against a megacity in 2019","Stop lying about climate change. CO2 does not cause climate change, it is 0.04% of the atmosphere","Faraday cages to stop the involuntary RFR exposure of untested 5G technology affecting residents, particularly those who are EHS","Faraday cages to stop the involuntary RFR exposure of untested 5G technology affecting residents, particularly those who are EHS","","","","We don't want 15 minute cities","No","","","","Yes","The houses should not be used to house illegal immigrants that the UK government are deliberately importing and housing in hotels. ","","","Yes","","A safe space away from harmful 5G masts that are being installed to track and trace the population","","We don't want a megacity. The consultation in 2019 showed that the public are categorically against this idea","","We don't want a megacity","Scrap business rates. Stop allowing small businesses to fail so that you can turn them into more homes ","","WE DO NOT WANT A MEGACITY","","","Yes","Preserving the unique heritage of Cheltenham, Gloucester and Tewkesbury","No","WE DO NOT WANT A MEGACITY","","","","STOP LYING TO THE PUBLIC ABOUT YOUR INTENTIONS TO BUILD A MEGACITY"]
[null,null,15,"","","No","The vision for meeting housing need should be more aspirational, there should be a firm presumption in favour of sustainable housing development, reflecting that of the NPPF. In particular there should be a firm objective to deliver more housing to meet the most pressing needs, particularly smaller homes, affordable housing and housing for older people. The SLP should seek a step change in housing delivery.\n\nThe notion of Green Growth needs to be clearly defined, is this not simply sustainable development, or does it go further?\n\nIt needs to be made clear that in addition to building on brownfield land, delivering the vision will include development on greenfield sites.\n\nIt needs to be clear that building at higher densities, and where appropriate greater height is required to meet housing needs in a sustainable manner.\n\nThere should be a focus on well located development including 15 minute cities.","No","Climate change objectives need to be clear in relation to the whole life carbon cycle, including embedded and operational carbon.","By reducing private car use","new buildings should be operationally zero carbon (with offsetting permitted).","Retention and reuse be encouraged, where an existing building can be effectively and efficiently used for the proposed development  / use.","No","No","","","","","Yes","","No","","Yes","The PPG recognises the importance of planning for the housing needs of older people, noting at Paragraph: 001 Reference ID: 63-001-20190626 that “The need to provide housing for older people is critical.\n\nIt is important that a range of different types of specialist housing types for older people are planned for and sites allocated accordingly. It needs to be recognised that smaller one and two bedroomed homes are the most important sizes. A mix of tenures including sale and rental units should be delivered, but not necessarily co-located within the same site or development for operational reasons. For operational, service charge and management reasons it is very difficult to accommodate affordable housing within market retirement developments, there should therefore be clear policies to deliver any affordable housing requirement offsite / through commuted payments. \n\nThe benefits of specialist housing types for older people in freeing up under-occupied homes should be recognised.","","","","It should be recognised that specialist homes for older people are often significant employers, particularly in care homes and extra care / assisted living sectors. ","","","Reducing traffic congestion, improving the amenity of town centres through street planting, public realm improvements and pedestrianisation. By increasing densities significantly in city and town centres.","","Public transport, and cycle and non motorised travel routes, i.e. segregated cycle paths, both within and linking main centres.","Public transport, and cycle and non motorised travel routes, i.e. segregated cycle paths, both within and linking main centres.","","","Yes","A hybrid model which blends urban concentration and Urban extensions, adopting a sequential approach to focus on urban concentration, using densification and higher rise development, where appropriate, should full housing needs (type and volume) not be able to be accommodated within urban areas, which is expected to be the case then urban extensions should be provided. Urban extensions, should, drawing on scenario 6, be well located in relation to sustainable transport.","No","Scenario 1 seems to assume that urban intensification inevitably results in harm to heritage assets, well designed urban intensification within the setting of heritage assets is not inevitably harmful. \n\nIt is incorrect that there are limited opportunity to deliver climate\nchange mitigation measures, there are significant climate change benefits through the efficient use of urban land.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","","","It is essential that negatively worded policies which restrict the development of specialist housing for older people, such as those which resist an over-concentration of facilities should be avoided.\n\nThe economic, social, health and wellbeing benefits of specialist housing for older people should be recognised.\n\nIt is important that sites are allocated for specialist housing for older people.\n\nIt is important developments for specialist housing for older people are not expected to contribute in the same way as market housing to affordable housing, infrastructure and CIL due to the additional costs related to the development ."]
["","Zesta Planning ","","","","Yes","Cotswold Oak support the vision and objective set out within the document. These are considered to represent an appropriate set of priorities for the area and will help to address wider objectives relating to the climate and ecological emergencies","Yes","Cotswold Oak support the vision and objective set out within the document. These are considered to represent an appropriate set of priorities for the area and will help to address wider objectives relating to the climate and ecological emergencies. In particular, support is given to the following plan objectives: • Delivering sufficient new homes in the right places to meet the needs of our communities, including market and affordable, specialist homes and those wishing to build their own homes (self and custom build homes). • Delivering housing of the right size, type and tenure to crate mixed and balanced communities, in sustainable locations and with good access to shops, services and facilities. • Supporting the creation of high quality, beautiful and sustainable buildings and places through good design • Ensuring that new development is integrated well with existing communities and providing welllocated infrastructure which meets the needs of the community. • Making as much use of brownfield land and conserving and enhancing the natural and historic environments. 6. The draft vision refers to a ‘focus will have been on making best possible use of brownfield sites in built up areas and large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved’. This statement within the overall vision suggests development will be focused on brownfield land and large-scale strategic allocations; allowance needs to be provided for rural development, to include small to medium scale sites within the rural areas. This is discussed in further detail below in reference to the rural dispersal scenario.","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Zesta Planning has been instructed by Cotswold Oak Ltd to make a formal representation to the Strategic & Local Plan Issues and Options Consultation: Spatial Options and Key Policy Areas. 2. Cotswold Oak are an established construction company and housebuilder within the Cotswolds, including Gloucestershire. The team have completed numerous niche bespoke housing developments to high standard of finish. Cotswold Oak have worked on a range of residential schemes from small scale sites to major development applications. 3. In this representation we offer general comments on the spatial options and key policy areas relating to new homes and the sustainable development scenarios; with a particular representation on the rural dispersal scenario and how an element of this should be provided within the new Strategic & Local Plan. 4. Cotswold Oak are also promoting site specific land within Gloucestershire as part of the Housing and Economic Land Assessment 2023 call for sites running simultaneously with the issues and options consultation for the SLP. \n\nThe consideration of a fresh development strategy and the use of six new spatial options is welcomed. As noted, none of these scenarios would, on their own, deliver sustainable development; the final strategy would be a combination of different elements. Scenarios 1-4 are all considered suitable options and would be focused on brownfield land redevelopment and extensions to the current urban areas. These are similar approaches to the previous JCS and allocations within the plan. Albeit, a key consideration for inclusion within the local plan would be in reference to rural dispersal. \n\nScenario 5 Rural Dispersal Scenario \nIt is noted from the Issues and Options consultation document that ‘Scenario 5 – Rural Dispersal’ is one of six different development scenarios seeking feedback at this stage. The consultation document notes this option would “mean distributing growth widely across the rural area by encouraging development at many existing settlements and potentially other rural locations. This would mean the smallest of hamlets and villages could contribute to meeting overall development needs.”\nIt is considered the incorporation of rural dispersal within the new plan is necessary; development within rural locations is important for the vitality of communities, sustaining affordability of housing in these locations and sustaining a younger generation instead of the new generation moving out of the rural areas. As a result, an element of rural dispersal should be provided within the plan. \nThe pros and cons of this scenario have been provided on page 44, with more cons outweighing the pros. Cotswold Oak agree with the five pros listed within the table. However, it is suggested that there is an array of pro’s which have been overlooked and some of the cons have not been assessed correctly.\nThe NPPF paragraph 83 states “to promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities. Planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.”\nThe inclusion of rural dispersal within the new plan would be key to promote sustainable development within rural areas in accordance with paragraph 83. Furthermore, paragraph 70 of the NPPF outlines how small and medium sized sites can make important contributions to meeting the housing requirement of an area and are often built-out relatively quickly. It can therefore be concluded that small and medium scale sites established through rural dispersal can aid in contributing to the overall housing supply. The timescale associated with these sites are much quicker for deliverability than the larger scale strategic allocations; this is evident in the timescale of North-West Cheltenham allocation. As a result, although urban extensions and new strategic settlements will always be incorporated as part of strategic planning; the timescale and realistic deliverability of these provide greater challenges. There cannot be an overelience on large scale strategic sites, given that these are not likely to be delivered in the short term; especially to maintain a five year housing land supply. Larger scale allocations and scenarios such as the urban extensions and new strategic settlements would require longer timescales and reliance on the deliverability of the relevant infrastructure to support such development. As a result, small and medium scale sites are important in making contributions to the housing requirement of an area. Rural dispersal is therefore a key development scenario to be incorporated in the development of the new strategic and local plan. \nFurthermore, rural settlement sites would assist in delivering the housing requirements across the districts to help maintain and achive a five year houisng land supply. Along with this the further development in rural areas would help in the retention of serivces such as the local shop and pub to remain open and functioning. \nThere are an array of sustainable rural settlements across the three Councils which could support further growth. Albeit the growth would need to be proportionate to the size of the settlement and services available. However, the consideration for rural dispersal can be expanded to a greater range of settlements than just the existing Rural Service Centres and Service Villages designated in the JCS, with settlements such as Ashleworth, Apperley and Gretton, to name just a few, being capable of further growth given their size and sustainable locations. Therefore as part of the formulation of the new strategic and local plan, the net needs to be cast wider to encompass areas for further growth at rural settlements. \nThe assumption within the cons list on page 44, that rural dispersal would likely harm the character and setting of existing settlements and surrounding countryside is too generic of a statement. Future policy and design can support that development in rural areas should be compliant with the character of the wider area and minimal landscape harm; this is currently a deciding factor as part of any planning application. However, as a principle of development consideration, the siting of residential development in rural villages needs to be provided in some capacity. \nExpanding development through rural dispersal would welcome the opportunity for a wider range of housing types and tenure to be built, along with improving affordability of the area. This point within the cons list is therefore not agreed with; in fact, it is considered rural dispersal would lead to a more varied form of housing and tenure within rural settlements. It would also aid in the retention of the local facilities and services within the village; development within these rural areas would increase expenditure within the local area.\nFurthermore, we disagree with the inference that rural dipersal is unlikely to support existing or new public transport, leading to greater dependency on the private car and road congestion. To the contrary, housing growth in rural areas helps to sustain bus services, with new developments contributing to the funding and longer term viability of bus services. This has been the case for many of the developments that have recently taken place at the Service Villages. This not only supports the sustainability of the new developments but helps with the retention of bus services for existing communities which are often at risk of being terminated due to a lack of funding.\nOverall, the generic vision, objectives and development scenarios have been well set out. It is considered that rural dispersal should be incorporated as part of the new development plan in some capacity. Rural dispersal is necessary in the vitality of communities, affordability, retaining newer generations in the area as well as positively and significantly contributing to housing supply. Small to medium scale sites which can be provided through rural dispersal will be built out under a quicker timescale than larger urban extensions and strategic allocations such as new settlements. It is acknowledged a mixture of scenarios will be required to formulate the new development plan, however Cotswold Oak strongly recommend for the reasons outlined above that rural dispersal is incorporated in some element as part of the new Strategic and Local Plan."]
["Statutory/Specific Consultee","Marine Management ",20,"See the South West Marine Plan for a full list of marine plan policies relevant to the area in question. Our policies can be referred to as a guide, demonstrating your regard to the marine plans, under the Marine and Coastal Access Act, 2009. It is important to note that marine plan policies do not work in isolation, and decision-makers should consider a whole-plan approach.","See previous question. See the South West Marine Plan for a full list of marine plan policies relevant to the area in question. Our policies can be referred to as a guide, demonstrating your regard to the marine plans, under the Marine and Coastal Access Act, 2009. It is important to note that marine plan policies do not work in isolation, and decision-makers should consider a whole-plan approach.","","Could include further reference to the marine area, encompassing rivers and estuaries, covered under the South West Marine Plan.","","Could include further reference to the marine area, encompassing rivers and estuaries, covered under the South West Marine Plan.","There are many themes within the draft local plan that fall in line with our South West Marine Plan policies. For instance, we also have policies on Climate Change, Seascape & Landscape and Biodiversity which you could signpost to within your Climate Change and Nature Recovery section.","","","","Yes","Please refer to our online mapping tool: Explore Marine Plans","","","South West Marine Plan Infrastructure policy: SW-INF-1 supports the development of land-based infrastructure that may facilitate marine activities such as the use of wave energy within the tidal estuary.","","","","","","","","","","","SW Marine Plan Policy SW-EMP-1 seeks to maximise sustainable economic activity, prosperity and opportunities for all to deliver sustainable economic growth particularly within communities close to marine area and supports existing national policies and strategies to deliver this.","See previous answer. SW Marine Plan Policy SW-EMP-1 seeks to maximise sustainable economic activity, prosperity and opportunities for all to deliver sustainable economic growth particularly within communities close to marine area and supports existing national policies and strategies to deliver this.","","","","","","Yes","","","","","","","","[Q.1] The South West Marine Plan has a 20 year horizon so it would be good to reflect this ambition within the Local Plan. \n[Q8.] Could consider marine biodiversity net gain within the 10%.\n[Q26.] Consider safeguarding marine sites for potential infrastructure. Please refer to Infrastructure policies SW-INF-1 and SW-INF-2 that support the development of land-based infrastructure that may facilitate marine activities and protects landing facilities critical for enabling industries such as shipping, tourism, recreation and leisure, constructure, aggregates and waste.\n[Q31.] There is currently no reference to the Marine Management Organisation and the Marine Policy Statement within the local plan. We would recommend that you mention the South West Marine Plan and the underlying policies and detail how this may integrate with the local plan. Under the Marine and Coastal Access Act, any authorisation or enforcement decisions must be made in accordance with the marine plan. Any other decisions which may impact the marine area must have regard to the marine plan. The South West marine plan extends up the Severn estuary to the village of Maisemore that falls within Tewksbury Borough Council and towards Gloucester Docks within the area of Gloucester City Council. It should also be considered how any activity upstream could influence the marine area and thus be compatible with marine plans, for instance how upstream water quality could affect the marine area, managed under Water Quality policy: SW-WQ-1. There are many themes within the draft plan that fall in line with our South West Marine Plan policies. For instance, we also have policies on Climate Change, Heritage Assets, Tourism and Recreation and Biodiversity which you could signpost to within your Climate Change and Nature Recovery section or when referring to the Historic Environment and Recreation topics. Please get in touch if you have any questions regarding implementation of the South West Marine Plan. The information provided within this document forms recommendations, and we suggest that your own interpretation of the South West Marine Plans is completed. We would also recommend you consult the following references for further information:  South West Inshore and Offshore Marine Plan and Explore Marine Plans."]
["Planning agent or developer","Land owners",20,"","","","Agreed in principle. The vision is, in effect, a wish list that few would disagree with. The key is the way in which the plan-making vision is translated into policy and finally into decision-making. Some supporting text explaining the need for positivity, flexibility and balance would be helpful.","","Delivering a wide choice of homes is set out under just 2 sub-paragraphs. More emphasis needs to be placed on the breadth and depth of housing need and supply, affordable need, the need for smaller sites, and the need for choice. Types of affordable homes are not discussed. There are no references to First Homes or other forms of Discounted Market Sales (DMS) housing. The term self-build does not appear in the Consultation draft.","","","","","","","","","","","Yes, but it should not plan for the minimum. Planning for the minimum has resulted in past plan failures.","","No, except that minimum calculated needs must be exceeded to ensure a robust supply and to ensure real choice.","","More needs to be said regarding choice of affordable housing, including First Homes and DMS affordable housing types. The needs for self-build must also be recognised and properly set out in the Plan.","","","","","","","","By policy, including the provision of proportionate smaller scale housing both in villages, (which should include urban fringe villages), and in rural areas. Scenario 4 could be particularly damaging to rural areas.","","Strategic size new settlements are not supported.","","","","","","Whilst aspects of Scenario 1, e.g., the reuse of PDL can be supported in principle, development should not be crammed into sensitive areas such as Conservation Areas. It is suggested that a review of the Green Belt will produce more sensible, and more acceptable, options for development than Scenario 1.\nThe housing crisis, together with constraints in the SLP area, and disadvantages of adopting other scenarios (in full) point to Scenario 2 as being the most appropriate core option. The circumstances are exceptional circumstances. The SLP Councils have failed to allocate sufficient land, and provide a sufficiently flexible system to deliver small sites of non-allocated land, in order to deliver housing at a required rate. The failure has extended over a prolonged period. Planning is always a question of weighing and balancing competing matters. It is the case that the “Pros” significantly outweigh the “cons” in Scenario 2, but that is not the case with any of the other Scenarios viewed individually. If the Scenario 3 “pros” approach was carried through to the Scenario 2 “cons” approach, there would only be a single “con” to scenario 2. We are not suggesting that is the correct approach, but there has to be a consistent approach.\nScenario 4 is not considered to be an acceptable or appropriate solution. More sustainable land is leapfrogged. The scenario will not assist urban regeneration or existing rural settlements; indeed, it is likely to be damaging to both. \nScenario 3 is not considered to be a realistic option. A review of the Green Belt is necessary. The first of the “pros” listed under paragraph 6.24 links together 3 elements: loss of greenfield land; loss of Green Belt; and loss of best and most versatile agricultural land, as if they were one and the same. That of course is not the case.  The same 3 matters are listed separately as cons in Scenario 2. It is noteworthy (and correct) that Green Belt is the only one of the 3 that is not also listed as a “con”.","Scenario 2: Urban extensions","","(1) larger Central Severn Vale settlements e.g. Churchdown and Innsworth, where not identified as Strategic Urban land have been somewhat overlooked, neither considered Urban nor Rural by past policy. These large villages are in highly sustainable locations and offer good opportunity for sustainable homes where they are needed, whether classified as urban or rural. (2) Ashleworth scores highly, and has expanded despite not being a designated as a service village. (3) Note, presumably a drafting error- paragraph 2.1 The map is wrong as Twyning is excluded from the SLP area as if it were not in Tewkesbury Borough. (The map on page 40 correctly includes Twyning)","[Q1] A 20 year minimum would be better for long-term planning, but perhaps of greater importance is the need for monitoring and review to ensure that the SLP remains fit for purpose. Planning for the minimum (Housing) has not worked in the past. Such a strategy should not be followed for the SLP.\n\n[Q29] Scenario 2 Urban extension with loss of some GB. It is however not considered appropriate to have an “all eggs in one basket” approach so a combination of scenarios is necessary. There are merits in Scenario 6 Sustainable Transport Scenario, but not at the expense of Scenario 5. Rural dispersal, where smaller scale development, which will support existing villages, should in principle also be encouraged. \n\nAt first glance the evidence base appears limited, although on closer inspection further evidence specific to individual Council administrative areas is provided. Taking the Green Belt as an example the evidence base refers to the September 2011 Green Belt prepared for the JCS. A more recent review LUC final Report July 2017  is found by following the link to the TBC evidence base.  For ease of reference all documentation that form the SLP should be filed in a single evidence base. \nGiven the extent of unmet housing need and the breadth of development constraints, including the direction of travel of national policy in matters including: sustainability; climate change; and biodiversity gain, a comprehensive review of the Green Belt is considered to be both overdue and necessary."]
[null,null,1,"Yes. The UK birth rate is less than 1 and the desires of the local communities for no further (imposed) expansion","Churchdown","No","If development is essential then it should be away from existing areas eg Innsworth","No","Denial of the need for further development","By leaving things as they are, extra CO2 will not be generated","Away from existing developments and in areas that are not productive for food eg hillsides","These should be refurbished which generated the least  CO2","No","Yes","All the farmland around me","Doctors surgeries","No","","No","0% population growth","Yes","•\tUK birth rate is less than 2 per couple so our indigenous population is decreasing.","","","No","Use brownfield sites","Brownfield sites","UK desperately needs more manufacturing to avoid buying from abroad. More factories. We also can't produce enough food for the population so we need more agriculture","If we don't build more houses then we don't need more employment!","By expanding farming and this will help us feed ourselves","Out of town retail is easy to get to and provides parking locally so abandon town centres.","This happens naturally by definition!!! If it is essential then it will be viable - if it isn't then it will die","Cycling and pedestrian paths (sinks for flooding)","New roads, schools, pharmacies,shops,hospitals,community centres,pubs,transport,gas, electricity, sewage, internet,post (You know all this (I hope))","New roads, schools, pharmacies,shops,hospitals,community centres,pubs,transport,gas, electricity, sewage, internet,post (You know all this (I hope))","Yes","Yes","Do nothing. Assume no population increase based on birth rate","Yes","","Scenario 5: Rural dispersal;","No","","We should work for a stable population. We cannot afford to build on farmland as we cannot already generate enough food in England for us."]
["Resident",null,5,"","","Yes","","No","Do not agree with 3 \" higher density \ndevelopment in city and town centres\"","For new build houses, Housing Committee to insist on no gas boilers, and all roof tiles to be photo-electric sensitive.","For new build houses, Housing Committee to insist on no gas boilers, and all roof tiles to be photo-electric sensitive.","Help with reducing carbon footprint.","Yes","Yes","Household gardens","Primary care","Yes","","Yes","","","","","","No","","","Need to house skilled workers","","","More households in city centre","","Primary care, schools","Primary care, schools","","Yes","","","Yes","","Scenario 2: Urban extensions","","",""]
["Statutory/Specific Consultee","Network Rail","","","","","Draft Vision and Strategic Objectives\n\nThe Strategic Local Plan (SLP) looks to address a number of key issues through planning policy in order to meet Government objectives and priorities.\n\nKey issues of interest to NR are those relating to Transport and infrastructure with the new plan looking to ensure new homes and jobs can be accessed by different types of transport including walking and cycling and the identification and facilitation of infrastructure needed to support development.\n\nThe draft Strategic Objectives prioritises sustainable transport and active travel through promoting the use of sustainable travel modes, improving existing and providing new transport links as well as safe walking and cycling routes in all new developments. The objective to prioritise sustainable transport should also consider the connectivity to services, and the safe use of Public Right of Ways especially in relation to level crossing use. ","","Draft Vision and Strategic Objectives\n\nThe Strategic Local Plan (SLP) looks to address a number of key issues through planning policy in order to meet Government objectives and priorities.\n\nKey issues of interest to NR are those relating to Transport and infrastructure with the new plan looking to ensure new homes and jobs can be accessed by different types of transport including walking and cycling and the identification and facilitation of infrastructure needed to support development.\n\nThe draft Strategic Objectives prioritises sustainable transport and active travel through promoting the use of sustainable travel modes, improving existing and providing new transport links as well as safe walking and cycling routes in all new developments. The objective to prioritise sustainable transport should also consider the connectivity to services, and the safe use of Public Right of Ways especially in relation to level crossing use. ","","","","","","","","","","","","","","","","","","","","","","","","Infrastructure\n\nNational planning policy sets out that plans should specify the policy requirements for the contributions expected from different types of development and where necessary, from\ndifferent sites.\n\nSeveral key issues have been identified in the delivery of sites and associated infrastructure, but no reference has been made to the impact forthcoming development will have on level crossing\nuse within the Joint Local Plan area and the infrastructure improvements associated with increases in usage. This is specifically true for the impact development is continuing to have on\nHomedown level crossing in Tewkesbury.\n\nIt has been identified that new infrastructure associated with new housing and employment sites will need to be funded through central and local government streams as well as\ncontributions from developers. \n\nDeveloper contributions should be sought for development proposals within the Tewkesbury Garden Town area that are likely to impact on Homedown level crossing in order to fund the\nnecessary improvements to Homedown LC. Improvements include the installation of a footbridge or stopping up the PROW via a diversion route. Where development contributes to\nthe material increase in pedestrian use over a level crossing, contributions should be sought. Policy should include a requirement for details of how development will impact on the railway\ninfrastructure (railway crossing) to be included in Transport Assessments. Developers must also demonstrate that safety will not be compromised, and where it is compromised serious\nmitigation measures would need to be incorporated to prevent any increased safety risk as a requirement.\n\nLevel crossings can be impacted in a variety of ways by planning proposals:\n• By a proposal being directly next to a level crossing\n• By the cumulative effect of development added over time\n• By the type of crossing involved\n• By the construction of large developments (commercial and residential) where road access to and from site includes a level crossing\n• By developments that might impede pedestrians’ ability to hear approaching trains\n• By proposals that may interfere with pedestrian and vehicle users’ ability to see level crossing warning signs\n• By any developments for schools, colleges or nurseries where minors in numbers may be using a level crossing\n• By any development or enhancement of the public rights of way\n\nThere is therefore an opportunity to address highway safety issues within the Ashcurch, Tewkesbury area in the form of level crossing safety. Currently there are 4 approved housing\nschemes on the western side of the railway which will cause an increased risk at Homedown Level Crossing. Network Rail were not consulted on 3 of these schemes and therefore had no\nopportunity to object or request contributions towards a footbridge or diversion of the PROW known as the Gloucestershire Way. ","","","","","","","","","","","[Q.29] Developmental Scenarios\n\nScenario 6 – Sustainable Transport Scenario\n\nThis scenario looks to deliver development in locations that are along existing and potential high frequency public transport, walking and cycling routes. This would mean prioritising new\nsites for housing and economic development in locations that maximise sustainable travel to access facilities and jobs.\n\nWhilst strategic scale development in these locations would support the use of sustainable transport like the rail network, improvements to rail infrastructure must be considered in order to address the increase in demand on the network and improve infrastructure for users such as providing necessary infrastructure to reduce increased risk from level crossing use. As Network Rail is a publicly funded organisation with a regulated remit it would not be reasonable to require Network Rail to fund rail improvements necessitated by commercial development. It is therefore appropriate to require developer contributions to fund such improvements.\n\nTewkesbury Potential Sites (HELAA)\n\nAccording to the Tewkesbury Council HELAA Map, the majority of land around Homedown level crossing is potentially developable for either employment use or housing schemes. This raises great concern with Network Rail surrounding the cumulative increase in people who will have access and use of Homedown level crossing and the PROW network that connects to it. The increase in risk to railway safety this will generate will be substantial with an increase in misuse imminent. \n\nIt is therefore vital that forthcoming developments in this area are required to provide development contributions towards the necessary improvements needed to reduce risk\naround the use of rail infrastructure within Ashchurch. \n\nNorthway Level Crossing – Tewkesbury\n\nClosure of the level crossing north of Ashcurch station known as Northway has previously been discussed due to the detrimental impact housing developments in this location would have on the risk generated at the crossing. It had been previously agreed that the crossing should be closed and diverted over a new structure, eradicating the safety risk to the public as well as supporting potential changes in services moving forward however funding for this has since been lost. \n\nClosure of Northway level crossing is still necessary to reduce risk from potential surrounding development and therefore developer contributions are necessary to provide mitigation in the form of a bridge.\n\nCheltenham\n\nA number of level crossings within the Cheltenham area including Churchdown 10, Morris Hill and Alstone Level Crossing are also vulnerable to increases in risk as a result of development. \n\nThe LPA should recognise the importance of providing the necessary infrastructure to accompany development proposals that will aid in the reduction of risk at level crossings\ncaused by development. \n\nCheltenham Potential Sites (HELAA)\n\nAccording to the Cheltenham Borough Council Draft HELAA (Dec 2023), there are two larger sites adjacent to Alstone level crossing which are deliverable for both residential and mixeduse development (Image 2). Similarly, there is a number of large sites around Morris Hill LC with land at Morris Hill (Image 3) being the closest. These all have the potential to be delivered as residential development/mixed use and therefore will impact on the use Morris Hill level crossing.\n\nPotential site allocations should therefore consider the impact development will have on the use of the level crossings with assessment being undertaken of this use within a submitted transport assessment. \n\nWe trust these comments will be useful in the preparation of the forthcoming plan documents.\n\n\n\n[Document also contains graphics - see separate PDF]"]
["Resident",null,60,"These are all very laudable objectives, but how development is to be \nmeaningfully and appropriately delivered on the ground in any \nlocation is of great importance.\nThere is no provision for master planning in any locality. It is a \nconcern there will be a mismatch between high level assessment of \nthe SLP and the delivery of clear and meaningful development at \ncommunity level.","The traffic on the B4215 which passes through Highnam. \nThis is a 'B' Classification Road, but due to the bridgehead status of \nGloucester with through traffic and commuter traffic converging from \neasterly and westerly directions, the A40 Northern Bypass frequently \nbecomes congested. This traffic passing around Gloucester dissipates in \na westerly direction largely onto the B4215, which is too narrow a road to \nsafely take the volume of traffic using the highway, with inadequately \ndesigned and unsafe footpaths for pedestrians.\nThe traffic is busy throughout every day and comprises the full range of \ncommercial, business, public service and private vehicles. What needs \nto be recognised is that this road not only serves the growing \ncommunities west of Highnam, being Newent, Ross-on-Wye and the \nsurrounding area, including the M50, but also further afield. It has \nbecome a major trunk road for vehicles originating and completing their \njourneys from a south westerly direction beyond Swindon, the M4 and \nOxford, to the River Severn bridgehead at Gloucester, with destinations \nin Herefordshire, and further afield into Wales. The B4215 in used in \npreference to the A40, as it is less undulating and a more direct, linking \nwith the M50 at a motorway junction.   The B4215 is also used in preference to the A417 which also routes to the M50.\nFor those wanting to travel by rail from Gloucester station and travelling \nfrom the West, they largely pass through Highnam along the B 4215.\nThis is a route under pressure and which is also vulnerable. Whenever \nthe A417 is closed, due to the A 417 being closed, due to flooding from \nthe River Severn breaking its banks, or the M5 closed due to accidents,\nthe B4215 is impacted, resulting in queues and tailbacks through the \nvillage at times gridlocking the community.\nThe A40 Gloucester Northern Bypass also floods periodically making \nemergency access for emergency service vehicles to Gloucester and \nCheltenham impossible.\nWith the ‘missing link’ highways development improvement work \nbetween Crickley Hill and the Cowley Roundabout on the A417, as well \nas connecting with the M5, more traffic will be funnelling along the \nNorthern Bypass around Gloucester heading Westwards towards \nHerefordshire and Wales, adding further traffic to the B4215 through \nHighnam.\nThe Highways authority have not engaged with this problem, but it \nneeds to be addressed and considered in the emerging Strategic & \nLocal Plan.\nThe economic impact of commuting delays on the A40 through Highnam for traffic needing to cross the River Severn is significant, any travelling beyond the local conurbations, e.g. to Birmingham, Swindon, Bristol and beyond requires careful timing or very early starts to avoid this congestion.\nNote the majority of inhabitants of any new residential properties west of the Severn will be commuting to destinations across the river.  A fundamental need for any further housing development west of the Severn is a further Severn crossing, probably from the South of Gloucester (Jn 12 M5) across to the Forest of Dean.","No","Adjustment to include consideration of adjacent areas, specifically the boundary with the Forest of Dean for communities that border this area.","No","Ensure that existing and future local community strategic plans, such as Highnam PC Neighborhood Development Plan are fully considered and embedded into the wider local and strategic plans.  The will and views of the local communities should be recognised and embedded not overridden.","Climate Change is happening and it is becoming an everyday reality.\nThe best way the Strategic and Local Plan could be most effective is as \na facilitator to work with other agencies to create a comprehensive set of \npolicies which together have impact and become effective.\nFrom the viewpoint of the Parishes close to the Severn Vale, flooding is \na major consideration and is already having a deleterious impact on \nHighnam. There are those properties directly affected which flood, whilst \nall the communities are affected by the lack of appropriate roads, \ndrainage, maintenance and adequate highway infrastructure. The \nincrease of traffic on an inadequate road infrastructure on the A40 and \nB4215 is exacerbating the problem.\nIf we are to become less reliant on cars, properly considered public \ntransport systems which are affordable, convenient, reliable and operate \nat times when passengers need them are essential. Unless the \nappropriate services are in place to meet people’s needs, transport \nservices will not and cannot be properly utilised. \nThere seems to be a belief amongst governing authorities that people \nwill change their behaviours by force, through cost penalties or making \nusing cars undesirable. A better, more popular and successful strategy \nwould be through inducements and transport systems which actually \nwork better than the conventional reliance on cars. \nThe present provision for the use of bicycles through cycle lanes is \neating up financial resources and space, to such an extent that in certain \nlocalities up to a third of the highway is taken up with dedicated lanes \ncarrying proportionally far fewer riders than the highway carries car \ndrivers and passengers.\nCycle lanes are however a positive innovation, but they have to work \nand are not a panacea for low carbon transport. Too many road users; \nHGVs, the disabled, emergency service vehicles, longer distance \ntravellers, van drivers and tradesmen etc., are excluded from using \nbicycles and dedicated cycle lanes create only a very partial solution to \nthe problem of polluting traffic and global warming. \nWith the current public sector strictures on finance and investment in the \ncommunity, there has been an increasing reliance on the private sector \nto pay more towards public infrastructure and services. There is a tilting \npoint beyond which the private sector cannot and will not pay to \nsupplement the funding of public projects. Their motive of the private \nsector has to be profit: the higher the financial burden and the tighter the \nimposed strictures, the poorer will be the private sector product, as with \nmodern estate housing, alternatively development will stop all together. \nThe emerging Strategic & Local Plan should be a facilitative document, \nenhancing and supporting communities to thrive as beautiful places to \nlive. All the necessary facilities should be made available to emerging \ncommunities through a comprehensive and well considered set of \npolicies.","","","Yes","No","This comment relates to Q8 above (no text box provided to add context to a Yes or No answer).\nWhilst biodiversity is important and the loss of wildlife habitat and plant \nspecies significant, care has to be taken how restorative action is taken. \nThe causes of the reduction in biodiversity are complex and targeting \ndevelopment and setting a 10% target might be inadequate. This alone \nwithout comprehensive policy covering all sectors of the economy will \nnot achieve the desired results. It may have the effect of stifling much \nneeded balanced development for employment and providing homes for \npeople to live in. Planning policy needs to be mindful of the complexities \ninvolved and the risk of unintended consequences of poorly informed \nand executed policy decisions.","","Yes","Solar generation  -  should focus on building roof and brown field site installation and minimise the use of prime agricultural land.\nBattery storage -  again should be provisioned in brown filed site locations or redundant farm yards.","","","","","","","","","","Location is everything, close to facilities and transport links (extension of existing industrial and commercial sites).","Create facilities and investment incentives that will support newer High Tech businesses (Tech Hubs).  Leverage relationships with local and national universities that are looking to create/spin out new businesses and are looking for appropriate modern facilities and business rate incentives.   ","Plan for new or extension of existing small business sites with varied use, i.e. office space, both shared and segregated, small workshops and small combination units that can serve both office and workshop needs for startup businesses.  These need to be backed by low rental costs, low (renewable) power costs and low business rate incentives.","","","Highway infrastructure - new and scaled appropriately for future growth.\nFlood protection and management.\nSchools, location and capacity.\nHealth facilities, location and capacity (Hospitals, Clinics, GP surgery's, Pharmacies).\nLocal retail outlets particularly in rural areas (to reduce the need to travel)\nPublic transport infrastructure.","As above","This will depend on the rural settlement being considered.  I would refer you to The Key Issues Statement submitted by Highnam Parish Council which identifies the matters that are relevant to developments in our Parish.   All of the above are relevant but the Highnam PC submission expands on this.  Items such as:\nCharacter\nHighway Infrastructure\nUtility Services\nFlooding\nEnvironment\nHousing Mix\nCommunity Infrastructure\nSustainability\nExisting Neighbourhood Development Plans ","Yes","No","","No","The 6 Scenarios suggested in the Strategic and Local Plan\nA Highnam Perspective\nIn the SLP Parishioners are asked which of 6 scenarios they would like to see the development of new homes and jobs fall into. There are pros and cons of each, some affecting Highnam more than others.\n1. Urban Concentration, this would involve increasing the density and height of the buildings within Gloucester and Cheltenham. This would rejuvenate city centres and use some unused previously developed sites.  This scenario would not affect Highnam unless the urban expansion did not produce enough houses etc.\n2. Urban Extensions, this option looks at extending all three towns/cities where this works best, an example of this would be Northway, Abbeymead, Churchdown etc.This may involve green belt areas.  This would mean public transport is more cost-effective, as these extensions can be easily supported from the centre. It may also produce nicer places to live, with lower densities.  From the Highnam perspective, we should be protected by the river from urban creep of houses.\n3. Urban Extensions, this option is as no.2 but not involving the green belt. The green belt was agreed Nationally to manage urban growth and comes with National policies. The extensions in this would include the areas that were moved from the green belt when the JCS was written.\n4. New strategic developments and settlements, these are seen to be \nindependent settlements with their own built-in infrastructure from the offset. These typically will consist of 4000 houses as a minimum. Three options have been suggested in the SLP. Ashchurch has already been granted Garden Town status with a significant grant from central Government. It has employment opportunities with a new business park and easy access to the motorway.  Boddington a rural area has been suggested, this falls between the M5 corridor and A38 so good road infrastructure to help with the development. There would be a loss \nof good agricultural land. \nThe third suggestion was the Highnam / Churcham triangle. This area has a poor, oversubscribed road network, not near any motorway junctions. The land and whole area is subject to frequent flooding with knock on effects to the neighbouring villages. Prime arable land would also be lost. This, third site, of this scenario is unsuited to this type of development.\nThis option only identifies land in the TBC area, and doesn’t share the responsibility with Gloucester and Cheltenham.\n5. The Rural Dispersal, option looks at the distribution of the housing requirement throughout the whole area, not just service villages and centres. This would enlarge existing communities, making them more viable in some areas, but for others, this would be over capacity for existing infrastructure and resources, like the schools, Doctors, \netc. They would also lack a good transport network as this would not be cost effective.\nIn Highnam, being a service village development has already occurred and continues to receive development. It is already at the point of the infrastructure not coping with demand. The roads are too busy, the school is over capacity and local children have to travel fair distances to a school by car, as there is no public transport and they are too far to walk or cycle. This goes against developing a good carbon footprint, which has been agreed as a common understanding between Councils.\n6. Sustainable Transport option, this suggestion looks at development along existing / potential public transport corridors, including cycle routes and walking routes. The development is linked to areas of good transport networks, promoting more sustainable travel, and reducing carbon emissions from transport.  This option prioritizes housing and economic development in areas where travel choices can be maximized.\nThis option ticks the boxes for sustainability and reducing the carbon footprint. It can also be linked with the Urban extensions in a lot of cases.\nSummary\nThese options can not be seen in isolation and a mixture of some of the options may be the best fit. The Ashchurch Garden Town has already been decided upon and meets the criteria for a new strategic development. This does not mean this is the best option for all areas. \nRural dispersal to a degree has already been achieved in service villages and centres, and is nearing, or has reached its infrastructure capacities. More of the same is not an option.\nUrban extensions, retaining as much green belt as possible would be the best choice, to achieve nice places to live, better transport networks and links to larger urban facilities. If people want to move to a more rural location, this can then be available if they choose. Variations in the way people live should be celebrated and welcomed as all people are individuals. One size does not fit all.","","","","The survey structure and lack of cross reference to the consultation document has made the process of completing the survey very difficult.  I doubt whether this process will yield a well rounded set of views and I am sure many will have given up on the process to complete.\n\nI would direct you to the submission made by Highnam Parish Council, particularly the 'Key Issues Statement' submitted by Cllr Charlie Coats dated 27th February 2024.  This is an excellent representation of the views of the Parish and also positions the existing Parish Neighbourhood plan as the core of what we believe makes sense for the Highnam Parish.\n\n\n"]
["Planning agent or developer","European Property Ventures (Gloucestershire) Ltd","","","","Yes","EPV supports and agrees with the draft Vision and Strategic Objectives as proposed in the SLP. Whilst these are aspirational, the proposals to meet the needs for housing and other development is strongly supported. However, it must be ensured that as the Plan progresses, the Vision and Objectives are not diluted and the Plan responds effectively for these objectives.","Yes","EPV supports and agrees with the draft Vision and Strategic Objectives as proposed in the SLP. Whilst these are aspirational, the proposals to meet the needs for housing and other development is strongly supported. However, it must be ensured that as the Plan progresses, the Vision and Objectives are not diluted and the Plan responds effectively for these objectives.","Within Chapter 4 of the emerging Plan, the authorities identify the importance of supporting the transition to a low carbon future and helping to contribute to reductions in green house gas emissions, minimise vulnerability and improve resilience to impacts. EPV supports this approach, particularly whereby the emerging Plan recognises in this context the importance of ensuring development is directed to the most sustainable locations. This is particularly important in the plan-area, whereby there are a range of types of settlements and it is critical for the Plan to appropriately consider where development should be located. As later sections of these representations will establish, in particular EPV suggest that the sustainable credentials of Shurdington should be recognised, as it represents a settlement that is well-located to accommodate growth, particularly given the range of existing services and facilities on offer at the settlement, as well as high quality transport links to key destinations. The delivery of new growth at Shurdington would accord with Paragraph 109 of the Framework which provides that the planning system should actively manage patterns of growth in support of sustainable development objectives by concentrating growth at locations which are, or can be, made sustainable through limiting the need to travel and offering a genuine choice of transport.","In respect of measures and standards for construction and operation of new buildings, the authorities should recognise the December 2023 Statement from the Government on Local Efficiency Standards. This confirmed that authorities should not be proposing local efficiency standards that go beyond existing building regulations or those coming into effect in 2025. Where authorities want to promote standards in Local Plans that go beyond those requirements, the Statement confirms that this must be well reasoned and accompanied by robustly costed rationale. EPV therefore requests that the authorities are mindful of the Government’s position on this matter when drawing up policies in relation to this.","","No","","","","","","Yes","The emerging Plan references the intention to undertake an updated Local Housing Needs Assessment later in the process of preparing the new Plan. It is strongly advised that this be prepared at the earliest opportunity, recognising the requirement of the Framework for Plans to be based on proportionate evidence and the importance of ensuring that evidence is up-to-date. Paragraph 60 establishes the importance of meeting the needs of groups with specific housing requirements, and therefore the authorities must have an understanding of this to ensure that specific needs can be planned for. 5.2 The Plan recognises the standard method provided by the Government represents a starting point for determining housing need. Whilst the Framework at Paragraph 61 establishes that there may be exceptional circumstances to justify use of an alternative methodology, it is not considered that such circumstances exist in the case of the SLP. As such, EPV strongly recommends that the authorities proceed with preparation of the Plan using a housing need figure that is based on the standard method calculation.","Yes","Whilst the emerging Plan recognises the standard method is a starting point, it does not go on to consider subsequent provisions considered in the Framework. This includes the need to also reflect current and future demographic trends and market signals. In addition to the local housing need figure, it goes on to identify that any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for. It is particularly pertinent that the emerging Plan appropriately plans to meet housing needs across the Plan area in full, recognising the persistent housing land supply issues particularly prevalent in Tewkesbury as evidenced by recent planning appeal decisions. An appeal decision (reference: 3326538) issued on 21 February 2024 confirms that the housing shortfall in Tewkesbury Borough is significant, with the signed Statement of Common Ground agreeing a housing land supply position of 3.39 years.\nIt is therefore considered that the emerging Plan should seek to remedy previous shortcomings in this regard, seeking to promote levels of housing over and above the standard method requirements to help address the Framework’s expectations of boosting housing delivery. As such, EPV recommends that the authorities should prepare the Plan on the basis of being able to deliver appropriate housing numbers that will ensure the three authorities are able to maintain housing supply and delivery throughout the emerging plan period, with sufficient contingency to adapt where sites take longer to be delivered or do not have the capacity originally envisaged. It is considered by EPV that this would represent appropriate justification for deviating from the standard method calculation, to provide additional buffer in housing numbers to ensure that the Plan contributes to boosting housing delivery and maintaining appropriate levels of housing across the three authority areas. In accordance with Paragraph 35 of the Framework, it is imperative that the SLP is positively prepared. It should be recognised that this includes a requirement for Plans set out a strategy which, as a minimum, seeks to meet the areas objectively assessed needs in order for the Plan to be capable of being found sound at Examination. The provision of Paragraph 35 of the Framework evidently establish the standard method housing requirement as a baseline for determining housing need, and it is strongly advised that opportunities to deliver new housing over and above this minimum requirement are progressed. ","","","","","","","","","","The emerging SLP recognises the role of city and town centres, as well as smaller village, farm and neighbourhood shops, as important and often forming the focus within communities. It also recognises that there are a wide range of different centres that perform different, but equally important roles. A review of the Retail and City/Town Centres was undertaken in March 2021, however it is noted that this only considered Town and City Centres, with no assessment done of other settlements. It is considered that the evidence supporting the Plan should fully consider the range of settlements and the role that these play, which should inform decisions regarding distribution of growth and infrastructure requirements across the Plan area. 5.6 Notwithstanding this, the Plan does recognise the role of planning policies to protect important community facilities outside of the main city and town centres, and support their diversification. This is strongly supported, noting that the Plan area contains a number of sustainable rural settlements such as Shurdington, which represent logical and appropriate locations to accommodate future plan-led growth. It is critical that the Plan fully acknowledges the importance of planning for growth and new development at existing sustainable and well-served settlements to help protect essential shops, services and facilities in villages and the rural areas. Such an approach would ensure that the SLP is consistent with Paragraph 83 of the Framework which advises that planning policies should identify opportunities for villages to grow and thrive.","In respect of determining appropriate locations for growth involving rural settlements, it is understood that the authorities are considering what key services and facilities are considered most important. EPV strongly encourages the authorities to consider what facilities should be most readily accessible to residents without the need to travel long distances, for example primary schools; convenience retail; GP surgery; open space; which should all be within a short distance of people’s homes. In respect of other facilities, such as secondary education; other retailers; employment and other leisure facilities; whilst it would be preferable for these to be close by, it should also be recognised that public transport links between settlements and key destinations should also be an important factor, and only assessing settlements in terms of existing facilities in isolation is not appropriate.","","In respect of determining appropriate locations for growth involving rural settlements, it is understood that the authorities are considering what key services and facilities are considered most important. EPV strongly encourages the authorities to consider what facilities should be most readily accessible to residents without the need to travel long distances, for example primary schools; convenience retail; GP surgery; open space; which should all be within a short distance of people’s homes. In respect of other facilities, such as secondary education; other retailers; employment and other leisure facilities; whilst it would be preferable for these to be close by, it should also be recognised that public transport links between settlements and key destinations should also be an important factor, and only assessing settlements in terms of existing facilities in isolation is not appropriate. As such, it must be recognised that Shurdington is well served by both existing facilities and public transport links, representing a sustainable location for future growth. There is a Primary School, Post Office & Store, Community Centre, Sports Club and Open Space, Public House and various employment opportunities; whilst further facilities are located at the southern edge of Cheltenham, approximately 1.5km to the north, and readily accessible by frequent bus services. The sustainability and accessibility of Shurdington is further assessed in Section 7 below.","","","Before considering the most appropriate strategy for growth in the emerging Plan, it should be recognised that the existing strategy focused on urban areas of Cheltenham and Gloucester, as well as urban extensions. As a result, the adopted planning policy context failed to fully consider the potential opportunities for development at sustainable rural settlements such as Shurdington, restricting the opportunities for new homes to be provided at such locations. This was predominantly as a result of a failure to comprehensively review the Green Belt through the JCS, with no Green Belt release pursued at Shurdington restricting the potential for development. This was compounded through the adopted Tewkesbury Local Plan, which again failed to advance growth that would have required Green Belt release but would have resulted in development that could meet the settlement’s housing needs. 6.2 A review of available housing monitoring information published by Tewkesbury Borough Council in the 2020/2021 Housing Monitoring Report confirms that between 2011 and 2021, 15 dwellings were completed at the settlement. In terms of other housing coming forward, the latest housing land supply monitoring information published in October 2023 identifies only one major development with consent, which comprises allocation SHU2 from the adopted Borough Local Plan, where 25 dwellings were approved in May 2023, confirming how plan-led growth is critical at the settlement. Otherwise, only 6 further sites are identified with permission totalling 9 dwellings. This confirms the challenge in bringing forward housing development at the settlement, despite its sustainability and local demands for both market and affordable housing, demonstrating that the emerging SLP should advance a positive approach to growth at Shurdington to address this. 6.3 As such, it is critical through the emerging SLP that a comprehensive review of the Green Belt is undertaken alongside a detailed assessment of sustainable locations for growth, such that sustainable settlements such as Shurdington benefit from plan-led growth. The Framework makes it clear that plan-making remains the only opportunity for reviewing the Green Belt, and whilst it is recognised that the latest revisions to the Framework in December 2023 removed the need for authorities to do so, Paragraph 145 continues to establish that authorities may choose to do so, where exceptional circumstances are fully evidenced and justified. It is considered that the strategic level of plan-making advanced by the SLP provides a positive opportunity to assess the designated Green Belt, and identify situations where there are opportunities to facilitate sustainable development by releasing small areas of low-performing Green Belt such as at Shurdington. 6.4 In respect of the spatial options identified, EPV strongly recommends that the authorities recognise that a single option in isolation is unlikely to result in a sustainable pattern of growth or deliver sufficient levels of growth to meet the Plan area needs. As a result, it is encouraged that the authorities consider how best to advance a spatial strategy that combines the options and pursues the most sustainable options for growth and development. The spatial options identified by the Plan currently fail to recognise the credentials of pursuing a dispersed model that focuses on the more sustainable rural locations, rather than considering all rural locations equally as per Option 5. This could also integrate locations well served by sustainable transport (as per Option 6), which should include consideration of locations such as Shurdington whilst also Claremont Planning on behalf of European Property Ventures (Gloucestershire) Ltd Representations to GCT SLP Regulation 18 Consultation March 2024 7 contributing to achieving wider objectives of the Plan that include addressing climate change and improving access to sustainable transport. 6.5 It is particularly important the that authorities recognise the risk of relying on new settlements, and ensure that a full range of sites are considered and allocated, including small to medium sites that can be delivered more swiftly. The provisions of Paragraph 69 of the Framework must be recognised, which require a mix of sites, including specific, deliverable sites for the first five years following adoption; as well as specific developable sites or broad locations for the remaining plan period. This is particularly pertinent in Gloucestershire, recognising the recent history of the proposed Garden Town at Tewkesbury, which was awarded Garden Town status in 2021, but remained at an early stage of planning with significant uncertainty regarding infrastructure delivery as of early 2024. Whilst Paragraph 74 of the Framework identifies that the supply of large numbers of new homes can often be best achieved by planning for a larger scale of development, the Framework also requires that proposals for this scale of growth are informed by a realistic assessment of likely delivery rates given the lead-in times associated with delivering this scale of development. As required by Paragraph 70 of the Framework, the contribution that small and medium sites, such as EPV’s site at Shurdington, can make towards meeting the housing requirement of an area must be recognised. The land under EPV’s control at Badgeworth Lane, represents a suitable site that is immediately available for development.","","Before considering the most appropriate strategy for growth in the emerging Plan, it should be recognised that the existing strategy focused on urban areas of Cheltenham and Gloucester, as well as urban extensions. As a result, the adopted planning policy context failed to fully consider the potential opportunities for development at sustainable rural settlements such as Shurdington, restricting the opportunities for new homes to be provided at such locations. This was predominantly as a result of a failure to comprehensively review the Green Belt through the JCS, with no Green Belt release pursued at Shurdington restricting the potential for development. This was compounded through the adopted Tewkesbury Local Plan, which again failed to advance growth that would have required Green Belt release but would have resulted in development that could meet the settlement’s housing needs. 6.2 A review of available housing monitoring information published by Tewkesbury Borough Council in the 2020/2021 Housing Monitoring Report confirms that between 2011 and 2021, 15 dwellings were completed at the settlement. In terms of other housing coming forward, the latest housing land supply monitoring information published in October 2023 identifies only one major development with consent, which comprises allocation SHU2 from the adopted Borough Local Plan, where 25 dwellings were approved in May 2023, confirming how plan-led growth is critical at the settlement. Otherwise, only 6 further sites are identified with permission totalling 9 dwellings. This confirms the challenge in bringing forward housing development at the settlement, despite its sustainability and local demands for both market and affordable housing, demonstrating that the emerging SLP should advance a positive approach to growth at Shurdington to address this. 6.3 As such, it is critical through the emerging SLP that a comprehensive review of the Green Belt is undertaken alongside a detailed assessment of sustainable locations for growth, such that sustainable settlements such as Shurdington benefit from plan-led growth. The Framework makes it clear that plan-making remains the only opportunity for reviewing the Green Belt, and whilst it is recognised that the latest revisions to the Framework in December 2023 removed the need for authorities to do so, Paragraph 145 continues to establish that authorities may choose to do so, where exceptional circumstances are fully evidenced and justified. It is considered that the strategic level of plan-making advanced by the SLP provides a positive opportunity to assess the designated Green Belt, and identify situations where there are opportunities to facilitate sustainable development by releasing small areas of low-performing Green Belt such as at Shurdington. 6.4 In respect of the spatial options identified, EPV strongly recommends that the authorities recognise that a single option in isolation is unlikely to result in a sustainable pattern of growth or deliver sufficient levels of growth to meet the Plan area needs. As a result, it is encouraged that the authorities consider how best to advance a spatial strategy that combines the options and pursues the most sustainable options for growth and development. The spatial options identified by the Plan currently fail to recognise the credentials of pursuing a dispersed model that focuses on the more sustainable rural locations, rather than considering all rural locations equally as per Option 5. This could also integrate locations well served by sustainable transport (as per Option 6), which should include consideration of locations such as Shurdington whilst also Claremont Planning on behalf of European Property Ventures (Gloucestershire) Ltd Representations to GCT SLP Regulation 18 Consultation March 2024 7 contributing to achieving wider objectives of the Plan that include addressing climate change and improving access to sustainable transport. 6.5 It is particularly important the that authorities recognise the risk of relying on new settlements, and ensure that a full range of sites are considered and allocated, including small to medium sites that can be delivered more swiftly. The provisions of Paragraph 69 of the Framework must be recognised, which require a mix of sites, including specific, deliverable sites for the first five years following adoption; as well as specific developable sites or broad locations for the remaining plan period. This is particularly pertinent in Gloucestershire, recognising the recent history of the proposed Garden Town at Tewkesbury, which was awarded Garden Town status in 2021, but remained at an early stage of planning with significant uncertainty regarding infrastructure delivery as of early 2024. Whilst Paragraph 74 of the Framework identifies that the supply of large numbers of new homes can often be best achieved by planning for a larger scale of development, the Framework also requires that proposals for this scale of growth are informed by a realistic assessment of likely delivery rates given the lead-in times associated with delivering this scale of development. As required by Paragraph 70 of the Framework, the contribution that small and medium sites, such as EPV’s site at Shurdington, can make towards meeting the housing requirement of an area must be recognised. The land under EPV’s control at Badgeworth Lane, represents a suitable site that is immediately available for development.","","","","[Q8.] In respect of Biodiversity Net Gain, the draft Plan queries whether policy should seek to go beyond the statutory minimum 10% biodiversity net gain required by the Environment Act. It is not considered that there Claremont Planning on behalf of European Property Ventures (Gloucestershire) Ltd Representations to GCT SLP Regulation 18 Consultation March 2024 4 is sufficient justification for such a policy requirement, recognising that the current statutory requirement represents a minimum provision, with developments already able to seek to exceed this where feasible. Delivering additional biodiversity net gain over this minimum level may not be feasible on all developments, or may only be deliverable at the cost of delivering other policy requirements or aspirations. Indeed, the statutory biodiversity requirement of 10% has been informed by impact assessments prepared by DEFRA which established that achieving this level of net gain is unlikely to significantly impact upon the viability of developments. The Planning Practice Guidance has also been recently updated to identify specifically that plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, unless justified. To justify such policy it confirms, it will need to be evidenced including local need for a higher percentage, opportunities for a higher percentage and impacts on viability for development. It also notes that consideration will be needed as to how a higher percentage would be implemented. EPV therefore considers that it is not necessary or justified for the Council to pursue a higher level of biodiversity net gain. If the Council intend to do so however, it is critical that this requirement is supported by robust assessment and justification with supporting evidence to confirm this would not compromise the viability and delivery of developments. This is necessary to ensure that the Plan is underpinned by proportionate evidence as required by Paragraph 35 of the Framework and consistency with the Planning Practice Guidance.\n\nThrough these representations the sustainability of Shurdington, and accordingly EPV’s land at Badgeworth Lane, as a location for development has sought to be established. The evidence base for the emerging Plan further confirms the sustainability of the settlement as a location for growth. The SLP Sustainable Transport Strategy Broad Site Assessment Report assessed the access to key services, including schools, employment, healthcare and retail within a 20 minute walk, bus and cycle of a range of locations across the Plan Area. Whilst it doesn’t assess Shurdington as a settlement specifically, the assessment maps various locations within the settlement and confirms that in each case accessibility in Shurdington was either High or Very High as illustrated in Figure 3-1, 3-2 and 3-3 of the report. Although there is no railway station nearby, this is a common factor in many of the settlements in the Plan area, with access to train stations generally limited. As advised by Paragraph 109 of the Framework, the distribution of growth proposed through the SLP should be informed by the imperative to concentrate growth at locations which are, or can be made, sustainable. The delivery of new growth at Shurdington would evidently achieve this aspiration through limiting the need to travel whilst also offering a genuine choice of sustainable transport modes. The village benefits from a range of services, including a primary school, village social centre, a number of pubs, shops and various local employers including car services, commercial (offices) and horticultural centres. Assessment of the village reflects the substantial range of services available in Shurdington which can meet most immediate needs of its residents. Furthermore, this substantial range of services is supported by robust public transport links that the village benefits from by way of a bus service departing from bus stops within 50m of the site, every 10 minutes towards Cheltenham and Gloucester. The location of Shurdington is conveniently close to both Cheltenham and Gloucester, the two primary settlements of the County and the wider sub-region. Cheltenham town centre is located approximately 4.4km to the north east of Shurdington, with Gloucester city centre located approximately 9km to the west. Bus journeys to Cheltenham take approximately 20minutes and 35minutes to Gloucester. This demonstrates a reasonable distance and commuting time by public transport to major employment opportunities of both Cheltenham and Gloucester. This reinforces the sustainability of Shurdington, as although a rural settlement, it is well placed for its residents to take advantage of opportunities further afield by other modes transport rather than the private car. The land under EPV’s control at Badgeworth Lane, as illustrated at Appendix 1, is considered to be indicative of the findings of the Sustainable Transport Strategy Site Assessment Report. EPV’s site is located adjacent to the existing settlement boundary of Shurdington such that existing services and facilities provided at the settlement, including the Shurdington Church of England Primary School, are located within a ten minutes’ walk of the site. Accordingly, it is considered that the EPV’s site at Badgeworth Lane represents both a logical, and critically, sustainable location for the delivery of new growth at the settlement. EPV’s site at Badgeworth Lane, extends to approximately 6ha in size and is currently laid to arable pasture. Enclosed on two sides by existing development, the site is well related to the existing settlement and bound by curtilages of existing dwellings to the south and east. To the north, the site’s boundary is marked by dense vegetation whilst to the west the site is partially open to fields with incoherent hedgerow and fields lines marking the boundary. Topographically, the site has a gentle gradient with no changes in levels of any note. A public right of way, Shurdington Footpath 7, crosses the site from the south east to the north west, providing a link from Lambert Avenue (via a driveway of 46 Lambert Avenue) towards Badgeworth, a village located to the north west of Shurdington. Low voltage power lines traverse the northern section of the site. The site falls entirely within Flood Zone 1 and is not affected by any areas of surface water flood risk. Furthermore, the site is unaffected by statutory designations, landscape, ecological or heritage related, aside from the Green Belt designation which currently washes over the entirety of the site. The Green Belt designation also includes other land around the settlement, which has constrained the potential for sustainable growth at the settlement through a failure to review this through both the adopted Joint Core Strategy and recent Tewkesbury Borough Local Plan. As such, housing needs arising in Shurdington have not been catered for through plan-making, failing to secure sufficient levels of housing delivery and in particular affordable housing, despite the relative sustainability of the settlement. It is therefore confirmed through these representations that the settlement of Shurdington is well placed to deliver sustainable growth through the emerging Strategic Local Plan, whilst specifically Land at Badgeworth Lane, controlled by EPV, represents a suitable, available and deliverable site to accommodate housing to assist in meeting the emerging needs of the Plan area and the settlement of Shurdington specifically."]
["Planning agent or developer","Alder King","","No","","","Gloucester Quays LLP offer general support to the Draft Vision for the Strategic and Local Plan as set out on Page 13 of the Issues and Options Consultation. Gloucester Quays LLP have a significant investment in Gloucester at the Outlet and are a significant employer in the city. They wish to see the continued economic growth and success of Gloucester, which the Outlet has been a key part and are supportive of continued investment into the city. In particular, Gloucester Quays LLP, note the Draft Vision confirms the vital role of city centres in the plan area, and the desire for them to be improved over the plan period. In this regard it is noted that the Gloucester Quays Outlet is located within the designated Gloucester City Centre and has developed and evolved to be an integral part of the city centre retail and leisure offer. ","","Gloucester Quays LLP offer general support to the Draft Strategic Objectives for the Strategic Local Plan set out on Pages 14 – 16 of the Issues and Options Consultation.\nSupport is specifically offered to the following strategic objectives:\n Ensuring that growth takes place in sustainable locations and minimises the need to travel.\n Ensuring a network of city and town centres that meet the needs of communities, including supporting cultural uses and events, and that are able to respond and evolve as the role and function of centres changes.\n Support the provision of a wide range of different uses appropriate to city and town centres, including new homes, to create activity at different times of the day and build an active city and town centre community.\n  To draw on the uniqueness of the different centres in planning for their future. \n\nRecognition of the different and unique roles played by existing town and city centres and their component parts is important to supporting and facilitating continued investment within them to allow them to continue to flourish and to continue to meet the needs of the population they serve. ","","","","","","","","","","","Support is offered to using the local annual housing need calculation from the standard method to accommodate future housing growth. However, this support is caveated on the basis that the Joint Councils use up-to-date housing information. The evidence currently available to the Councils appears to be that from 2020, that information is out-of-date and unreliable. Reliance on such data would not deliver robust housing growth figures and could undermine the progression of the plan. The plan should look to accommodate housing growth to meet local needs to ensure that sufficient housing, including affordable housing, is brought forward over the plan period. To fail to deliver sufficient housing growth will undermine the support for services and facilities in the area’s town and city centres.","","","","","","","","","","","The current plan appears to rely upon health checks of the various town and city centres undertaken in 2019. To rely upon health checks that are now 5 years old is likely to render any plan unsound. It is essential to undertake updates to the town centre health checks to ensure that the emerging strategies and policies reflect the current health of the designated centres recognising their strengths and weaknesses, particularly post Covid. \n\nThe emerging plan notes the need for policies to seek complementarity between the traditional shopping core in Gloucester and the Docks/Gloucester Quays within the city centre. The inclusion of an appropriate policy in this regard which refers to the complementary and mutually beneficial relationship of the different parts of the city centre, namely the traditional shopping core and Gloucester Quays/Docks is supported. Any such policies should be carefully drafted to allow this successful relationship to continue and should not be unduly restrictive such that they stifle growth and investment, noting the diverse role of different parts of city centres which contribute to the health of centres. In this regard it should be noted that the development at Gloucester Quays, including the factory outlet shopping and leisure development, has made a significant and important contribution to the city centre over the past 15 years. Any new policy should promote the different parts of the city centre, including Gloucester Quays, in looking to enhance the vitality and viability of the whole. \n\nThe development at Gloucester Quays has always sought to provide a complementary offer to the traditional shopping core, building on the previous success of Gloucester Docks. It is by design, a retail and leisure destination that has a significant catchment, far beyond that of the traditional shopping core. Evidence previously provided by Gloucester Quays LLP has demonstrated that trips to Gloucester Quays are often linked to the remainder of the city centre and that the appeal and success of Gloucester Quays has had a positive effect on the wider Gloucester City Centre in terms of expenditure and footfall directly contributing to the health of the centre, as a whole. ","","","","","","","","","","","","","\nAs stated in responding to other questions in the response form, Gloucester Quays LLP wish to highlight the importance and positive contribution that the Gloucester Quays Outlet makes to Gloucester City Centre, the city of Gloucester and wider sub-region.\n\nThe Outlet and its component parts provide an established an important retail and leisure destination within the city centre, which is complementary to the traditional offer of the city and\nwhich makes a significant contribution to the local economy including through the provision of significant and varied employment opportunities. The wide influence of the destination brings in expenditure from a broad geographic area offering wider benefits to the city-region as a whole. Emerging policy should support the continued growth and investment in this facility which remains an integral part of the retail and leisure offer of the city centre.\n \n"]
["Local Councillor","Prestbury Parish Council",15,"Secondary health care, i.e. hospitals","Cheltenham racecourse is in Prestbury parish.  Access for race traffic and local traffic.\n\nFlooding.\n","Yes","","Yes","Greater explanation is needed –  it is too nebulous.","Prioritise dealing with flooding and drainage.","","Maximise re-usage of existing buildings.","No","Yes","Add allotments sites to all new developments.","Schools.\nHealth care.\nCorner shops and Post Offices.","Yes","Maximise use of existing sites – eg Sainsbury’s car park at Oakley could be roofed over and solar panels added.","No","We understand the model used dates from 2014.  Much has changed since then – update?","","","Yes","More starter homes.\nMore accommodation for older people.\nNot so many 4/5-bedroom houses.","","","","Integration is the key – infrastructure.","","Food security.  Encourage much greater level of food produced from British farms rather than relying so heavily on imports.","Free car parking in all car parks for the first hour.\nLower business rates for all businesses permanently.\nFree business consultation services available to all.","Keep existing car parks.  Cheltenham Borough Council – don’t sell Idsall Drive car park in Prestbury to developers.","An integrated transport policy that includes public transport of all types and provides enough car parking space.\nFailure to provide enough car parking space clogs up roads and causes huge problems for the emergency services.","See above","See above","Yes","","","No","One size does not fit all.\nBits from all the development scenarios are required.\nFlexibility.","","","",""]
["Planning agent or developer","David Lock Associates","","HLM has not identified any significant additional topic areas that should be considered through\nthe SLP. ","","","The vision is broadly positive in focussing on the better future outcomes that are aspired to – albeit that the date for the vision may need to extend to say 2046 (which in itself would allow further ambition to be embraced in the SLP). HLM in particular welcomes the ambition to foster inward investment, innovation and growth in key sectors.\n\nHLM regrets that the ambition in relation to the provision of new homes is more limited. The place making principles are laudable yet there is something limiting in the ambition only that “peoples housing needs will have been met”. The provision of new homes in high quality places is intrinsically linked to the wider aspirations and ambitions of the Plan. New homes built during the life of the SLP will be, the most sustainable within the plan area by far, and will have a great\ncontribution to make in delivering the transition to a low carbon future. Likewise a broad range of new homes is integral to delivering the economic aspirations of the vision. \n\nHallam’s view is that “meeting needs” conveys little vision, or aspiration, contrasting with the wider ambition expressed in relation to other strategic topics and, underestimating and undermining the role of new homes in achieving such ambition(s).\n\nIn Hallam’s view the vision in respect of the making provision for new homes needs to be positive and express the ambition to embrace all sustainable development opportunities that are presented within the plan period. Unless the Plan provides the framework for such opportunities to be realised then the Plan runs the significant risk of failing to be positively prepared (in accordance with the NPPF), and would have substantive negative impacts on the prospects of\nsuccessfully delivering the Plan vision.\n\nHallam notes the expressed focus of “making best possible use of brownfield site and large-scale comprehensively planned development”. The I&O consultation offers six scenarios or options to inform preparation of the Plan’s development strategy. In para 6.8, the Authorities’ note that the ultimate strategy will depend on a broadly based combination of options. In Hallam’s view, and indeed as expressed in the consultation, brownfield opportunities can only play a part in the development strategy for the Plan area. It is not only necessary but also desirable that large scale\ncomprehensively planned development (including in sustainable greenfield locations) forms a key part of the strategy. Such development is likely to include a range of sites (and site scales) and opportunities.\n\nWhile the protection of farmland and valuable green spaces is offered as the justification for the focus on brownfield sites, this is not evidenced and takes no account of the substantial “cons” in para 6.16 in relation to Scenario 1 (Urban concentration). Manifestly those “cons” – not delivering sufficient jobs, provision of only a limited range of housing types, loss of commercial space, harm to urban character and most critically of all, limited opportunity to deliver climate\nchange measures, and new infrastructure (indeed the opposite - the placing of additional pressure on existing infrastructure), are in direct contradiction to the wider ambition of the Vision.\n\nWhile brownfield sites in urban areas will have a role, they cannot be placed at the centre of the vision if its wider and better objectives are to be realised. In any event, and having regard to the evidence base for the Plan (including the HELAA) it is very unlikely that there would be sufficient brownfield land available to support any strategy based on significant brownfield development.\n\nThe authorities should look at sustainable greenfield locations to meet as much of the need as possible, and Bishops Cleeve is an obvious location for growth given its capacity to accommodate new development, the suitability of sites located beyond the green belt at Bishops Cleeve and in particular its ability to address the needs of Tewkesbury District.\n\nWhilst in due course there may be the opportunity to embrace a more meaningful and effective spatial strategy within the vision, this is not the case yet. ","","Hallam supports many of the strategic objectives set out in the SLP.\n\nIn particular, under ‘Meeting the challenges of climate change’, the references to “Ensuring growth takes place in sustainable locations“– needs to be fully reflected in the development scenarios– discussed later.\n\nEqually it is a critically important semantic point that the objectives should provide clarity that development opportunities that come forward in sustainable locations, and are sustainable in nature and/or supportive of the wider vision, should be realised.\n\nIt should not be the case that such opportunities should be resisted simply because a sufficiency of provision is deemed to have been provided. This would be inconsistent with the NPPF.\n\nWhilst the opportunities presented by use of brownfield land are noted – the role of well-located greenfield sites in sustainable locations must be fully recognised in order to meet housing and wider growth needs and to deliver wider ambitions of the SLP. For the reasons set out in relation to the vision under consultation question 4, an overreliance on brownfield development will mean that the wider ambitions of the plan will not be met. \n\nUnder the heading of “delivering a wide choice of homes that meet the needs of our communities” the objectives should be less limiting and should actively encourage the wider vision. Hence bullet 1 should be expanded as follows: “Delivering sufficient new homes in the right places to meet the needs of our communities…., and to support the economic ambitions of\nthe Plan, the retention and enhancement of local infrastructure and the transition to a low carbon future”. The provision of new homes is not simply a matter of just trying to provide the minimum number of homes to meet need. ","Hallam believes that the most effective means for the SLP to address climate change – avoiding impacts and mitigating where necessary – is through a positive and ambitious planning approach.\n\nAs noted above, new homes built during the life of the SLR will be the most sustainable within the plan area by far, and will make a substantial contribution to delivering the transition to a low\ncarbon future. Likewise a broad range of new homes is integral to delivering the economic aspirations of the vision.\n\nThe SLP can effectively address climate change by embracing and capturing all sustainable development opportunities that are presented within the plan period. The most effective\napproach will embrace a wide range of options and opportunities (as begins to be set out in para 6.8 of the Consultation document). Inevitably this will include a focus of development at key\nsettlements that are accessible and can benefit from, and encourage, active travel, including walking, cycling and public transport infrastructure.\n\nSuch an approach is important not only in addressing issues of housing supply and choice and affordability, but also in improving choices of travel by sustainable modes and contributing\ntowards more sustainable commuting behaviours.\n\nEqually such an approach can consider positively the extent to which new opportunities can contribute to delivering new and enhanced green infrastructure and BNG. ","The SLP should be aligned with Building Regulations and Future Homes and Buildings Standards. The pace of change in national standards is rapid and substantial and is robustly evidenced (including in relation to the practicality and viability of delivering such standards). Local standards are unlikely to be as reliably or robustly evidenced. ","The SLP should be aligned with Building Regulations and Future Homes and Buildings Standards. The pace of change in national standards is rapid and substantial and is robustly evidenced (including in relation to the practicality and viability of delivering such standards). Local standards are unlikely to be as reliably or robustly evidenced. ","","Yes","Hallam is promoting Land north of Stoke Road, Bishops Cleeve (BIS012).\n\nIt is one example of a well located site capable of delivering a highly sustainable development.\n\nIn addition, the site offers extensive opportunities to  integrate green infrastructure within the proposals, restoring and enhancing existing watercourse corridors (the Glebe Brook). In developing such proposals to date, a key aim has been to facilitate an enhanced green infrastructure network which would improve habitat connectivity, enhance the landscape value of the site over its baseline value, and provide for active travel links not only for recreational enjoyment, but importantly to enable residents of the development to access facilities and vice versa.\n\nHallam have tested an ecological corridor improvement scheme which was holistically designed to offer biodiversity net gain and landscape improvements.\n\nIf the SLP fails to embrace as part of its vision objectives and spatial strategy such opportunities, then it will not be able to achieve the green infrastructure and environmental aspirations that it sets itself and which are the minimum expectation of national policy and guidance. ","Hallam considers that new development should be well connected by active travel infrastructure, to local services and facilities, that are able to meet the day to day needs of local communities – in effect aligning with the principles for creating 20-minute neighbourhoods, followed by opportunities for improved connectivity to locations by enhanced or new public transport connections. Optimally, local employment opportunities have the potential to benefit new developments, certainly if they are also well connected, even more so if they are well matched to the local and future residential offer. By way of example, Land at Stoke Road, Bishops Cleeve, is well connected to existing local services and facilities in Bishops Cleeve and integrates a local centre, primary school, employment and residential development within the proposals. Bishops Cleeve, as a whole, represents a valuable opportunity to focus growth, given that this settlement benefits from a wide range of local facilities and employment offer.","","","","Hallam considers that the annual housing need calculation, as derived from the Standard Method\nshould be used as the minimum requirement, albeit only as a starting point.\n\nThe NPPF invites LPAs to consider exceptional circumstances that may be present to justify an alternative approach to calculating housing need; that alternative approach to reflect the current and future demographic trends and market signals.\n\nHallam considers a key exceptional circumstance that justifies a reassessment of the housing requirement is the need for economic growth to be matched by sufficient levels of housing to avoid and even seek to reverse unsustainable levels of commuting into Cheltenham and Gloucester – major employment centres.\n\nHallam notes from GFirst LEP’s Strategic Economic Plan that although Gloucestershire has improved its economic performance over recent years, relatively high house prices and rents could well be linked to the failure to attract and retain talented young people. One of the key threats is the lack of development opportunities that may arise if housing supply, as dictated by the Standard Method, rather than economic ambition, is relied upon. \n\nHallam, notes that the evidence base – other than in respect of the Standard methodology – is dated. As the SLP progresses it will be imperative for the authorities to consider establishing a requirement above the minimum of the Standard Method to align with economic growth ambitions and minimise the risks of increased commuting. \n\nA failure to establish an appropriate requirement also runs the significant risk of planning for only “business as usual” and incremental change. Para 5.20 of the I&O already notes that a large number of the required homes are already planned in or accounted for. If so, the SLP is likely to be ineffective in delivering the change and ambition it seeks – including in relation to low carbon futures. Failing to positively plan for the homes of the future undermines the Plan fundamentally. ","","See above [Q12].\n\nIn addition, too often LPAs, in making strategic growth decisions have placed too much weight on strategic growth locations in the form of new settlements and urban extensions, often in absence of more modest, yet significant ad sustainable, sites. With such an unbalanced portfolio, LPAs have become exposed to inadequate housing supply which in turn has led to speculative proposals undermining the originally intended strategies to deliver planned housing and linked infrastructure investment.\n\nIn Hallam’s view, the plan needs to ensure that sufficient resilience and contingency is built into the plan, to include a balanced portfolio of sites, that accords with a preferred and achievable spatial strategy and supported by an effective implementation and monitoring framework that allow important decisions on their phasing and release.\n\nHallam is also mindful that the SLP includes areas of Green Belt. This does not and should not impose a constraint on the overall ambition of the plan or on the level of housing that should be planned for. For all the reasons set out above, the housing policies of the SLP should be driven by the economic and wider ambitions of the Plan. ","","","","","","","A broader variety of locations supported as appropriate locations for new homes is also likely to support a wider range of employment requirements from the large scale, high value and knowledge intensive to more local and growing new businesses.\n\nHallam is promoting Land of Stoke Road Bishops Cleeve (BIS012).\n\nIt is one example of a well located site capable of delivering a highly sustainable development including employment development.\n\nIf the SLP fails to embrace such opportunities, as part of its vision objectives and spatial strategy, then it will not be able to achieve the economic, place making and sustainability objectives of the Plan. ","","Recognising, through the SLP, the role of Key Rural Service Centres such as Bishops Cleeve, and, will reinforce the vitality and viability, as well as further reinforce the sustainability, of such location","Recognising, through the SLP, the role of Key Rural Service Centres such as Bishops Cleeve, and, will reinforce the vitality and viability, as well as further reinforce the sustainability, of such locations.\n\nIn addition facilitating high quality development in such locations, outside the main towns, has the ability to deliver infrastructure such as active travel routes and community facilities and can assist in the long term viability of local services. ","Hallam understands the question being asked but would seek to respond by turning that around to ask what sort of new development would be most critical to achieve the delivery of associated infrastructure.\n\nThis will not be through the provision of more brownfield opportunities but development in sustainable locations on greenfield sites that are of a sufficient scale to support or accommodate infrastructure provision.\n\nHallam Land, the strategic development arm of Henry Boot group, delivers not only high quality places but physical, community, social and environmental infrastructure alongside new homes. By accommodating such a delivery model, the SLP will maximise the potential to deliver\ninfrastructure alongside development. ","Hallam is aware that the proposed new settlement at Ashchurch has been awarded Garden Town status and is one example of a strategic scale new settlement.\n\nIn Hallam’s view key infrastructure is likely to include:\n• Investment in widening travel choice between Ashchurch, Tewksbury and towards Cheltenham, with existing road / new highway corridors and improvements to Ashchurch\nfor Tewksbury railway station. \n• Improvements to the A46 corridor and Junction 9 of the M5.\n\nA key consideration is how the settlement can be planned and delivered to ensure that wider strategic improvements to the A46 is not prejudiced by planned development.\nThe A46 forms part of the Strategic Road Network. The scope for potential improvements has been considered in the Midlands Connect Study, which identifies Ashchurch as a barrier to growth due to its constrained capacity and issues experienced at J9 of the M5 arising from existing capacity constraints. The recommended approach is for National Highways to work with GCC in relation to the following:\n- Dual carriageway link to the M5 Junction 9\n- Upgrading of the M5 J9\n\nNo details have emerged yet of a preferred route or of the scope and nature of potential upgrade to J9 of the M5. Proposed impacts of a new settlement on the strategic function and capacity of the A46 and M5 J9 will need to be carefully considered. The preferred route and design of the\nA46, including junction locations and design will also have an impact.\n\nThe timings of the development of proposal, including the improvements National Highways Route Investment Strategy and securing funding and delivery will be vulnerable to delays. The Midlands Connect A46 Corridor Study suggested that delivery on a £250m scheme in 2024/25. However, it is clear that in absence of any agreed proposals, that uncertainty remains on timings, which will have implication on progress with the allocation of a deliverable sustainable settlement and indeed other major new settlement options and will introduce a need for flexibility in the SLP.\n\nIn conclusion, the role and delivery timetable of Ashchurch needs to be managed so that the delivery of this key infrastructure is alongside new development.\n\nIn the short term, development at Bishops Cleeve has the potential to deliver quickly. There is potential to create new sustainable travel routes along the A435 between Cheltenham, Bishops Cleeve and Ashchurch. This would have a real opportunity to tie some of the most sustainable locations and new development areas in the centre of the plan area together, coherently.","Hallam, considers that the suitability of settlements will depend on the range of services and facilities offered. Bishops Cleeve is an exemplar of a sustainable village where there is less dependence on travel by private vehicle to meet daily needs - including a range of employment opportunities, education across all tiers, a food superstore, medical centres, and various sports facilities.\n\nAdditionally good transport connectivity is important, where there is a choice of modes of active travel and public transport. Again, Bishops Cleeve is an example of a settlement from good choice of modes and which is soon to benefit from further enhancements including the A435 Cheltenham to Bishop’s Cleeve Cycleway.","","","Hallam considers that none of the scenarios presented in the I&O consultation form an adequate basis for progressing the SLP.\n\nIt is inevitable, and accepted in para 6.8, that the final strategy will need to include combinations of the various scenarios. In this sense there will be many combinations and derived strategies.\nThese will need robust testing through the Sustainability Appraisal, as such derived combined strategies are developed and consulted upon.\n\nHowever, Hallam does note one apparent important omission from the scenarios offered for consultation. Scenarios 1,2 & 3 are each described, in various terms, as urban options. Each –\nwith or without green belt options - relate to the three principal settlements only – Tewkesbury, Cheltenham and Gloucester. Likewise Scenario 4 includes only three possible locations for\nstrategic development.\n\nScenario 5 – rural dispersal - jumps to the other extreme with some 40 locations for growth.\n\nGlaringly absent from the scenarios is any focus on ‘Sustainable settlements’ to capture those settlements with good range of employment, services and facilities and the potential to accommodate growth. \n\nThe authorities should look at sustainable locations to meet a substantial proportion of the housing needs and to deliver sustainable development in their own right.\n\nIn this regard Bishops Cleeve is an obvious location for growth given its capacity to accommodate new development (including the highly sustainable BIS12), proximity to urban centre of\nCheltenham and sustainable transport options.\n\nOutside of the 3 main settlements, Bishops Cleeve is the most (or one of the most) sustainable settlements and should accommodate an amount of development in order to reflect this and to further reinforce its sustainable credentials and qualities. ","","Scenario 1 – Urban concentration\nWhile brownfield sites in urban areas will have a role, they cannot be placed at the centre of the SLP if its wider and better objectives are to be realised (and not simply because there is inadequate capacity on brownfield sites).\n\nWhile the protection of farmland and valuable green spaces and green belt is offered as one “pro” for this focus, this is not evidenced. There is no evidence, only conjecture, that development taking place on green field locations cannot be accommodated in a number of cases without recourse to green belt land, higher quality agricultural land or land of any particular landscape sensitivity. Just by way of example there is substantial capacity adjacent to Bishops Cleeve (e.g. BIS12).\n\nHallam agrees with the “cons” set out in para 6.16. They are very substantial indeed and would undermine fundamentally the SLP. Manifestly those “cons” – not delivering sufficient jobs, provision of only a limited range of housing, loss of commercial space, harm to urban character and most critically of all, limited opportunity to deliver climate change measures, and new infrastructure (indeed the opposite - the placing of additional pressure on existing infrastructure) are in direct contradiction to the wider ambition of the Vision. \n\nScenario 2 and 3 – Urban extensions and Urban extensions avoiding the Green Belt\nThe urban extensions options embedded within Scenarios 2 and 3 will have a role to play in the SLP. They feature strongly within the JCS and to this extent are likely to require continuity of approach.\n\nThe advantages mooted in para 6.20 are broadly accepted with an important caveat. Whilst in simple capacity terms such sites might enable the authorities estimate of housing needs to be met, they may not support a more appropriate level of provision.\n\nOf more significance, the scenario presumes implicitly that such locations on the scale envisaged are the only such locations capable of delivering sustainable development. Manifestly wrong, the scenarios ignore by default other locations that are well served by local employment, services and\nfacilities and are inherently sustainable.\n\nEmbracing ‘Sustainable Settlements’ with good range of employment, services and facilities and the potential to accommodate growth is a necessity if real beneficial sustainable opportunities are to be realised. It is also a necessity to ensure a balanced portfolio of options that will ensure a realistic and robust delivery strategy.\n\nThe failure of Tewkesbury Borough Council, for instance, to demonstrate on any consistent basis a a five year supply of housing land in recent years only underlines the necessity of a more broadly based scenario than mooted in Scenarios 2 or 3. \n\nScenario 4 – New Strategic Settlement\nHallam considers new strategic settlements are a much longer term prospect. Limited progress has been made in respect of each of the options and notwithstanding the ‘Tewksbury Garden Town’ status, each presently is a long way from commencement. So too the necessary infrastructure to support such development. \n\nScenario 5 – Rural Dispersal\nWhilst some smaller rural settlements provide limited opportunities in the form of infill sites, any strategic level of growth should be focussed in the most sustainable settlements (for the avoidance of doubt to include the higher tier settlements such as Bishops Cleeve). \n\nScenario 6 – Sustainable Transport Scenario\nLocating sites in locations that maximise travel choice is supported by Hallam as a matter of principle.\n\nScenario 6 on the other hand appears hugely ambitious in seeking to concentrate all new uncommitted development in the identified Sustainable Transport Corridor. The consequence is the expressed concern that the scenario would “result in the loss of designated Green belt between Cheltenham, Gloucester and Bishops Cleeve, greenfield sites and potentially higher quality agricultural land”.\n\nElements of the scenario however would not require the loss of high quality land, green belt or sensitive green field sites. As above these include capacity options at Bishops Cleeve.\n\nThere are benefits too in enhancing the connectivity of existing settlements such as Bishops Cleeve.\n\nHallam also notes that Bishop’s Cleeve is to benefit from improved connectivity with the delivery of the A435 Cheltenham to Bishiop’s Cleeve Cycleway, which will for part of the Gloucestershire ‘Cycle Spine’. On completion of the sections linking Bishops Cleeve to Cheltenham. ","","","","[Q1] - Paragraph 2.10 of the SLP Issues and Options Consultation notes that, on the basis of a Reg 19 Submission in April 2026, then the SLP should plan for the period until at least 2041 – to enable strategic policies to look ahead at least 15 years in accordance with national guidance. \n\nIn so doing, limited flexibility is built into the plan period given the necessary examination and adoption processes.\n\nHallam Land Management (HLM) would endorse a longer plan period – potentially to 2046 – for a number of reasons including:\n• to give more scope to make longer term decisions regarding growth in the SLP area;\n• to provide a long term and stable basis for supporting and achieving the Plan’s objectives in relation to promoting green employment growth, inward investment and the delivery of infrastructure;\n• to provide a degree of realism relating to the timescales required to deliver key strategic options such as the Ashchurch Garden Town; and\n• to envision and embrace, ambitiously, the progressive transition to a low carbon future.\n\nNotwithstanding the plan period that is adopted by the Authorities, it will be imperative for the plan to be reviewed AND updated on a five year cycle to ensure that it is responsive to events and new opportunities.\n\n[Q8] - The SLP should align with national guidance in relation to BNG and adopt a 10% as the target and not as a minimum. National guidance is clear that authorities “should not seek a higher percentage than the statutory objective of ten per cent biodiversity net gain”. Thers is no justification, evidenced of otherwise, why such guidance should be disregarded in the Plan Area. , either on an area-wide basis or for specific allocations for development unless justified”. Equally, in so doing there is a parallel obligation on the SLP to facilitate development options that are best suited to, or capable of, delivering high levels of BNG and indeed GI.\n\n[Sir\n\nThank you for inviting responses to the CG and T Strategic and Local Plan Issues and Options – Spatial Options and Key Policy Areas  \n\nI am delighted to attach the response of Hallam Land Management Limited (care of David Lock Associates), in respect of the matters and questions set out for consultation. \n\nPlease do not hesitate to contact me if you have any queries regarding the representations made. \n\nFor clarity I will also be submitting additional information, on behalf of Hallam Land Management, in relation to the SLR consultation as follows: \na)\tObservations on the HELAA methodology\nb)\tAdditional information in relation to HELAA site BIS012\nc)\tAn additional site submission in respect of land at Bishops Cleeve.  \n\nThese will follow shortly. \n\nShould you wish to do so Hallam Land would be delighted to discuss their representations with you.  \n\nI look forward to following progress with the SLP.]\n\n[Q.29] As noted above [Q28], Hallam considers that none of the scenarios presented in the I&O consultation form an adequate basis for progressing the SLP.\n\nIt is inevitable, and accepted in para 6.8, that the final strategy will need to include combinations of the various scenarios. In this sense there will be many combinations and derived strategies. These will need robust testing through the Sustainability Appraisal as such derived combined strategies are developed and consulted upon. Any such combination at this stage cannot be prejudged and should not be so. Indeed the selection of a scenario, or even a combination of scenarios, carries great dogmatic risk that would exclude other highly sustainable and desirable options\n\nThe authorities should look at sustainable locations to meet a substantial proportion of the housing needs and to deliver sustainable development in their own right.\n\nIn this regard Bishops Cleeve is an obvious location for growth given its capacity to accommodate new development(including the highly sustainable BIS12),, the suitability of sites located beyond the green belt at Bishops Cleeve and in particular its ability to address the needs of Tewkesbury District. "]
["","Hayfield Homes","","The NPPF requirement for ‘Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for:\n\na)\thousing (including affordable housing), employment, retail, leisure and other commercial   development;\nb)\tinfrastructure for transport, telecommunications, security, waste management, water  supply, wastewater, flood risk and coastal change management, and the provision of  minerals and energy (including heat);\nc)\tcommunity facilities (such as health, education and cultural infrastructure; and\nd)\tconservation and enhancement of the natural, built and historic environment, including  landscapes and green infrastructure, and planning measures to address climate change and  adaptation.’\nHayfield agree that the SLP should oversee these items as a minimum.  ","Hayfield are not aware of any locally specific issues that would need be addressed in only one council area.  There is an obvious need for housing within the three-authority areas which needs to be delivered and met within their respective areas and monitored accordingly.  ","","The Plan will need to deliver a range of housing sites providing a range of housing types, sizes and tenures. Hayfield considers that it is appropriate for the Council to identify housing, and the maintenance of the five-year supply (as a minimum) should form a key objective for the Plan. ","","Hayfield agree that it will be important for the Plan to deliver a wide choice of homes that meet the needs of our communities.  Hayfield support the need for the Plan to delivering new homes in the right places to meet the needs of the communities, including market and affordable. Hayfield also support the aim to deliver housing of the right size, type and tenure to create mixed and balanced communities, in sustainable locations (such as Twyning) that have access to shops, services and facilities.  ","","Hayfield would recommend against policies that seek to go beyond national policy changes. There is simply no need for Local Plans to include policies on matters that are adequately addressed through Building Regulations, other consenting regimes and other regulations.  Doing this creates confusion, duplication, misunderstandings, misalignments and sometime full out policy conflicts. \n\nThe Written Ministerial Statement in December 2023 was clear that this isn’t something Local Authorities should do without robust evidence and explanation.","Hayfield would recommend against policies that seek to go beyond national policy changes. There is simply no need for Local Plans to include policies on matters that are adequately addressed through Building Regulations, other consenting regimes and other regulations.  Doing this creates confusion, duplication, misunderstandings, misalignments and sometime full out policy conflicts. \n\nThe Written Ministerial Statement in December 2023 was clear that this isn’t something Local Authorities should do without robust evidence and explanation.","No","","","Hayfield suggest that the spatial strategy should recognise that there may be clusters of villages that provide differing services that are within reasonable travelling distance of each other, and thus villages may need to be grouped together. \n\nHowever, growth in the first instance should be aimed toward villages and towns that have suitable facilities to accommodate new development","","","Yes","Standard method should be used unless exceptional circumstances justify an alternative approach.   There are no exceptional circumstances which would warrant a different approach than the standard method being used as the starting point for considering the housing requirements for the Cheltenham, Gloucester and Tewkesbury SLP. \n\nParagraph 61 of the newly revised (Dec 2023) NPPF says that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance. The outcome of the standard method is an advisory starting-point for establishing a housing requirement for the area”.  Paragraph 67 states that “The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment.”","No","Hayfield suggest there are no reasons for the housing requirement to be constrained and in fact could be higher.","","Hayfield are supportive of the need for new homes.  The Plan should provide for a wide range of deliverable and developable sites across in order to provide competition and choice and a buffer to ensure that housing needs are met in full.  The Plan will also need to deliver a range of housing sites providing a range of housing types, sizes and tenures.  ","","","","The Council should consider the interaction between employment and housing.  An increase in the number of jobs can generate a requirement for additional housing.  It may be that a higher housing figure is needed for economic reasons and a higher housing number is also needed for housing delivery reasons.  ","Again, note the interaction between employment and housing.","","","The allocation of new housing sites within rural areas helps maintain support for the local facilities, shops and services that may otherwise struggle. Therefore, housing in rural areas is encouraged. ","Development can only be required to mitigate its own impacts and cannot be required to address existing issues and shortfalls.  It would be unreasonable and fail the CIL tests to request developers to pay to address existing deficiencies.  It is not appropriate for any methodology of site selection to increase the likelihood of a site being allocated on the basis of how it could address existing infrastructure problems, or over deliver against policy requirements.","New settlements and large urban extensions can have long lead times.  Reliance on one (or more) new settlements and/or urban extensions can often mean delivery from these sources will occur later on in the Plan period. This increases the importance of the need for a range of other sites to be provided to ensure a Five-Year Land Supply and early delivery of much needed housing. It will be important for policies and allocation in the Plan to provide for a range of housing sites, and as such the site selection methodology needs to reflect this.\n\nTherefore, growth of existing, sustainable settlements (Twyning for example) should also be encouraged through the Local Plan.","New development in settlements that currently do not have particular service can creates circumstances where new developments supports the provision of new services and facilities in those locations, helping them to become more sustainable. The Local Plan will also need to recognise that settlements that currently do not have services could expand to include those services if new development is allocated in those areas. \n\nThere is a danger that any such criteria could being used negatively to become a way of preventing development in certain communities rather than promoting improved villages and neighbourhoods. The site selection methodology should reflect this position.","","No","The consultation considers six distinct scenarios to consider the understand their ‘pros’ and ‘cons of each of them.  As para 6.8 of the consultation notes, none of these scenarios would, on their own, deliver sustainable development and the final strategy will be a combination of different elements. The six different development scenarios tested were:\n\n•\tUrban concentration\n•\tUrban extensions\n•\tUrban extensions, avoiding the Green Belt\n•\tNew strategic settlements\n•\tRural dispersal\n•\tSustainable transport\nHayfield suggest that the above approach is suitable.","","Hayfield would suggest that each scenario should also be tested to see the implication sit would have on the availability of small sites.  ","","Yes","Twyning has a range of facilities suitable to accommodate future growth.","[Q1] The NPPF states that strategic policies should look ahead over a minimum 15-year period from adoption and that where larger scale developments form part of the strategy, policies should be set within a vision that looks further ahead (at least 30 years), to take in account the likely timescale for delivery. \n\nHayfield requests that the Council ensures that the Plan period will cover at least the 15-year post adoption of the Plan as required.  \n\n[Q8] The Local Plan should reflect the change in PPG, which now states: \n\n‘Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified’.\n\n[Q29] The housing requirement in the SLP should be increased from the standard method baseline for a variety of reasons including addressing the current housing crisis, meeting housing need and providing affordable housing. A higher housing requirement may also be particularly important if development is to be of the scale necessary to support significant infrastructure projects in a way that is viable and deliverable.  \n\nThis means that it is likely that elements of all of the scenarios may be needed. Hayfield suggests development within existing settlements, urban extensions and new settlements may all be needed to meet the housing requirements in full."]
["Planning agent or developer","Hayfield Homes",null,"The NPPF requires strategic policies to set out the overall strategy for the pattern, scale and design quality of places to make a sufficient provision for relevant policy topics. The NPPF requirement should be seen as a minimum as the Strategic Local Plan offers the opportunity to address any cross-boundary issues that exist. The Strategic Local Plan covers an area that has a number of constraints to contend with, including Green Belt and the Cotswold Area of Outstanding Natural Beauty (AONB). To ensure \nthat the Strategic Local Plan is most effective and can deliver the level of development required for the area, a Green Belt Review should be considered.","Tewkesbury, Cheltenham and Gloucester areas all have a number of constraints respectively. However, Cheltenham and Gloucester are particularly constrained in relation to available land suitable for development as the boundaries are restricted. Therefore, the Strategic Plan is supported due to a need for the three Authorities to cooperate in order to meet the relevant demand for housing and employment. However, given this, there will be a lot of expectation on Tewkesbury to meet the majority of housing land due to the land restrictions in Cheltenham and Gloucester. Available and suitable sites surrounding Cheltenham or Gloucester within Tewkesbury Borough, such as Land at Mill Lane, should be viewed positively as they can help to meet needs arsing directly from the urban areas.","","Hayfield consider that it is important for the housing need to be met in full and that this should be set as a clear objective in the vision and the Local Plan in general. It is agreed that housing should be provided in the most sustainable locations, and this should weigh heavily in favour for new developments, particularly on the edge of the major settlements, such as Land at Mill Lane, Prestbury. The site offers an opportunity to provide new high-quality market housing set in a beautiful and safe place, in a sustainable and accessible location. ","","Hayfield agree that the Strategic Objectives cover a number of important issues. Hayfield seek to provide EPC A rated homes across all our developments and are committed to being net-zero carbon by 2030. Therefore, we support the commitments to sustainability and energy betterment within the objectives. Hayfield equally support the objective of delivering housing of the right size, type and tenure to create mixed and balanced communities. These should be in sustainable locations and with good access to shops, services and facilities. To ensure the strategic visions are achievable, they need to be considered in a wholistic way to ensure development remains viable. Sustainability measures can often come with higher upfront costs, so this will need to be considered in any viability testing. Hayfield considers that it is appropriate for the Council to explicitly identify meeting housing needs in full. Considering the Council’s difficulty around housing delivering over recent years, there should also be a commitment to maintaining a five year housing land supply over the plan period.","Hayfield consider it is important to tackle Climate Change, but planning policies should not seek to recreate measures which are already captured through Building Regulations and other regulations. Anything beyond this is considered onerous and could negatively impact housing delivery.","As above, the Local Plan should not seek to recreate measures covered by Building Regulations and other similar regulations. Paragraph 16 of the NPPF requires plans to contain policies which are clear and unambiguous which serve a clear purpose and do not unnecessarily duplicate policies. It is considered that this equally applies to measures already addressed within Building Regulations, such as obligations to provide EV charging points, water betterment and energy betterments. Anything above and beyond this could cause uncertainty and policy conflicts, particularly as Building Regulations are updated more frequently than Local Plan policies.","","No","","","It is important that the Local Plan advocates for sustainable development close to existing services, ideally on the edge of well-established settlements. Land at Mill Lane, Prestbury is on the edge of Cheltenham and is close to a number of existing services associated with Prestbury and wider Cheltenham. The site is available for development in a sustainable location and should be considered for allocation. It is also important for the Local Plan to recognise that housing development can also improve services within areas, as they attract additional people for custom but also generally come with financial contributions to local services through S106 obligations, such as contributions to local schools and public transport links. Allocating housing sites in rural areas can also provide opportunities for small sites which are particularly helpful for SME builders.","","","No","Paragraph 61 of the updated (Dec 2023) NPPF says: “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance. The outcome of the standard method is an advisory starting-point for establishing a housing requirement for the area”. Paragraph 67 states that: “The requirement may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment.” As the Councils are preparing a joint Local Plan to cover a Strategic area, Hayfield absolutely consider that the Standard Method should be used as a minimum starting point to guide housing numbers. Considering the large housing need that will arise from the combined area, Hayfield consider that the Plan should go further than the standard method and positively plan for much needed housing growth. A higher housing requirement will provide flexibility for housing delivery and ensure that a higher level of open-market and affordable dwellings are provided within the districts.","No","Parts of the Strategic area are covered by Green Belt and the Cotswolds Area of Outstanding Natural Beauty (AONB). Whilst these are constraints to be considered in the Local Plan, there are equally large areas of the Districts which are not covered by these constraints. Hayfield therefore consider that they are not reasons for housing numbers to be reduced or restricted. Indeed, due to this, the Councils should be considering reasonable alternatives for housing growth in sustainable areas to account for these constraints elsewhere. For example, Land at Mill Lane, Prestbury is outside of the AONB and the Green Belt and would be suitable for residential development. It should be considered for allocation as it is suitable, available, and deliverable for residential development.","","","","","","The Councils should consider the interaction between employment and housing. An increase in the number of jobs can generate a requirement for additional housing. The two requirements need to sufficiently support each other to ensure that homes are provided where job opportunities exist and vice versa.","","","","","","","","","No","Hayfield does not consider that there are further specific scenarios which should be considered but would note that the Council should consider a combination of all elements as the final strategy. This will ensure that all reasonable opportunities are explored and will ensure that the proposed strategy is suitable for the entire plan area.","","Hayfield consider that the pros and cons represent a high-level assessment of each scenario, but that these will need to be robustly tested to ensure that the chosen scenario(s) address all needs arising within the area. Hayfield are particularly concerned with the housing requirement within the Strategic area and the chose scenario(s) should ensure that the housing requirement is met in full. Any scenario which does not achieve this should not progress.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","Land at Mill Lane is located in Prestbury, on the edge of Cheltenham. It falls within the Tewkesbury Borough Authoritative area. Hayfield have an option on the site and are actively promoting it for residential development. The site boundary is attached at Appendix 1. The site was assessed as part of the Housing Land Availability Assessment (HELAA) (2023) as site reference SOU001 Land at Gravel Pit Lane. It was assessed as Potentially Developable but it is noted that it sits within an area of Special Landscape Area (SLA). The SLA policy will be subject to review as part of the Local Plan process. This will be supported by a Landscape Character Assessment and Sensitivity Study. The previous assessment was carried out in 2013, so this will require updating, as many of the designated SLA parcels within the district have changed over time. The timeframe for the production of this is unknown. However, Hayfield consider that it is important that this policy is reviewed and updated to ensure it serves its best purpose. The site is suitable, available and deliverable within the proposed Plan period. It is capable of delivering a number of benefits, including suitable landscape mitigation. Hayfield agree with the overall conclusion of the HELAA, but consider that the site should be upgraded to Developable. Hayfield are a HBF 5* housebuilder with a track record of delivering high-quality, sustainable homes and creating beautiful places. If Land at Mill Lane is allocated for housing, it would be capable of being brought forward quickly and to the highest quality to help meet the housing needs of the district. [Q1] The Strategic Local Plan (SLP) covers the period up to 2041. The National Planning Policy Framework (NPPF) 2023 details that strategic policies should look towards a minimum period of 15-years from adoption (paragraph 22). Where the Plan includes larger scale developments, such as new settlements or significant extensions, policies should be set within a vision that looks further ahead (at least 30 years). The current timetable for the preparation of the Local Plan anticipates adoption in 2026. However, this has already been delayed by at least 2 months. Considering the multiple stages of plan-making, and that the Joint Plan is being prepared across three districts, the Local Plan period should be adjusted to sufficiently account for the Plan preparation. It is suggested that a period of two years would allow for this, so the Plan period should be pushed back to 2043 at the earliest. Further, if the Councils seek to introduce a new settlement or a significant extension to any existing settlements then the vision should look forward to 2056, at the earliest, to align with requirements of the NPPF. [Q8] No, it is not necessary for the Local Plan to require above and beyond the legal requirement for 10% Biodiversity Net Gain (BNG). It is important that BNG does not prevent, delay or reduce housing delivery. If the Council do intend to seek above the legally required 10%, any policy seeking more than 10% BNG needs to be adequately and thoroughly viability tested when considering land to be allocated, particularly where considering strategic, longer term allocations. This is as site conditions can change over time, BNG obligations could compromise the viability of a scheme if there is an unanticipated high baseline. There are significant additional costs associated with biodiversity net gain, which should be fully accounted for in the Council’s viability assessment, some of which are unknown at this time. Hayfield would encourage the Council to ensure the Local Plan fully considers and provides evidence on how BNG has formed part of the site selection process. This should include understanding the site requirement, including undertaking an assessment of baseline conditions to support the allocation. The Councils should be aware of the full cost for BNG measures and viability testing for the site and considering how this may impact other policy requirements such as affordable housing, other s106 or CIL contributions. [Q29] It is considered that a combination of all the scenarios should be explored, as each comes with benefits. The Council’s aim should be to meet their housing requirement in full, as a minimum. This will likely require considering all areas of the district, including the main towns and the more rural areas. If the Council are considering urban extensions and developments on the edge of established settlements, Land at Mill Lane, Prestbury is available, suitable and deliverable within the Local Plan period. It is outside of the Green Belt and the AONB and is well located to services within Prestbury and Cheltenham. This site is capable of delivering residential dwellings on a smaller scale than large extensions. Paragraph 70 of the NPPF (2023) details that small and medium sized sites can make an important contribution towards meeting the housing requirement and are often built-out relatively quickly. Hayfield are a HBF 5* housebuilder with a track record of delivering high-quality, sustainable homes and creating beautiful places. If Land at Mill Lane is allocated for housing, it would be capable of being brought forward quickly and to the highest quality to help meet the housing needs of the district."]
["Statutory/Specific Consultee","Home Builders Federation","","HBF note the NPPF requirement for ‘Strategic policies should set out an overall strategy for the \npattern, scale and design quality of places, and make sufficient provision for:\n(a) housing (including affordable housing), employment, retail, leisure and other commercial \ndevelopment;\n(b) infrastructure for transport, telecommunications, security, waste management, water \nsupply, wastewater, flood risk and coastal change management, and the provision of \nminerals and energy (including heat);\n(c)community facilities (such as health, education and cultural infrastructure; and\n(d) conservation and enhancement of the natural, built and historic environment, including \nlandscapes and green infrastructure, and planning measures to address climate change and \nadaptation.’\nWe would agree that the SLP should oversee these items as a minimum. HBF would suggest \nthere is a need to consider whether there are any cross-boundary strategic issues, and/or \ninfrastructure needs, that exist with the neighbouring authorities that border the SLP three partners \nareas, which the SLP would need to address in a strategic manner. \nIn light of the housing crisis and the need for housing need to be met in full, HBF would suggest the \nPlan may need to consider the need for a Green Belt review and green belt releases of land for \nhousing, and possibly other uses. It would be logical for this to be addressed in a strategic manner. \nIt is important that the Plan takes decisions about the most appropriate place(s) for new \ndevelopment and provides a clear direction moving forward.\nHBF would also suggest that the delivery of Biodiversity Net Gain may be a strategic issues (see \nour comments later in this response) that needs to be addressed.","HBF is not aware of any locally specific issues that would need be addressed in only one council \narea. However, there will clearly be a need for the housing need of the three-authority area to be \nmet within their respective areas and monitored on that basis. This would seem to be particularly \nimportant in relation to the issue of specialist housing, and self and custom build. HBF would also \nargue there is a need for additional hosing to meet the growth aspiration of the area and wider \nregional housing needs. Such housing would not necessarily need to be restricted to location \nwithin one of three LPA areas of the SLP.","No","The Plan will need to deliver a range of housing sites providing a range of housing types, sizes and \ntenures. This will need to include a full range of housing including the family housing. HBF \nconsiders that it is appropriate for the Council to identify housing, and the maintenance of the fiveyear supply as an objective for the Plan. Meeting housing need in full should also be a key \nobjective of the Local Plan.\nHBF also suggest that Plan will also need to recognise that there will be a possible tension \nbetween policies that seeks a maximise housing density and policies seeking to meet the full range \nof housing needed necessitating a range of new housing types, scale and design.","","HBF agree that it will be important for the Plan to deliver a wide choice of homes that meet the \nneeds of our communities. HBF support the need for the Plan to delivering sufficient new homes \nin the right places to meet the needs of the communities, including market and affordable, \nspecialist homes (e.g. older persons), Gypsy, Travellers and Travelling Showpeople and those \nwishing to build their own homes (self and custom build homes). We welcome the recognition of \nthe important role market housing has to play in delivering this ambition.\nHBF also support the ambition to delivering housing of the right size, type and tenure to create \nmixed and balanced communities, in sustainable locations and with good access to shops, services \nand facilities. However, the policy ask must be considered in the round to ensure development \nremains viable. HBF considers that it is appropriate for the Council to explicitly identify meeting \nhousing needs in full, and the maintenance of the five-year supply as an objective for the Plan.","As discussed in more detail in response to Question 7, HBF is very concerned about the \nproliferation of climate change and energy policies that seek to go further and faster than national \npolicy changes that result in patchwork of differing local standards. There is simply no need for \nLocal Plans to include policies on matters already adequately addressed through Building \nRegulations, other consenting regimes and other regulations. ","Although the HBF is very supportive of the role that Local Plans can play in helping to address and \nmitigate the impact of climate change. HBF is very concerned about the proliferation of climate \nchange and energy policies that are being suggested in some emerging Local Plans. HBF would \ncaution against policies that seek to go further and faster than national policy changes that result \nin patchwork of differing local standards.\nThere is simply no need for Local Plans to include policies on matters already adequately \naddressed through Building Regulations, other consenting regimes and other regulations. Doing \nso creates confusion, duplication, misunderstandings, misalignments and sometime full out policy \nconflicts, which do nothing to help secure the environmental benefits that communities and \ndevelopers are seeking to achieve. \nFor example, HBF note that the current Part G Building Regulations requires developments to \ncompliance with a limit of 125 litres per day. House builders are frequently delivering 115-110 \nlitres per day which means the house building industry is already improving upon the regulations. \nThere is therefore no need for a water efficiency policy in a Local Plan.\nSimilarly, HBF is concerned about any policies which mandate connections to district heating \nnetworks. Heat networks are one aspect of the path towards decarbonising heat, however, \ncurrently the predominant technology for district-sized communal heating networks is gas \ncombined heat and power (CHP) plants. Over 90% of district networks are gas fired. \nAs 2050 approaches, meeting the Government’s climate target of reducing greenhouse gas \nemissions to net zero will require a transition from gas-fired networks to renewable or low carbon \nalternatives such as large heat pumps, hydrogen or waste-heat recovery but at the moment one \nof the major reasons why heat network projects do not install such technologies is because of the \nup-front capital cost. \nThe Council should be aware that for the foreseeable future it will remain uneconomic for most \nheat networks to install low-carbon technologies. This may mean that it is more sustainable and \nmore appropriate for developments to utilise other forms of energy provision, and this may need \nto be considered. If the policy were to be pursued HBF considers any such requirement must be \nimplemented on a flexible basis.\nThe Government consultation on Heat Network Zoning also identifies exemptions to proposals for \nrequirements for connections to a heat network these include where a connection may lead to \nsub-optimal outcomes, or distance from the network connection points and impacts on \nconsumers bills and affordability.\nFurthermore, some heat network consumers do not have comparable levels of satisfaction as \nconsumers on gas and electricity networks, and they pay a higher price. Currently, there are no \nsector specific protections for heat network consumers, unlike for people on other utilities such as \ngas, electricity or water. A consumer living in a building serviced by a heat network does not have \nthe same opportunities to switch supplier as they would for most gas and electricity supplies","","No","","HBF does not comment on specific sites or potential allocations, but we would request the Plan \nactively considered the issue of stacking in relation to BNG, SANGS, carbon sequestration and \nother relevant issues and policy in this area is developed.","The Plan will need to set out a spatial strategy that directs new development to the most \nsustainable locations. In light of the scale of housing need HBF suggest that this will need to\ninclude a range of sites reflecting the settlement hierarchy. It will be important for development \nto be located in accordance with the settlement hierarchy and a range of allocations that meet a \nrange of housing need provided. \nThe NPPF encourages plans to look 30 years into the future when setting a long-term vison for \ntheir area. Paragraph 22 requires that “strategic policies should look ahead over a minimum 15-\nyear period from adoption, to anticipate and respond to long-term requirements and \nopportunities, such as those arising from major improvements in infrastructure. Where larger-\nscale developments such as new settlements or significant extensions to existing villages and \ntowns form part of the strategy for the area, policies should be set within a vision that looks \nfurther ahead (at least 30 years), to take into account the likely timescale for delivery”. HBF \nwould encourage the Councils to use this new joint Local Plan as a way of setting a clear direction \nfor the future development of the area.\nIf the Councils intend to develop any new settlement(s) and/or significant SUEs as one of the ways \nto meet their housing need, this decision should be taken now. It can take many years if not \ndecades for a new settlement to be delivered. Whilst SUEs can be expected to deliver more \nquickly than new settlements they also take time, and as such would make a contribution to \nhousing land supply land later in the plan period. It will be important to be realistic about the \ntimeframes that it will take to deliver a new settlement and/or SUEs so that any assumptions \nabout the contribution of this approach to the land supply of this Plan are realistic. It will be \nimportant for the Plan to acknowledges, if a new community is needed it will take time for it to be \nworked up and developed. The Local Plan should make clear decisions to ensure it provides the \ncertainty the development industry and local communities need.\nIn order to secure an ongoing supply of deliverable sites it will be important for a range of sites to \nbe provided including sites that can be developed in the short and medium terms, as well as \ntaking longer term decisions.","","","Yes","The NPPF requires the standard method to be used unless exceptional circumstances justify an \nalternative approach. In HBF’s view there are no exceptional circumstances which would warrant \na different approach than the standard method being used as the starting point for considering \nthe housing requirements for the Cheltenham, Gloucester and Tewkesbury SLP.\nThe Government has made it clear that it still supports the national target of 300,000 new homes \nper year. The standard method housing requirement has always been only the starting point for \nsetting the housing requirement in a Plan. \nPara 61 of the newly revised (Dec 2023) NPPF says that “to determine the minimum number of \nhomes needed, strategic policies should be informed by a local housing need assessment, \nconducted using the standard method in national planning guidance. The outcome of the \nstandard method is an advisory starting-point for establishing a housing requirement for the \narea”. Para 67 states that “The requirement may be higher than the identified housing need if, for \nexample, it includes provision for neighbouring areas, or reflects growth ambitions linked to \neconomic development or infrastructure investment.”\nHBF strongly support the need for more housing in the Cheltenham, Gloucester and Tewkesbury \nSLP for a variety of reasons including addressing the current housing crisis, meeting housing need, \nproviding affordable housing, to support small and medium house builders and to support \nemployment growth. HBF would request that the Council considers the proposed housing \nrequirement fully considers all of the issues that may result in a need for a higher housing \nrequirement, including the need to provide a range and choice of sites, the need for flexibility, \nviability considerations and whether higher levels of open-market housing are required in order to \nsecure increased delivery of affordable housing.","No","HBF suggest there are no reasons for the housing requirement to be constrained. In fact, for the \nreasons listed above HBF would argue that the housing requirement should be higher.\nHBF would also encourage the Council to take a broader view of the role of its Plan. The new SLP \nmust not be prepared in isolation. HBF is very aware of the housing challenges facing the Bristol \nCity Region, especially since the collapse of the WECA strategic planning. To avoid similar issues \nbe failing North Gloucestershire HBF would suggest that SLP should be developed with input from \nthe neighbouring LPAs in northern Gloucestershire and the Plan may need to be proactive in \nsupporting growth and development of the Region. This necessitates planning for a higher \nnumber of much needed homes.\nThe NPPF (para 70) also requires Local Plans to identify land to accommodate at least 10% of the \nhousing requirement on sites no larger than one hectare, unless there are strong reasons why this \ncannot be achieved. HBF has undertaken extensive consultation with its small developer \nmembers. One of the chief obstacles for small developers is that funding is extremely difficult to \nsecure without a full, detailed, and implementable planning permission. Securing an \nimplementable planning permission is extremely difficult if small sites are not allocated. Without \nimplementable consents lenders are uneasy about making finance available or the repayment \nfees and interest rates they set will be very high. Small developers, consequently, need to invest a \nlot of money and time up-front in the risky business of trying to secure an allocation and a \nplanning permission, and this is money that many small developers do not have. \nThe Councils’ should therefore set out in the SLP’s policies and evidence base to set out how the \nplan will deliver 10% of homes on sites of less than one hectare, as required by the NPPF. Indeed, \nthe HBF would advocate that a higher percentage of small sites are allocated if possible. Such sites \nare important for encouraging the growth in SME housebuilders who will tend to develop these \nsites but rarely see the benefits that arise from the allocation of sites in a local plan. Up until the \n1980s, small developers once accounted for the construction of half of all homes built in this \ncountry resulting in greater variety of product, more competition, and faster build-out rates. Since \nthen, the number of small companies has fallen by 80%.","Yes","HBF are supportive of the need for new homes. The Plan should provide for a wide range of \ndeliverable and developable sites across the area in order to provide competition and choice and \na buffer to ensure that housing needs are met in full. The Plan will also need to deliver a range of \nhousing sites providing a range of housing types, sizes and tenures. This will need to include a full \nrange of housing including the family housing. The Plan will also need to recognise that there will \nbe a possible tension between policies that seeks a maximise housing density and policies seeking \nto meet the full range of housing needed necessitating a range of new housing types, scale and \ndesign. \nHBF would request that the Council also considers the need and demand for housing on \nbrownfield sites and any potential market saturation, recognising these sites may be more suited \nto high density mid-high development which results in a certain kind of housing type, often \napartments which appeal to a particular kind of buyer. It will be important in providing the mix \nand range of housing types that a mix and range of housing sites are allocated included greenfield \nsites which may be better suited to the delivery of family housing.","","","","HBF would suggest that the Council needs to consider the interaction between employment and \nhousing. An increase in the number of jobs can it itself generate a requirement for additional \nhousing. It may be that a higher housing figure is needed for economic reasons and a higher \nhousing number is also needed for housing delivery reasons.","Again, HBF note the interaction between employment and housing. In the same way that an \nincrease in the number of jobs can it itself generate a requirement for additional housing, the \nfailure to address housing needs in the midst of a housing crisis will have negative social, \neconomic and environmental consequences for the region. It may be that a higher housing figure \nis needed for economic reasons and a higher housing number is also needed for housing delivery \nreasons. ","","HBF recognise that housing can play an important role in town centre regeneration, and the \nredevelopment of brownfield sites for housing and other uses is supported by national planning \npolicy and guidance. However, the deliverability of residential development on brownfield sites \nwill be dependent upon the viability of those sites and the demand for high density city centre \nliving post Covid-19. It is important that delivery of the housing requirement set out in the SLP \ndoes not rely overly ambitious intensification of dwellings on allocation and/or windfall sites. \nHBF would request that the Council note the possible issues around the need and demand for \nhousing on brownfield sites and any potential market saturation, recognising these sites may be \nmore suited to high density mid-high development which results in a certain kind of housing type, \noften apartments which appeal to a particular kind of buyer. It will be important in providing the \nmix and range of housing types that a mix and range of housing sites are allocated included \ngreenfield sites, including possibly green belt sites, which may be better suited to the delivery of \nfamily housing.","HBF does not comment on individual sites, other than to say the Plan should provide for a wide \nrange of deliverable and developable sites across the area in order to provide competition and \nchoice and a buffer to ensure that housing needs are met in full. \nSome development may therefore also be needed in villages, and in relation to rural \ndevelopment, HBF would suggest that the spatial strategy should recognise that there may be \nclusters of villages that provide a range of services for that area within reasonable travelling \ndistance of each other, so villages may need to be grouped together. These areas might be able to \nsustainably support a substantial level of development but may not have all the services within \none particular village.\nSimilarly, the SLP should recognise that settlements that currently do not have services could \nexpand to include those services if new development is allocated in those areas. Any list of village \nservices should not be used as a basis for only locating development close to existing services \nrather identifying where services could be improved through new development. There is a real \ndanger that any such criteria could being used negatively to become a way of preventing \ndevelopment in certain communities rather than promoting improved villages and \nneighbourhoods. \nThe SLP should recognise that settlements that currently do not have services could expand to \ninclude those services if new development is allocated in those areas. The current range of village \nservices should not be used as a basis for only locating development close to existing services. It \ncould in fact also identify where services could be improved through new development. Allocating \nhousing sites in rural areas can also provide opportunities for small sites which are particularly \nhelpful for SME builders.","Development can only be required to mitigate its own impacts and cannot be required to address \nexisting issues and shortfalls in provision. It would be unreasonable and fail the CIL tests for \ndevelopers to be expected to pay to address existing deficiencies. It is not appropriate for any\nmethodology of site selection to increase the likelihood of a site being allocated on the basis of \nhow it could address existing infrastructure problems, or over deliver against policy requirements.","HBF does not comment on individual allocation. We would however note that new settlements \nand large urban extensions can have long lead times. Reliance on one (or more) new \nsettlement(s) and/or urban extension(s) for housing delivery may mean delivery from these \nsources will occur later on in the Plan period. This increases the importance of the need for a \nrange of other sites to be provided to ensure a Five-Year Land Supply and early delivery of much \nneeded housing. It will be important for policies and allocation in the Plan to provide for a range \nof housing sites, and as such the site selection methodology needs to reflect this.","HBF note that new development settlements in settlements that currently do not have particular \nservice, or range of services, can create the conditions that would also support the development \nof new services and facilities in those location, helping them to become more sustainable. \nThe Spatial Strategy of the Plan should also recognise that there may be clusters of villages that \nprovide a range of services for that area within reasonable travelling distance of each other, so \nvillages may need to be grouped together. These areas might be able to sustainably support a \nsubstantial level of development but may not have all the services within one particular village. \nThe site selection methodology needs to recognise this reality.\nSimilarly, the Local Plan will also need to recognise that settlements that currently do not have \nservices could expand to include those services if new development is allocated in those areas. \nAny list of village services should not be used as a basis for only locating development close to \nexisting services rather identifying where services could be improved through new development. \nThere is a real danger that any such criteria could being used negatively to become a way of \npreventing development in certain communities rather than promoting improved villages and \nneighbourhoods. The site selection methodology should reflect this position.","","","The consultation considers six distinct scenarios/spatial options to consider the understand their \n‘pros’ and ‘cons of each of them. As para 6.8 of the consultation notes, none of these scenarios \nwould, on their own, deliver sustainable development and the final strategy will be a combination \nof different elements.\nThe six different development scenarios tested were:\n1. Urban concentration\n2. Urban extensions\n3. Urban extensions, avoiding the Green Belt\n4. New strategic settlements\n5. Rural dispersal\n6. Sustainable transport\nHBF do not have any alterative suggestion for spatial options that could be tested but as the \nstrategy will be a combination of approaches it is important that the different combination of \napproaches are tested as the plan’s spatial strategy is further developed.","","HBF would suggest that each scenario should also be tested to see the implication sit would have \non the availability of small sites. There will also be a need to consider the deliverability and \nviability of housing under each option, including mix, type and affordable housing percentages.\n","","","HBF considers that it is important that the spatial distribution of sites follows a logical hierarchy, \nprovides an appropriate development pattern and supports sustainable development within all \nmarket areas. HBF requests that the Plan’s approach to the distribution of housing should ensure \nthe availability of a sufficient supply of deliverable and developable land to deliver the housing \nrequirement. \nHBF are of the view that in light of the housing crisis, and the scale of housing need for \nCheltenham, Gloucester and Tewkesbury a variety of site allocation will be needed, and this is \nlikely to include the need for greenfield also green belt releases. \nHBF would expect the Plan to be an ambitious plan that plans for the future development of \nCheltenham, Gloucester and Tewkesbury, detailing where new housing will go, meeting housing \nneeds in full, providing certainty for the house building industry and setting out a long-term vision \nfor the area, in accordance with the NPPF. \nHBF suggests the Council must come to a view on the appropriate strategy need for a new \nsettlement within the area. HBF reiterate the Plan should provide for a wide range of deliverable \nand developable sites across the area in order to provide competition and choice and a buffer to \nensure that housing needs are met in full. \nAs the spatial strategy for the Plan is considered, HBF reiterates that there will be a need for the \nsettlement hierarchy to be established and used to inform allocations. We would also reiterate \nthat in order to support rural development and smaller home builders some development may \nneed needed in villages. As such there may be clusters of villages that provide a range of services \nfor that area within reasonable travelling distance of each other, so villages may need to be \ngrouped together.\n","[Q1.] The NPPF (2003, para 22) states that strategic policies should look ahead over a minimum 15-year period from adoption and that where larger scale developments form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take in account the likely timescale for delivery. \nHBF would therefore request that the Council ensures that the Plan period will cover at least the 15-year period is provided post adoption of the Plan as required. HBF also note that it can take a long time for Plans to progress from Issues and Options through Reg 18 and Reg 19 consultation,the Submission and Examination of the Plan, the Inspector’s Report and then the formal adoption, by the three constituent authorities. \nIn light of the amount of time it can take to progress through the multiple stages of plan making, a realistic timetable for the preparation of the SLP is essential. This must be realistic, and HBF suggest including a contingency within that timetable would also be sensible. Whatever plan period is chosen there is a need for evidence to cover the whole plan period, it would therefore be sensible to ensure the evidence covers a longer time frame as well.\nThe draft vision refers to 2041 and beyond, we would suggest beyond 2043 may be a more \nsensible approach.\n\n[Q8.] It is the HBF’s opinion that the Council should not deviate from the Government’s requirement for 10% biodiversity net gain as set out in the Environment Act. There are significant additional costs associated with biodiversity gain, which should be fully accounted for in the Council’s viability assessment. It is important that BNG does not prevent, delay or reduce housing delivery. Although the national policies requiring 10% BNG cannot be subject to site specific viability discussion, any policy requirements over 10% can be. Any policy seeking more than 10% BNG needs to reflect this position.\nIn light of all the new guidance on BNG that has recently been published, the Council will need to ensure its approach to BNG to ensure it fully reflects all the new legislation, national policy and guidance. \nHBF has been involved in a significant amount of work, being led by the Future Homes Hub, on BNG preparedness for some time and note the final version of DEFRA BNG Guidance was published on 12th Feb 2024 and the final version of the PPG published on Feb 14th 2024. HBF understand that both may be further refined once mandatory BNG is working in practice, to reflect any early lessons learnt. \nHBF note that there is a lot of new information for the Council to work though and consider the implications of, in order to ensure that any policy on Biodiversity Net Gain policy so that it complies with the latest policy and guidance as it is finalised. It should also be noted that the PPG is clear that there is no need for individual Local Plans to repeat national BNG guidance.\nIt is also important to note that large and complex sites where the development is phased, the guidance is clear that the 10% must be delivered at the end of the development, and this may not result in 10% BNG on each phase. The BNG PPG has been since its draft version to provide additional advice on phased development. \nHBF also suggest particular care is needed in terminology to ensure the BNG policy reflects the national policy and guidance. For example, on-site and off-site biodiversity is referred to as units, and the statutory national credit system of last resort is referred to as credit. Similarly, it will be important to differentiate between the mitigation hierarchy, which seeks to avoid harm and then mitigate it in relation to protected habitats and the BNG hierarchy which prioritises on-site BNG delivery, then off-site units and finally allows for statutory credits. National BNG policy allows for all three of these options, and therefore the Plan should also reference statutory credits. \nThe costs of BNG must also be considered as part of the whole plan viability assessment and should be specified as a single specific item, not combined into a generic s106 costs item. There \nare significant additional costs associated with biodiversity net gain, which should be fully accounted for in the Council’s viability assessment, some of which are unknown at this time. It is important that BNG does not prevent, delay or reduce housing delivery. As this is an emerging policy area and the market for off-site provision, and statutory credits are not yet known, any figure used for BNG costs will need to be kept under review as BNG implementation progresses and a greater understanding of actual costs become available. The Whole Plan Viability \nAssessment should clearly set out how it considered the implications of mandatory BNG and how it was arrived at using the most up to date BNG costs information available.\nHBF suggest that there will also be a need for SLP to explain how it links into the emerging Local Nature Recovery Strategies. Although these are new initiative, and one has yet to be prepared that covers Cheltenham, Gloucester and Tewkesbury, the LNRS will be an important part of setting a spatial strategy for Nature. As such, as the LNRS emerges it will be important for this Local Plan to be kept under review and further public consultation on the interaction between the two documents and/or changes to Local Plan policy to reflect the LNRS may be needed. \nHBF would encourage the Council to ensure the Local Plan fully considers and evidence how BNG has formed part of the site selection process. This should include understanding the BNG requirement, including undertaking an assessment of the baseline to support the allocation. Understand the BNG costs and viability for the site and considering how this may impact other policy requirements such as affordable housing, other s106 or CIL contributions. \nHBF also notes that there seems to be significant potential for confusion around environmental hierarchy, and suggest particular care is needed to avoid any confusion between the wellestablished mitigation hierarchy and the new BNG hierarchy. There is need for the policy wording and/or supporting text to be clearer about the differentiation between the mitigation hierarchy (which seeks to avoid harm in the first place, then mitigate and only then compensate it in relation to protected habitats) and the BNG delivery hierarchy (which avoids loss to start with, \nbut then prioritises on-site BNG delivery, then off-site units and finally allows for statutory credits). There seems to be significant potential for confusion between the two difference hierarchies. HBF therefore suggest that the Reg 19 Plan should do all it can to explain how the two hierarchies work in different ways and that they seek to achieve different aims. We would suggest the use of the term “BNG spatial hierarchy” may help with this issue.\nReference could also usefully be made within the Plan to the small sites metric. This is intended to be a less complex statutory metric that can be used to set out how 10% BNG will be secured on small sites. It can only be used for on-site BNG delivery. The national mandatory 10% BNG policy will apply to small sites from April 2024.\n\n[Q29.] HBF believe the housing requirement in the SLP should be increased from the standard method baseline for a variety of reasons including addressing the current housing crisis, meeting housing need, providing affordable housing, to support small and medium house builders and to support employment growth. HBF would request that the Council considers the proposed housing requirement fully considers all of the issues that may result in a need for a higher housing requirement, including the need to provide a range and choice of sites, the need for flexibility, viability considerations and whether higher levels of open-market housing are required in order to secure increased delivery of affordable housing, each of which on their own may be a reason to increase the housing numbers, so their cumulative impact could be significant. A higher housing requirement may also be particularly important if development is to be of the scale necessary to support significant infrastructure projects in a way that is viable and deliverable. \nAs such HBF suggest that this means that it is likely elements of all of the scenarios may be needed. Indeed, the Council acknowledges a combination of approaches will be needed. HBF \nsuggests development within existing settlements, urban extensions and new settlements may all be needed to meet the housing requirements in full. Development in both non-greenbelt location and green belt locations will be needed, development in villages and along transport corridors will also be needed. This would enable the Plan to provide for a full range and type of sites to enable a full range and different housing types to be provided to meet needs in full.\nHBF does not comment on individual sites, other than to say the Plan should provide for a wide range of deliverable and developable sites across the area in order to provide competition and choice and a buffer to ensure that housing needs are met in full. The soundness of strategic and non-strategic site allocations, whether brownfield or greenfield, will be tested in due course at the Local Plan Examination.\n\n[Q31.] HBF would highlight the importance of consideration being to the Monitoring of the Plan, right from the outset. Monitoring is an essential part of the Plan, Monitor, Manage approach, and it is essential that actions are taken if monitoring shows under-delivery of housing during the Plan Period. It will be important for the Plan to include a monitoring framework which sets out the monitoring indicators along with the relevant policies, the data source and where they will be reported, this should include the actions to be taken if the targets are not met. \nHBF do not support the inclusion of policies within a Local Plan that merely triggers a review of the Local Plan if monitoring shows housing delivery is not occurring as expected. Such a policy does nothing to address the housing crisis or undersupply of homes. There are other more effective and immediate measures that could be introduced into policy that would enable the Council to address housing under-delivery much more quickly than would be possible through the production of another plan, or plan review. \nHBF trust that the Council will find these comments useful as it continues to progress its Local Plan. I would be happy to discuss these issues in greater detail or assist in facilitating discussions with the wider house building industry. HBF would like to be kept informed of all forthcoming consultations upon the Local Plan and associated documents. Please use the accompanying contact details for future correspondence."]
["Statutory/Specific Consultee","Historic England","","Short Answer \n\nWe do not have any additional strategic policy topics to suggest, although we would like to offer some early advice on potential content for strategic policies on heritage and design. We strongly suggest that the authorities’ in-house heritage and design specialists are involved in drafting these policies. Detailed Advice Heritage In line with NPPF paragraph 20, we support the inclusion of a strategic policy on heritage, while also noting that the SLP consultation document (paragraph 2.11) states a wish that the SLP should not duplicate national planning policy. Avoiding duplication will become increasingly important when National Development Management Policies are introduced. \n\nParagraph 196 of the NPPF provides a steer on what should be taken into account to ensure that plans contain ‘a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats’. We suggest that in drafting this policy, the SLP authorities consider:\n\n- Signalling what is special and distinctive about the historic environment of the area that ought to be conserved and enhanced. This could include drawing out those aspects of the current JCS strategic policy (and its supporting text) that help to paint a picture of the area and to drive good design and decision making. \n- Indicating how the authorities will capitalise on their heritage as a factor in wellbeing and a catalyst for regeneration, culture and tourism e.g. through current or proposed strategies. \n- Identifying any special considerations in terms of the way that landscape/townscape interacts with heritage. \n- Indicate how the authorities will ensure that historic city, town and local centres, including those which are conservation areas, will continue to be vibrant and attractive places or, if necessary, undergo transformation and regeneration (for example, as a legacy of the Townscape Heritage Initiative and High Street Heritage Action Zones). \n- Indicating what the authorities are doing and can do through the local planning process to address heritage assets that are ‘at risk’ (see: https://historicengland.org.uk/imagesbooks/publications/har-2023-registers/). \n- Encouraging re-use, refurbishment, adaptation and retrofit of historic buildings having regard to their embodied carbon. \n- Indicating how they will promote public access and enjoyment of heritage assets. \n- Setting out any special requirements in relation to conservation areas or the management of particular asset types such as Historic Parks and Gardens or archaeology in the area. \n- Circumstances where S106 or CIL should be leveraged to contribute to cultural heritage infrastructure. \n\nWhile we note the stated intension that strategic policies are ‘cross-boundary’ and are distinguished from non-strategic ‘locality’ policies, it is worth noting that the NPPF does not make this distinction. The cathedral and dockside heritage of Gloucester, Tewkesbury’s Abbey and the Spa-town heritage of Cheltenham are certainly of strategic importance to the sub-region. Consequently, while we agree that this distinction may be useful as a general guide in the drafting of the plan, we suggest that it should not be applied so strictly as to inhibit appropriate references to the area’s key settlements and characteristics within strategic policies. \n\nWe provide more general advice on how to take account of the historic environment in the preparation of Local Plans in our Good Practice Advice in Planning 1: The Historic Environment in Local Plans (note that NPPF policy references are now out of date). As part of a robust evidence base, it will be beneficial if the plan draws upon up-to-date information including Conservation Area Character Appraisals and the Heritage Strategies for Gloucester and Tewkesbury. \n\nDesign \n\nCareful consideration will need to be given to the content of a strategic policy on design and how this will respond to areas of historic character. NPPF paragraph 132 states that plans should, at the most appropriate level, set out a clear design vision and expectations, reflect local aspirations, and be grounded in an understanding and evaluation of each area’s defining characteristics. Paragraphs 133 and 134 go on to set out requirements in relation to design guides and codes. It would be helpful if the strategic policy could indicate how the authorities intend to meet these requirements through the SLP, its evidence base, and any design guides and codes (potentially as part of the plan or as supplementary plans). In rural areas, the Historic Landscape Characterisation for Gloucestershire should form part of the evidence base to inform the design of new development. \n\nWithin NPPF chapter 11 on ‘making effective use of land’ (paragraphs 129-130) there is associated guidance on how area-based character assessments, design guides and codes can help authorities to balance the need to obtain higher development densities with the need to respect the character of their areas. This is particularly important in sensitive historic environments and it may be helpful to consider Historic England’s research into Increasing Residential Density in Historic Environments.","Cheltenham, Gloucester and Tewkesbury all have district level plans that were relatively recently found sound and adopted. These contain local development management policies, including those relating to landscape, design and heritage, along with local site allocations. We expect that many of the topics identified in these plans will remain relevant and suggest that a bottom up review of the adopted plans should be carried out to identify policies for retention, adjustment or deletion. \n\nIn relation to heritage, some of the suggestions that we have made in relation to strategic policies may be better suited to local policies if they only apply to a discrete area. Equally, for issues that are included in the strategic policy, there may in turn be more specific issues or projects that could be dealt with by the local policies. For example: \n\n- In relation to heritage assets at risk – identify and promote opportunities for enhancement and beneficial re-use of specific assets (including those on the Heritage at Risk register), such as a disused historic warehouse or mill or other urban or rural building – e.g. Healings Mill. \n- Are there special considerations in relation to the landscape, townscape or views that are relevant to a particular authority or area? For example, are there any important skyline views and views of or from heritage assets, that ought to be protected from the impacts of unsympathetic development? \n- Are there specific themes of local importance such as Gloucester’s archaeology and dockside heritage, the Spa heritage of Cheltenham, or the rural villages of Tewkesbury, that require a distinct approach to development management? \n- Is there a named local asset, or group of assets, that require special attention such as the cathedral precinct or a historic high street? - Are there aspirations within the existing Heritage Strategies for Tewkesbury and Gloucester that could be elevated into strategic or local policies?","Yes","Historic England broadly agrees with the proposed Vision. \n\nWe request that the reference to heritage assets being ‘preserved’ is replaced with ‘conserved’, to reflect the terminology of the NPPF and the need for careful management of change, rather than preservation unchanged. \n\nThere is also an opportunity to harness the potential of the outstanding historic environment of the area as a driver for tourism and heritage-led regeneration, particularly in centres and historic high streets. It would be helpful to highlight this in the Vision.","Yes","Historic England broadly agrees with the proposed Strategic Objectives. \n\nAt point 3 under ‘meeting the challenges of climate change’, which relates to efficient use of land and high density development, we request the addition of the wording ‘insofar as this is compatible with local character and heritage’. This reflects NPPF paragraphs 129, 130 and 196(c) and is particularly important in the context of some of the sensitive historic areas that exist within Cheltenham, Gloucester and Tewkesbury. \n\nAt point 3 under ‘delivering well designed, beautiful and safe places’ we request that the last phrase is adjusted slightly to say ‘respects and enhances local character and distinctiveness’. This again reflects NPPF paragraph 196(c). \n\nUnder the heading ‘making as much as possible of brownfield land and conserving and enhancing the natural and historic environments’, at point 1 we request that ‘protecting’ is replaced with ‘conserving’ to reflect NPPF terminology for the conservation of heritage assets.","Promoting renewable energy at appropriate sites and areas, while ensuring that there is a robust policy framework to protect the environment including heritage. \n\nSupporting the retention, re-use, conversion, adaptation and retrofit of existing buildings where appropriate. This should include heritage assets and other buildings of traditional construction which make up a significant proportion of our housing stock. Historic England provides a wide range of technical and planning advice on retrofit and energy efficiency in historic buildings, see: https://historicengland.org.uk/advice/technical-advice/retrofit-and-energy-efficiency-in-historicbuildings/ as well as flooding and historic buildings: https://historicengland.org.uk/advice/technical-advice/flooding-and-historic-buildings. A new Advice Note on Climate Change and Historic Building Adaptation in the context of planning is also in preparation.","","In relation to question (b) retention and reuse of existing the buildings, the authorities could consider the following: \n\n- Whether consideration of embodied carbon should form part of the decision-making framework. \n- Whether the building is of architectural and historic merit and/or in keeping with local character such that this should add further weight to the desirability of retaining and reusing a building. \n- Conversely, whether retention and reuse are not appropriate in some circumstances having regard to the quality and condition of the building, for example where re-use of a modern structure of poor design/construction would be inefficient and where its removal could enhance the landscape, townscape or historic settings.","","No","No response","No response","No","The NPPF states that Local Plans should provide a positive strategy for renewable and low carbon energy and heat and should consider identifying suitable areas for renewable and low carbon energy sources. The incentive to identify specific areas is more pressing if the authorities wish for there to be opportunities for wind energy in the district. This is as a result of footnotes 57 and 58 of the NPPF which require wind turbines to be located in ‘an area identified as suitable for wind energy development’ in the plan or another of the documents listed. \n\nThe Renewable Energy Study referred to at paragraph 4.16 of the SLP consultation document identifies technical potential for wind energy and other renewable sources in the plan area. Planning Practice Guidance for renewable and low carbon energy (https://www.gov.uk/guidance/renewable-and-low-carbon-energy) states that local planning authorities should take into account the requirements of the technology and, critically, the potential impacts on the local environment, including from cumulative impacts (Paragraph: 005 Reference ID: 5-005-20150618). We are therefore pleased to note that the methodology for the technical assessment excludes certain heritage assets, namely Registered Parks and Gardens, Registered Battlefield, Scheduled Monuments, Listed Buildings, Conservation Areas and locally listed buildings in Cheltenham. However, this does not account for impacts on the settings of heritage assets. We would be pleased to have further discussions with the authorities about how any proposed areas suitable for wind could be informed by a high-level risk assessment of impacts on historic settings, with an opportunity to establish best practice in this area. For example, could an additional component alongside the Landscape Sensitivity Analysis take account of significant views from highly graded heritage assets (e.g. those listed at paragraph 206b of the NPPF) to ensure that areas likely to have unacceptable impacts are excluded? \n\nWe recognise that areas suitable for wind differ from other forms of site allocation, often emerging as broad areas of search rather than discrete areas in which the principal of development is established. Any proposal would therefore need to be subject to further detailed assessment of impacts at application stage. Due to the considerable height of wind turbines, most would be expected to have heritage impacts, and it will therefore be important that any associated policy requires Heritage Impact Assessment of site-specific proposals to inform location and design and to support planning applications.","No","No response","No","No response","No","","","No response","No response","There is huge potential for heritage-led regeneration as a driver for economic development, particularly in Gloucester. We would welcome policies that acknowledge and seek to harness this potential, both as part of the general employment policies and for specific site allocations.","As above – the historic environment of the area should be viewed as an asset to drive heritage-led regeneration. Conserving, enhancing and where appropriate finding new uses for heritage assets, while sensitively introducing new uses and developments alongside, can create vibrant and attractive places where businesses want to invest. Further information can be found in Heritage Counts: https://historicengland.org.uk/research/heritage-counts/heritage-and-economy/placedevelopment/.","No response","Please see our response to question 19. Issues to consider include: \n\n- What opportunities are there for historic high streets – for example capitalising on the legacy of projects and strategies such as the Townscape Heritage Initiative in Southgate Street and the High Street Heritage Action Zones at Cathedral Quarter/Westgate and Tewkesbury? \n- How can increased use and activity be promoted, including increasing residential populations in central Gloucester and making use of upper floors for residential or commercial uses? \n- Are there historic centres where review of Conservation Area Appraisals and Management Plans could help to drive positive change? \n- How can the plan help to stimulate and support regeneration of Barton Street ‘at risk’ Conservation Area? \n- We support the continued promotion of Healings Mill as a mixed-use development opportunity and a key feature of regeneration of Tewkesbury town. \n- Could this or other heritage assets be identified as potential targets for developer contributions from CIL/S106 associated with strategic development proposals (e.g. Tewkesbury Garden Town)?","No response","We would welcome recognition in the SLP that heritage is integral to much of our infrastructure: from railway stations and viaducts to historic streets, bridges, canals and other waterways, parks and public spaces. \n\nHistoric England’s Good Practice Advice in Planning: The Historic Environment in Local Plans identifies some of the potential roles of planning obligations in relation to heritage, which include: \n\n- Repair, restoration or maintenance of a heritage asset(s) and their setting \n- Public realm obligations, including enhancement of historic squares and spaces, registered parks and gardens, historic pavement materials, street furniture, removal of street clutter and installation of sympathetic lighting, etc. \n- Increased public access and improved signage to and from heritage assets - Interpretation panels/historical information and public open days \n- Provision of local capacity for the storage of, and public access to, archives resulting from archaeological and/or historical investigation \n\nThere is also an opportunity for the infrastructure Delivery Plan (and in future the Infrastructure Delivery Strategy) to form part of the authorities’ positive strategy for the historic environment (as envisioned by NPPF paragraph 196) by ensuring that it includes any public/infrastructure assets that are in significant need of investment as potential targets for money raised through planning obligations.","No response","No response","","","No response","","Scenario 1: Urban Concentration – An additional pro of the first development scenario if done well could be heritage-led regeneration. \n\nScenario 4: New Strategic Settlement – A potential pro or con that will vary between and within the potential new strategic settlements would be impacts on rural heritage assets, historic landscape character and unknown archaeology. We very strongly advocate Heritage Impact Assessment and a masterplanning approach to the potential new strategic settlement(s) to inform site selection and policy criteria, including avoidance and mitigation of impacts on the historic environment. \n\nFor example, between Highnam and Churcham there are sensitivities relating to the presence of Grade I listed Highnam Court, its Grade II* Registered Historic Park and Gardens and associated heritage assets. Along the A40 and at Churcham there are numerous listed buildings including the Grade II* listed Church of St Andrew, along with non-designated assets on the Historic Environment Record including a Roman Road. \n\nIn and around Boddington – an area with monastic associations – there is the Grade I listed Church of St Mary Magdalen, several other listed buildings and non-designated heritage assets including the site of a medieval deserted settlement west of Boddington Manor. \n\nAt Ashchurch, heritage assets include the Grade II* listed Church of St Nicholas, other listed buildings, scheduled monuments and non-designated assets. Just north of the boundary in Wychavon there are also several scheduled monuments of Iron Age and Roman origin, highlighting the high potential for significant unknown archaeology in the area.","Scenario 1: Urban concentration","","","We promote Heritage Impact Assessment (HIA) of all potential site allocations as a step between the HELAA and the selection of site allocations for inclusion in the plan and the drafting of associated policies. This is particularly important in sensitive historic environments, which are common in the SLP plan area. This work can be carried out in-house by heritage professionals, or by consultants. Published guidance including a 5-step process for proportionate Heritage Impact Assessment in the context of Local Plans can be found in The Historic Environment and Site Allocations in Local Plans. Other South West local authorities who have recently undertaken, or are undertaking this work include Teignbridge, East Devon, BCP Council and Exeter City Council. Further advice on this is provided in our response to the HELAA.\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nWe agree that brownfield development should form part of any mix of development scenarios. We would also support gentle densification in appropriate circumstances, which to some extent aligns with Scenario 1 – urban concentration. In pursuing this option it will be important for the authorities’ to consider the guidance in Chapter 11 of the NPPF – making effective use of land, including paragraph 128(d) which states that policies and decisions should take account of ‘the desirability of maintaining an area’s prevailing character and setting (including residential gardens), or of promoting regeneration and change’. Paragraphs 129 and 130 go on to indicate how area-based character assessments, design guides and codes can assist this process."]
["Statutory/Specific Consultee","Homes England","","","","Yes","The draft Vision set out for the SLP is supported. In particular, Homes England supports the emphasis on meeting housing and growth needs in sustainable locations, which is a key facet of delivering high quality development which meets the challenges of climate change. The priority of utilising brownfield sites is supported, however as recognised in the vision, there is also a need for ‘large-scale, comprehensively planned new development’ on greenfield sites at sustainable and appropriate locations. Homes England considers that such large-scale sites, which are most likely to require greenfield land, must be focused on locations which deliver the NPPF objective of sustainable development. For plan-making this means promoting sustainable patterns of development that seek to meet the development needs of their area, align growth and infrastructure and mitigate climate change, amongst other requirements (para 11 of the NPPF). Development should be promoted in areas with good access to public transport and in particular rail connectivity, including the potential for new and improved station and train facilities. Additionally, development should be promoted within sites which are located adjoining major sustainable settlements, and unless Very Special Circumstances are demonstrated, are not within the Green Belt in the first instance. To deliver this ambitious vision requires the delivery of such sites, such as the opportunity afforded by a Garden Community at Ashchurch, Tewkesbury. This location is a highly sustainable location for meeting the housing needs of Tewkesbury and potentially wider SLP area. It adjoins Tewkesbury, does not flood, is accessible by public transport to a wide range of employment, retail, and services. Additionally, Ashchurch for Tewkesbury Railway Station is located centrally within the Garden Town. Homes England considers this must be prioritised over other greenfield proposals with less potential for sustainable transport.","Yes","Homes England strongly supports the strategic objectives. The Tewkesbury Garden Community will be planned and delivered in line with national Garden Communities principles (published by the former Ministry of Housing, Communities and Local Government), and the local Tewkesbury Garden Town Charter (once adopted). Homes England considers these are well-aligned with the draft SLP strategic objectives, as summarised below: 1. Meeting the challenges of climate change – a clear principle of garden communities, which would be at the heart of Tewkesbury Garden Community, is that they are resilient places that allow for changing demographics, future growth, and the impacts of climate change including flood risk and water availability, with durable landscape and building design planned for generations to come. 2. Building strong, competitive and sustainable urban and rural economies – an integral part of garden communities is that they are built at a sustainable scale which supports the necessary infrastructure to enable the community to function whilst providing capacity for future growth to meet the changing economic needs of the local area. The Tewkesbury Garden Community is well-located to support sustainable economic growth due to its proximity to Ashchurch and Tewkesbury town, as well as being accessible by rail to Cheltenham, Birmingham, Bristol and major urban locations further afield. 3. Ensuring strong and vibrant city and town centres – building on the principle of sustainable scale and to be self-sustaining, garden communities are expected to establish a distinctive OFFICIAL local identity with an attractive, functioning centre and public realm which would support and complement rather than compete with existing centres. 4. Delivering a wide choice of homes that meet the needs of our communities –a key component of garden communities is that they should make a significant contribution to closing the housing supply gap. The proposed Tewkesbury Garden Community would significantly boost high-quality housing supply (including affordable housing) and diversify the housing stock / tenures within the SLP area, in line with evidenced housing need. 5. Delivering well designed, beautiful and safe places –given the scale of the proposed Tewkesbury Garden Community, there is clear opportunity to deliver place-making that embeds the highest quality design from the outset. Garden communities are intended to be vibrant mixed-use communities that support a range of local employment types and premises, retail opportunities, recreational and community facilities. These will form core components of the emerging masterplan for Tewkesbury Garden Community. 6. Prioritising sustainable transport and active travel – this clearly aligns with the garden community principles of ensuring developments are delivered with integrated, forward looking, and accessible transport options that support economic prosperity and wellbeing for residents. The Tewkesbury Garden Community will leverage the benefits of the proposed improvements to Ashchurch railway station and increased service frequency alongside walking and cycling infrastructure to deliver a place which is easy to navigate by active travel, and facilitates sustainable access to adjacent jobs, education, and services. Homes England are working with Network Rail to provide additional land to enable a third platform and third passing rail line to be delivered at the station using Homes England land. This alongside other strategic route upgrades considered in the Birmingham to Bristol Strategic Corridor Study (2022), would result in services increasing to a minimum of 4 per hour in both directions from the station (See our HELAA Submission for Church Farm). Homes England intend to then deliver on the adjoining land to the mainline station at Church Farm, a mixed use residential, retail and community development with multi modal interchange integrating the Railway Station directly into the Garden Town located to the east with convenient, safe and accessible foot, cycle, and public transport connections to the wider garden town. 7. Making as much use as possible of brownfield land and conserving and enhancing the natural and historic environments –In meeting the identified housing need, previously developed sites will play an important contribution. However, this source of housing land is finite and in short supply within Tewkesbury District and indeed the wider Strategic Plan area. As such sustainable, urban extensions on greenfield sites which are appropriate in all other respects will also be required to meet the housing needs of the SLP area. 8. Promoting healthy and resilient communities – an important principle of garden communities is they are designed to provide the ‘choices and chances’ for all to live a healthy life, through taking a whole systems approach to key local health and wellbeing priorities and strategies. Within the context of Tewkesbury Garden Community, this would be developed via local vision and engagement as to how such communities can address key priorities for health and well-being. In addition, there is also the requirement for garden community legacy and stewardship arrangements to be in place for the care of community assets, infrastructure and public realm, for the benefit of the whole community. The Garden Town will provide significant new and expanded areas of community open space, networks of recreational and activity routes accessible by foot and cycle, and large well designed integrated areas of public open space and leisure facilities. This will contribute significantly to the new and existing communities.","A new Garden Community at Ashchurch represents a major opportunity to address the impacts of climate change, through provision of large-scale mixed-use development in a sustainable location, given it is served by the Ashchurch for Tewkesbury railway station, several public transport bus routes, National Cycle routes and existing Public Rights of Way, following the principles of “Transit Oriented Development”. Delivery of Tewkesbury Garden Community offers an opportunity to focus on the upgraded provision of sustainable transport modes, including walking, cycling, public transport and rail connectivity. By focusing a large proportion of the planned growth in a sustainable location there is a significant opportunity to plan comprehensively for homes, employment, infrastructure and services that can be accessed by walking and cycling, hence reducing the need to travel. It also provides the opportunity for future communities to travel by sustainable modes, particularly by rail as discussed above. Given the scale of the sites promoted through the Tewkesbury Garden Community, homes and facilities can be strategically designed in a manner that ensures they are linked by active travel routes. Furthermore, there are multiple opportunities to embed green and blue infrastructure (GBI) and take an integrated approach to BNG and sustainable water management, deliver net zero carbon and energy efficient housing, and include community renewable energy schemes. All of theseserve to future proof development and foster resilient communities, which are key principles of the Garden Community and Homes England’s Strategic Plan (2023-2028).","Homes England expects that the Strategic and Local Plan should reflect the current building regulations at the time of adoption. The Homes England Strategic Plan (2023-2028) sets out key objectives to deliver a housing and regeneration sector that works for everyone, driving diversification, partnership working, and innovation. This aims to deliver amongst other items, a more productive housebuilding sector, and promotes the uptake of construction using Modern Methods of Construction (MMC), where Homes England will continue to encourage partners to deliver homes using forms of MMC which bring the greatest innovation, productivity or sustainability benefits. Another integral objective of the Strategic Plan is to deliver well-designed homes and places in line with Building for a Healthy Life, the National Design Guide and local design codes. In relation to this, Homes England have clear ambitions to increase the proportion of homes that meet or exceed the agreed standards for design quality (in line with Building for a Healthy Life). In addition, Homes England is committed to the objective of delivering sustainable homes and places, maximising their positive contribution to the natural environment and minimising their environmental impact. Under this objective, there is the ambition to elevate building performance (EPC B or above) and develop embodied carbon indicators for Homes England supported development.","Homes England expects that the Strategic and Local Plan should reflect the current building regulations at the time of adoption. The Homes England Strategic Plan (2023-2028) sets out key objectives to deliver a housing and regeneration sector that works for everyone, driving diversification, partnership working, and innovation. This aims to deliver amongst other items, a more productive housebuilding sector, and promotes the uptake of construction using Modern Methods of Construction (MMC), where Homes England will continue to encourage partners to deliver homes using forms of MMC which bring the greatest innovation, productivity or sustainability benefits. Another integral objective of the Strategic Plan is to deliver well-designed homes and places in line with Building for a Healthy Life, the National Design Guide and local design codes. In relation to this, Homes England have clear ambitions to increase the proportion of homes that meet or exceed the agreed standards for design quality (in line with Building for a Healthy Life). In addition, Homes England is committed to the objective of delivering sustainable homes and places, maximising their positive contribution to the natural environment and minimising their environmental impact. Under this objective, there is the ambition to elevate building performance (EPC B or above) and develop embodied carbon indicators for Homes England supported development.","","Yes","As set out in response to Question 8, given the scale of land availability and development that would be delivered as part of the Garden Community, there are significant opportunities to deliver integrated multi-functional green and blue infrastructure that performs various functions for climate resilience, nature recovery and food security. Provision of green spaces that deliver an array of benefits including flood risk mitigation and recreation are at the heart of the Garden Community principles, and Homes England would collaborate with other delivery partners and the authorities to ensure that the approach to Tewkesbury Garden Community masterplan embeds these features at the outset of design of the garden community.","Homes England considers that new development should be sustainably located, with a particular emphasis on mixed use and higher density, walkable environments in the proximity of train stations to better promote use of public transport and reduce carbon emissions generated by reliance on private (non-electric) vehicles. Such an opportunity is afforded through Tewkesbury Garden Community, which is located on the existing rail line with excellent connectivity and potential for integrated modes of sustainable transport and active travel. Homes England acknowledges that there is a potential transformation opportunity associated with proposed upgrades by Network Rail to the Ashchurch for Tewkesbury railway station. A well serviced railway station can provide multi-faceted and wider benefits to Ashchurch and the future Garden Community, including economic and enterprising opportunities, enhanced public realm and landscape and retail / leisure facilities. As referenced in response to Question 5, a key principle of Garden Communities is that they are holistically planned, self-sustaining and at a sustainable scale which supports the necessary infrastructure to allow the community to function self-sufficiently on a day-to-day basis, with the capacity for future growth to meet the evolving housing and economic needs of the local area. They are expected to be genuinely mixed use, vibrant mixed-use communities that support a range of local employment types and premises, retail opportunities, recreational, education and community facilities. For example, the proposal to deliver 10,000 homes as part of Tewkesbury Garden Community would be of sufficient scale to support the delivery of a new secondary school.","","","","Homes England supports the use of the standard method in the Strategic and Local Plan, on the basis that (as required under paragraph 61 of the NPPF), evidence has not been provided to date to justify exceptional circumstances for diversion from this approach. Homes England considers that the publication of new household projections from the 2021 Census, may result in changes to the projection of housing need calculated via the standard method, and this should be reviewed as part of the ongoing preparation of the Strategic and Local Plan.","","The 20-year need for Tewkesbury Borough is calculated as 11,140 new homes. Homes England considers that at least 10,000 new homes can be reasonably accommodated at the broad location of Tewkesbury and Ashchurch, through the Tewkesbury Garden Community. This presents an excellent opportunity to meet a large proportion of the borough’s housing need within a highly sustainable location in the Borough, adjacent to the main settlement of Tewkesbury. As the main settlement in the borough, Tewkesbury benefits from a range of existing employment, services and facilities. It also benefits from a mainline train station, making it a highly sustainable location for the delivery of large-scale housing need for the area. Technical due diligence undertaken for the Tewkesbury Garden Town indicates that the site has no major planning constraints including few landscape/environmental protections in the immediate areas and a low risk of flooding, further supporting realistic delivery during the plan period. Whilst infrastructure investment and delivery would be required to facilitate Tewkesbury Garden Community, the scope of this is relatively focused given the existing context and would provide wider benefits to Tewkesbury and the Borough, such as improvements to public transport provision, schools, open spaces and community facilities. Given the opportunity to accommodate such a large proportion of housing need in a sustainable way within the Garden Community, it is not considered that there are constraints which justify planning for a lower level of housing growth than the calculated need. In addition, Homes England are committed to partnership with the SLP authorities in delivering a Garden Community in Tewkesbury. This is demonstrated by early local and stakeholder engagement to date and will include further engagement with local authorities, key landowners, developers and third parties to establish necessary agreements to deliver development at-scale and phased strategically in line with other transport infrastructure proposals for the area (including M5 J9 and the A46). Extensive technical due diligence has been undertaken for sites promoted within the Garden Community, and overall, this demonstrates technical deliverability underpins ongoing masterplan and Business Case development. Such master planning activities being undertaken collaboratively with Tewkesbury Borough Council and other stakeholders will be key to understanding the potential of the area to deliver sustainable and inclusive place-making in this strategic location. At this stage, Homes England anticipate delivery of initial phases (subject to OFFICIAL planning approvals) within 5-10 years of the Plan Period. However, Homes England is the Government Housing enabler and seek to accelerate the delivery of land for housing so will seek to work with partners to achieve development within the shortest timescale possible.","","With the potential increase in service provision at Ashchurch Railway Station, there is potential opportunity to provide high density accommodation at this location given its accessibility to Birmingham, Cheltenham and Bristol in under 1 hour by train. It would also be appropriate for the SLP to consider the needs of older and vulnerable members of society for their housing needs – including extra care, sheltered housing or assisted living integrated into suitable areas of the Garden Town around Local or District centres and mixed-use centres.","","Homes England has no objection to this proposal, noting that whilst not currently a component of the proposals for Tewkesbury Garden Community, it could provide an opportunity for suitably located traveller pitches, should no other suitable sites be available in the Plan area.","Homes England has no objection to this proposal, noting that whilst not currently a component of the proposals for Tewkesbury Garden Community, it could provide an opportunity for suitably located traveller pitches, should no other suitable sites be available in the Plan area.","Homes England broadly supports the approach outlined towards economic growth. In achieving sustainable growth, Homes England recommends that large employment allocations and major opportunities for growth are focused at main centres and adjoining large-scale development such as Tewkesbury Garden Community. It is noted that Tewkesbury Borough is identified as an area requiring particular growth in Use Classes B1c (light industry), B2 (general industry) and B8 (storage and distribution). The provision and location of Use Class B8 must be carefully considered, due to the particular requirements of this type of use (such as space, access and traffic impacts) to ensure it is located in appropriate locations on the transport network and planned in conjunction with other types of development. One of the benefits of the Garden Community is that it will be planned to integrate well with existing communities within Tewkesbury and will enhance regeneration and support existing centres, while also providing substantial opportunities for planned employment growth. There is clear advantage in sustainability terms of locating the Garden Community development around key nodes such as the Ashchurch for Tewkesbury railway station. With high frequency rail services to Birmingham, Bristol and Cheltenham-arising from Network Rails’ proposals to upgrade services to a minimum of 4 per hour, there is opportunity for transformation. This will benefit not only the Church Farm site (submitted by Homes England in response to the SLP Call for Sites) but would also generate positive ripple effects for the wider Garden Community, in particular the adjacent existing employment areas due to enhanced accessibility and access to skilled employees and the wider economy through enhanced connections and facilitating greater modal shift. There is a role for the future Garden Community masterplan to underpin the creation of a thriving, sustainable place around the Ashchurch for Tewkesbury railway station that includes development of future employment space (particularly uses with a high employment density, non-logistics or industrial, such as SMEs) to catalyse enterprising and economic activity, supported by the residents of the Garden Community and existing adjacent communities, which would ultimately deliver benefit to the wider SLP area.","Homes England broadly supports the approach outlined towards economic growth. In achieving sustainable growth, Homes England recommends that large employment allocations and major opportunities for growth are focused at main centres and adjoining large-scale development such as Tewkesbury Garden Community. It is noted that Tewkesbury Borough is identified as an area requiring particular growth in Use Classes B1c (light industry), B2 (general industry) and B8 (storage and distribution). The provision and location of Use Class B8 must be carefully considered, due to the particular requirements of this type of use (such as space, access and traffic impacts) to ensure it is located in appropriate locations on the transport network and planned in conjunction with other types of development. One of the benefits of the Garden Community is that it will be planned to integrate well with existing communities within Tewkesbury and will enhance regeneration and support existing centres, while also providing substantial opportunities for planned employment growth. There is clear advantage in sustainability terms of locating the Garden Community development around key nodes such as the Ashchurch for Tewkesbury railway station. With high frequency rail services to Birmingham, Bristol and Cheltenham-arising from Network Rails’ proposals to upgrade services to a minimum of 4 per hour, there is opportunity for transformation. This will benefit not only the Church Farm site (submitted by Homes England in response to the SLP Call for Sites) but would also generate positive ripple effects for the wider Garden Community, in particular the adjacent existing employment areas due to enhanced accessibility and access to skilled employees and the wider economy through enhanced connections and facilitating greater modal shift. There is a role for the future Garden Community masterplan to underpin the creation of a thriving, sustainable place around the Ashchurch for Tewkesbury railway station that includes development of future employment space (particularly uses with a high employment density, non-logistics or industrial, such as SMEs) to catalyse enterprising and economic activity, supported by the residents of the Garden Community and existing adjacent communities, which would ultimately deliver benefit to the wider SLP area.","","Homes England considers that it is important that new development does not undermine existing town centres. Nevertheless, large scale development such as Tewkesbury Garden Community will require a proper, focused centre which is sustainable and accessible for residents. It will be important for the Tewkesbury Garden Community to provide a different character; a viable and deliverable mixed use centre comprising retail, leisure, education and play, which will complement the main town centre in Tewkesbury rather than undermine or compete with it. Whilst acknowledging that the Plan identifies the value of smaller centres, it is considered by Homes England that smaller, dispersed centres are unlikely to be appropriate for a Garden Community.","","To support delivery of the Tewkesbury Garden Community, and its ambitions as a new sustainable settlement, new and enhanced rail facilities are critical, including additional services to be provided to better connect the existing communities of Ashchurch and Tewksbury to locations further afield. Additionally, realignment of the existing A46 would facilitate the Garden Community development through providing ‘fit for purpose’ accessibility for a future community of the scale proposed. Homes England recognises the need to work closely with Network Rail, the OFFICIAL Councils, National Highways and the Department for Transport to develop these proposals and enable their delivery within the plan period. The scale of development proposed within the context of the Garden Community is likely to require a full range of social infrastructure, green infrastructure, public transport infrastructure, active travel connections and utilities / servicing requirements, delivered strategically to meet the needs of the future community. One of the key benefits of the Garden Community that is that it is of such a scale that it can support the delivery of new infrastructure and be self-sustaining, whilst also offering benefits to existing residents through potential off-site developer contributions (s106 agreements / planning obligations) and through required contribution of Community Infrastructure Levy (CIL) funding. It is acknowledged that both mechanisms are expected to be replaced by the forthcoming Infrastructure Levy (IL), once effective through means of secondary legislation. However, each mechanism could clearly support delivery of evidenced infrastructure requirements, including where these are set out in the new SLP Infrastructure Delivery Plan (once prepared). Within the context of the Garden Community, a strategic masterplan approach developed in collaboration with multiple delivery partners including Tewkesbury Borough Council, developers and the local community, will drive a comprehensive and integrated approach to infrastructure planning.","Further to the response provided to Question 24, a Concept Masterplan for the Tewkesbury Garden Community has been developed and Tewkesbury Borough Council is developing the Business Case in consultation with developers, including Homes England, to together establish the case for the infrastructure needed to support the Garden Community.","","Yes","","","","Homes England offers the following comments on the six development scenarios outlined: Development Scenario 1 – Urban Concentration: Whilst recognising the focus on efficient use of land within this development scenario, it is primarily targeting previously developed land and intensified development in Cheltenham and Gloucester. This approach would be less appropriate for Tewkesbury and would not provide the level of housing need identified in the plan for Tewkesbury Borough of approximately 10,000 homes. Consequently, this scenario does not fully reflect of the requirement in Tewkesbury to use sustainable greenfield sites to meet the housing need. The delivery of Tewkesbury Garden Community would complement the delivery of Development Scenario 1 in Cheltenham and Gloucester. Development Scenario 2 – Urban Extensions: Homes England considers that this development scenario reflects the aspirations for Tewkesbury Garden Community, which would effectively create an extension to the existing settlement at Tewkesbury and Ashchurch. This is simply because the Garden Town directly adjoins and will integrate with Ashchurch, Tewkesbury. This location benefits from a large existing area of housing at Ashchurch, a large industrial estate and main line railway station. Whilst separated from Tewkesbury by the M5 motorway, the Garden Town is functionally and spatially linked to directly to Tewkesbury and the many other facilities, services, retail, and employment areas in the town which are within 2-5km of the Garden Town. The Garden Community would reflect many items identified in the ‘pro’ list for this scenario, as an opportunity to create a sustainably located, high quality development adjacent to an existing rail station and with limited planning constraints. Further, it does not reflect the ‘cons’ identified for this scenario, as it would not represent loss of Green Belt land. Development Scenario 3 – Avoiding Green Belt: Homes England supports the aspiration to avoid Green Belt land within the district. It is considered that opportunities exist for large scale development, through urban extensions and the creation of Tewkesbury Garden Community, to significantly contribute toward meeting the Plan’s growth requirements without needing to utilise Green Belt or other constrained land such as that on the flood plain. Development Scenario 4 – New Strategic Settlement: it is noted that Tewkesbury Garden Town (or Community) is identified under this development scenario as one of the three comprehensive, masterplanned new settlements that it would seek to deliver. Homes England suggests, considering the other two locations identified under Development Scenario 4, that the Tewkesbury Garden Community is better situated under Development Scenario 2 as an urban extension. Unlike the other two locations, it would not represent a new, free-standing settlement in the open countryside. As set out under Development Scenario 2, the location of the Tewkesbury Garden Town location benefits from a large existing area of housing at Ashchurch, a large industrial estate and main line railway station. Whilst separated from Tewkesbury by the M5 motorway, this area functions and links directly to Tewkesbury and the many other facilities, services, retail, and employment areas in the town which are within 2-5km of the Garden Town. The Garden Town is therefore not a new Strategic Settlement but a Large Scale Sustainable Urban Extension to Tewkesbury at Ashchurch. Accordingly, the ‘cons’ identified for this development scenario within the Reg 18 Issues and Options Consultation Document: including, potentially not providing homes and jobs where they may be needed close to urban and rural settlements; the loss of higher quality agricultural land; OFFICIAL not supporting the vitality and viability of larger city and town centres; or being unlikely to provide for all the new homes and jobs, resulting in worsening housing unaffordability and constrained economic growth - are not as relevant to the Tewkesbury Garden Community given its proposed adjacency to the Ashchurch for Tewkesbury Railway Station and existing communities of Ashchurch and Northway, and associated employment land. Development Scenario 5 – Rural Dispersal: Homes England does not support this development scenario, which is not considered to align with the national and local planning aims of delivering sustainable development. Development Scenario 6 – Sustainable Transport Scenario: Homes England supports this development scenario and the ambition to deliver growth in sustainable locations. It is considered that Tewkesbury Garden Community should be referenced under this scenario, given that it would benefit from a sustainable location on the rail network, with potential to provide enhancements such as an extra platform, a rail line realignment and increased services per hour in both directions to a minimum of 4 per hour.","","","","[Q.1] It is acknowledged that a 15-year plan period meets the minimum Government requirements, and therefore a 15-year period is supported. Homes England acknowledges that the delivery of 10,000 homes at Tewkesbury Garden Community within 15 years would require much higher rates of delivery than recently experienced in TBC. Calculated from point of adoption from 2025, this would require approximately 666 homes built per year to deliver the Garden Community during the plan period. When compared to recent annual housing completions within Tewkesbury Borough Council (TBC) , this rate is a higher target rate of delivery than required for the JCS plan period, and indeed almost double the level that has been delivered in recent years (a total annual completion of 386 in 2021/22), with overall rates in TBC falling beneath target requirements since 2019. Homes England supports challenging delivery targets and boosting the supply of housing and considers that the proposed Tewkesbury Garden Community represents an opportunity to deliver housing at pace and scale. The SLP should set a positive policy framework for the Tewkesbury Garden Community to form the basis for joint working to enable the planning and delivery of the infrastructure necessary to support and unlock development. \nWe suggest that the strategic Vision and Growth Scenarios may be better situated within a 30- year strategic plan period, within which there are two 15-year periods for detailed plans, with 10,000 homes required within the first 15 years, and any shortfall or surplus carried over into the requirement for the second half of the plan period. This longer-term strategic timescale, supported by an update at the halfway point, is considered more appropriate for delivery of a major growth opportunity such as Tewkesbury Garden Community. The volume that the Garden Town could deliver at a strategic scale could significantly accelerate housing delivery and therefore achieve much higher rates of housing completions for TBC. Acknowledging the tests of soundness in plan-making, such an approach would be consistent with paragraph 22 of the NPPF, which states ‘Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery’\n[Q8.] Homes England supports the mandatory Biodiversity Net Gain (BNG) requirement, and comments that BNG would be delivered at a strategic scale, introducing multi-functional benefits for both the environment and future population within the context of the Tewkesbury Garden Community masterplan.\n[Q26.] Homes England considers that the Strategic and Local Plan should plan for the A46 realignment, which is essential to facilitate the Tewkesbury Garden Community. Homes England considers that opportunities for partnership working between developers and Department for Transport, including for the proposed rail bridge crossing the level crossing on the mainline (linking Northway and B4079) and the M5 J9 interchange, are critical to further support the delivery of the Garden Community. Investment should be prioritised into infrastructure for crossing over M5 and the rail line between Tewkesbury town and the proposed Garden Town."]
["Local Councillor","",20,"No","Since Gloucester City and Cheltenham Borough are predominantly urban (urban with city and town) and Tewkesbury Borough is predominantly rural (largely rural), it is clear that the balance between housing, infrastructure, community facilities and the environment (natural, built and historic) is different for the two urban local authorities and the rural local authority. What are Gloucester and Cheltenham delivering under their duty to cooperate with Tewkesbury, while Tewkesbury must deliver without limit?","No","Most of the Draft Vision is about urban areas. What is the Vision for rural areas? If the SLP is for 20 years, the vision should extend to 2046 (not 2041).","No","How do the Strategic Objectives encourage residents to live near to where they work to improve sustainability?","Modifying Flood Zone 3b (functional floodplain), or defining a new flood zone, to allow for climate change and avoid developing areas that will require huge future investment in flood defences. Local authorities appear to be ignoring the predicted rise in sea level that will affect Gloucester and the Severn Vale.","Low energy costs.","","No","No","","Public transport, roads that are not liable to flood, education, health, retail.","Yes","Large windmills or solar farms are unlikely to be accepted. The Severn Estuary (for tidal energy) is not within the SLP area. That leaves batteries for energy storage.","No","If the local authorities do not use the Standard Method, someone else (UK Government and developers) will. For the reasons below (Q13), the local authorities should find another method that is a better fit for the two predominantly urban authorities and one predominantly rural authority.","Yes","For the SLP, following the Standard Method will justify the expansion of Gloucester and Cheltenham major urban areas into Tewkesbury Borough, the predominantly rural area. Since the land availability in Gloucester and Cheltenham cannot meet the projections assumed for them (based on past growth), this will fall on Tewkesbury to provide, with few brownfield and mostly greenfield sites available. The 5 year land supply will continue to be the major issue. Areas such as the Severn Vale floodplain and Cotswolds AONB are not suitable (or sustainable) for development, so all that remains is land between Gloucester, Cheltenham and the other urban centre, Tewkesbury. The Garden Town and Cyber Park are examples of this. What is missing is the infrastructure: roads, rail, etc. By 2100, will all three urban areas be continuous? Is that the Vision? Is it sustainable?","Yes","It is clear, from the projections, that the growth in households required is greater than the growth in population. Thus the need must be for smaller houses. Is this what is being built?","","","","","","It would depend whether the rural employment is: (a) employment in rural areas; or (b) employment due to the diversification of agricultural businesses. The Vision does not make that clear. If it were (b), the amount of additional employment would be limited.","The city and town centres have already changed. Much of the shopping has moved away or online. What is the Vision for these centres?","It is too late for villages and rural areas that have already lost their shops.","Roads, cycle routes and footways. Interconnections instead of breaking links.","There is only one mentioned, with 4000 new homes. This is smaller than Bishop's Cleeve (Service Centre) but it would have better access to the M5 and the rail network. New settlements should not repeat the mistakes of the extending a much smaller village.","See the settlement audit for the JCS. The scoring system can seem odd and should be reviewed. Service Villages were not always selected according to their ranking. Why?","Yes","No","","Yes","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement","No","","About Strategy:\n1. Define the flood zone allowing for climate change. Should it be Flood Zone 4 or 3cc, or what?\n2. Unless a barrage is to be built across the Severn Estuary, provide the flood defences for the houses and businesses that have been built where it will flood by 2100.\n3. Stop building where it will flood in future, otherwise it cost a fortune that should be spent on everything else.\n4. Add or modify roads that are flooded regularly, isolating parts of the SLP area.\n5. Make it clear what areas are being protected, for example: because of flooding; and to protect the natural landscape. \n6. If limits are set for development in specific places, whether in the hierarchy or not, stick to those limits. How is development plan-led if the plan is always ignored?\n7. A strategic new settlement must have good links and infrastructure. It should not be located where it consumes valuable agricultural land or isolate (during construction or afterwards) rural settlements or partition rural parishes (into the new part and what remains of the old).\n8. What are Gloucester and Cheltenham providing under their duty to cooperate? It seems that the predominantly rural Tewkesbury is being consumed by the two major urban centres. Should the boundaries change to recognise this? If they did, should the growth of the predominantly rural Tewkesbury be equal to or less than the predominantly urban Gloucester and Cheltenham?\n\nAbout Bio-Diversity:\n9. Many sites are cleared of any natural assets before planning applications are made. 10% of zero is zero. How do the local authorities intend to preserve bio-diversity, never mind achieve a gain?"]
["Resident",null,"","No","I don't think any are unique but each community will need separate treatment. As in extra consideration for the people such as age, wealth, unemployment but also due to specific area concerns such as green belt and capacity of infrastructure.","Yes","","No","I personally don't think that point 3 is the best approach and I think the feedback should be consulted before a decision is taken. My view is that this option would lead to high density population which could relate to low standard of living and over capacity within our larger towns/cities. I would put forward that the best approach would be to the development of new towns where a complete masterplan can be formed on how a sustainable community can be formed with employment opportunities, mixed housing types and public transport development to link with surrounding areas.","Perhaps it could go further by putting forward that developments over a certain size should be built with solar panels or heat pumps/electric boilers. House construction techniques could also be put forward in the form of passive house.","","","Yes","No","","Public transport is key, the developments should push for moving away from the use of cars. Buses, trains, cycle paths should all be the top priority for interconnectivity.","Yes","Solar farms, ","Yes","","No","","","","","","","","","","We NEED to protect our town centres. I think we should not convert any retail spaces to houses unless extraordinary circumstances. Councils need to support local and small retailers is establishing shops, be it with reduced rates, pop-up shop, community retail use.","","Public transport","Public transport","","","No","","Yes","","Scenario 4: New strategic settlement; Scenario 6: Sustainable transport scenario","No","",""]
["Resident",null,20,"","","No","New developments should be based on the existing road infrastructure -  look at areas that are accessible by road, rail and cycles.","No","I understand TBC have to hit housing targets but the areas developed should be decided based on their accessibility to the larger towns of Gloucester, Cheltenham & Tewkesbury as this is where people will need to get to, to go to work.","Don't add more queuing traffic to already congested roads.  Encourage people to use the new cycle way from Cheltenham to Gloucester or consider building a cycle way from, say, Newent to Gloucester or something adjacent to the A40 from Longhope/Huntley/Minsterworth into Gloucester.","Use brownfield sites in the towns or bring disused buildings back into use.","As above.  Why keep building new houses when there are areas in the towns that look awful and could be spruced up for people to live, thereby negating the need for them to travel.","No","No","","Shops and places to work.  They are the reasons that people get into their cars.","","Maybe.  Depends on the site.","No","Because that figure is always changing. You should set a figure and stick to it.  These plans always seem to change and nothing is ever set in stone.","","I do not know because I did not do the calculation.","Yes","Bungalows for the elderly.  Elderly people are not going to sell a large detached house to buy a tiny house on a housing estate.  They would buy a bungalow with a garden.","","I don't know about this but I personally would not buy a house adjacent to a traveller community as I feel they would stick to their own community and not mix with the rest of the estate therefore no cohesion.","I really do not know, I have no knowledge of what these communities require.","Lower business rates to retain shops in the town centres.  Give small businesses incentives to employ people.","You need to encourage employment opps throughout the county, not just in the 3 large towns so that people do not have to travel. Too much congestion on the roads in rush hour, people in the Forest without a car have really limited job opportunities.  If they can get a job it will probably be in Gloucester or Cheltenham.  The queues on the A40 between 0700 and 0930 are quite ridiculous.  All those fumes going into the atmosphere.","Build some business parks like the one in Highnam to encourage locals to work there instead of driving into town.  Improve bus services to the 3 big towns, more frequency needed from Newent/Highnam into Gloucester.","Honestly, you need better bus services into the main towns. I no longer work in Gloucester as it was taking me 40 mins in the morning to get from Highnam to Quedgeley, a 5 mile trip. People do not want to sit in queues of traffic.  Or a park & ride somewhere around Churcham/Minsterworth.","Get people to use them instead of driving to the supermarkets all the time. Support some sort of discount scheme and where there is a Post Office do something to support the Postmaster.","Transport links/roads/cycle ways.","As above.  You cannot build large developments without widening existing roads or putting on more buses. If you built 3000 houses at Churcham the queues in the morning would honestly be ridiculous.  A 3rd bridge across the River Severn is what is needed in this area so that traffic south of Minsterworth e.g. Lydney area does not have to travel north to cross the river at Over to get to Gloucester/Quedgeley/Berkeley.","Loss of good agricultural land is a problem.  The PM talked recently about the need for farmers to keep producing food to feed an increasing population so you cannot keep building on the fields.  Transport links. Flooding caused by loss of fields for drainage.","No","Yes","I think it is best to build in small pockets next to existing small towns like Cinderford, Lydney, Newent.  A few hundred houses in each area and a small business park/school/shop is what you need, not these massive housing estates where thousands of people go to live. You would get more of a community with smaller developments.  That development at Hare Hill at Cheltenham is insane!  My friend says it takes 10 minutes to get out of the estate in the morning.","No","I don't feel they are detailed enough, rather brief.","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario; Scenario 5: Rural dispersal","Yes","Newent, if the bus service to Gloucester is improved.  AND the Newent bus to Ross on Wye needs to be reinstated along with a bus to Ledbury.  People need to be able to travel to work, unless you are going to do the small business park thing in situ.","I strongly feel that instead of asking opportunistic landowners to put land forward you need to start by identifying the areas that can take development according to their existing or planned transport links and the job opportunities that can be created in those areas.  You would not build on land miles away from a main road, common sense, so why not start with the areas that are suitable to develop and then ask landowners if they want to sell.\n\nFlooding is a major issue on the B4215 at Malswick.  Today it has rained heavily again all day and it is flooded at Malswick.  I expect in a few days the A417 at Maisemore will be closed due to flooding so the traffic from Hartpury/M50 will be diverted down the B4215 which adds to the congestion.  You will have to sort out the flooding in this area before you consider building more houses.  Thousands more houses along the B4215/A40/A48 needs a lot of thought.  There is limited employment in Highnam, Churcham, Huntley, Minsterworth so all these people will need to travel to work. The vast majority will travel to Gloucester, Cheltenham, maybe Bristol, along the A40.   I suggest the areas to build are adjacent to the 3 big towns and along the M5 - your road infrastructure is already there."]
[null,null,null,"2.4 d covers the conservation and enhancement of the natural environment but does not specifically mention biodiversity.  Nature recovery should be covered as a strategic issue.",null,null,"Sports facilities, flood management and biodiversity have been lumped together.  Feels like a bit of a strange combination.  In my opinion it would be better to unpick that paragraph. It's an ok vision but it is the same really as every other Local Plan vision.  It could be about anywhere. Would be good to see something like this - A catchment approach will be taken to flood risk management. Natural flood management will be a priority, with urban watercourses greened and buffers promoted along rural watercourses.  Features such as permeable paving and raingardens will be commonplace in urban areas, there will be more tree cover, and wetlands areas will be expanded.  The delivery of multifunctional benefits for people and nature will be prioritised, with watercourses at the heart of a green infrastructure network.  ",null,"I would like to see an objective around design to allow children (of all ages) to play.  85% of UK children are not getting enough exercise.  Children become less active with each year of primary school.  And girls do less than boys.  This is going to be a physical and mental health epidemic within this plan period - if it is not already.","By requiring new development to be carbon neutral, promoting district level renewable energy and heating, and then rolling out retrofitting in existing housing stock.  E.g. new development generating district level renewable energy is then required to hook up existing built environment to their system.  E.g. better grants to retrofit.  This would be innovative and requires proper join up between planning and other arms in the council.",null,null,"Yes","Yes","Carrant Brook should be a priority green corridor.  Delivery of BNG to increase it's value for wildlife, including birds such as curlew and others coming up from the Severn Estuary SPA.  Natural flood risk management should be delivered here, including the creation of wetland areas.  The proposed developments at Mitton and in the area formally known as the Garden Town will put pressure on the brook and should be required to deliver this green corridor.  It should be whoppingly big, to actually deliver it's function.","Schools and green spaces.","No","No, because would not want to stifle schemes coming forward in other locations.  New development should be required to wash its own face, and deliver wider community benefit.  How it does that it up to the developer.",null,"Sustainability around social and environmental limits needs to be a key consideration in reaching the right figure.  Not after the number has been decided.",null,null,null,null,null,null,null,null,null,null,"There could be a case for more town centre housing.  Residents to support the very local economy in the town centres, including night time economy.",null,"Green infrastructure and self-propelled modes of transport ie walking and cycling.","All infrastructure! They should be self sufficient as far as is possible.  15 minute neighbourhoods.  However linking into their surrounds.","Shops. Schools. ",null,null,null,null,"Pro's and con's for green space, GI and biodiversity look a bit slim.","Scenario 1: Urban concentration; Scenario 6: Sustainable transport scenario",null,null,"[Q.8] Yes.  However, I believe DCLG is now saying this needs to be justified.  Could the need for natural flood management be part of the justification?  Certainly larger developments should do more than 10%, 10% is pretty paltry and we're talking about a plan in place for many years.  Well until the next review!\n\n[Q.29] The layout of the questions means a lot of scrolling up and down to remind what the options are - bit of a mare! Option 1 - support, but need to ensure not building on greenspace. Option 2 - I don't support the extensions around Tewkesbury.  Avoiding the watercourses and floodplains is leading to a development pattern a bit like spokes on a wheel.  The new development is too far away from the town centre and shouldn't count as a sustainable urban extension.  I expect the same is true for Cheltenham and Gloucester.  Option 3 - worse!  Green belt is a 'strategic' designation to prevent town/cities from merging.  I don't think that is still a valid argument, with the amount of housing we need.  Also development between Cheltenham and Gloucester could be quite sustainable, re transport. Option 6 - yes I think this option has legs."]
[null,null,null,null,null,null,null,null,"I would like to see incorporated the need to review continuously developments that have been approved to check that they met the goals at the time approval was given.  We see small scale developments in Churchdown to which objetions had been made, and now the properties have been built they do not fit with the surrounding properties and are not selling.  We should learn from past mistakes",null,null,null,null,null,null,null,null,"Within the three areas covered by this strategic plan we do not seem to have much in the way of renewable energy generation or storage.  Maybe some of the large fields around Tewkesbury and between Cheltenham and Gloucester could be used for building solar panels, and some of the higher parts of the area such as Cleeve Hill could have wind turbines built on them (I am guessing that Robinswood and Churchdown Hill would be too small due to the nature of their landscape and the risk of birds being injured)"]
["","",30,"The areas covered are comprehensive but we need to consider how they can effectively be delivered and not simply tick them off a list - currently the notion of CIL paid by developers for housing projects is failing to make a dent in the needs of the local community in churchdown for healthcare, transport congestion, sustainable transport and education to name a few. I would like to see it expressly called out that housing developers need to BUILD facilities for the community not just throw some money at the problem.","","Yes","","No","I would like to see these expanded upon to cover not just what but how. For example, the recent development of the cycle spine through churchdown to Cheltenham is laudable, but has been managed in a sub-optimal way by contracting in lots to different contractors, meaning that the sequencing of works appears almost random and, at times, there have been several sections of works led by different contractors taking place in close proximity, leading to poor traffic circulation. Work could potentially have been completed much quicker had it been contracted to one contractor and delivered to an accelerated timetable. I assume the approach taken was to spread the cost across several years' budgets, but this has had an undeniably negative effect on the community. It has also turned people off to what was a very good idea, which is a shame. Furthermore, I would have liked to see more engagement with the community on how the project could have linked up to local areas. I occasionally use the new cycle route and it's good - but getting to it down the narrow and busy roads of churchdown is a nightmare.\nAs for building, despite the words in previous vision statements that sound very positive, we see more houses going up, more cars on roads and absolutely no new school places or GP capacity. Also the few retail premises we have in the community are closing down and neglected by landlords.","Protecting green belt land as much as possible. Rejuvenating community parks and play areas. Incentivising the planting of woodland with nature trails to encourage public access. Provide funding and/or support for the location of community environmental projects such as a zero waste (refill) shop.","Ensuring new development is done sensitively e.g. houses not packed together with little green space between them.","Reduced administration and barriers to development for repurposing existing buildings. Exploring council powers to take over neglected commercial properties from absentee landlords and let them out to community projects or businesses that would benefit communities.","Yes","No","","GP, school, groceries, recycling point, public transport, cycle routes.","Yes","geothermal, battery storage","Yes","","","","","","No","","avoiding already built up areas to discourage potential sprawl when sites are busy.","","","","Offer grants for small business start ups. actively seek out diversity of tenants and businesses so that the town centres have more to offer than coffee shops and betting shops.","I understand new powers are being explored via High Street Rental Auctions - a measure in the Levelling Up and Regeneration Act aimed at tacking long-term empty shop units in town centres. Could this be used in rural settings? Churchdown has very few active retail units for the size of the village, but several long term disused units that are being allowed to go to rack and ruin by an absentee landlord. I know of several people that would be itching to take one over if it were to be properly maintained and let at a fair rate.","GP surgery capacity - it is extremely difficult to get an appointment in Churchdown, through no fault of the surgery team. School places - particularly primary.","an additional school per X number of houses. Make the developers build it on their land, not just throw some money at the council who can't magic up some land to build a school on. Evidence that GP and healthcare facilities exist to cater for the increased capacity before permission is granted to build.","capacity of roads (especially as standing/queuing traffic generates significant localised pollution), plus school places and GP/healthcare capacity as above.","Yes","","","No","Urban extensions - the \"cons\" fail to mention that this is - already - causing loss of identity of village locations becoming part of the urban sprawl of adjacent cities and losing their rural appeal. Furthermore, existing development in Churchdown has, to date, failed to add any capacity to vital local services and infrastructure (schools, healthcare, roads) but rather increased pressure on them.\nSustainable transport - this scenario fails to acknowledge the inertia that most people possess when it comes to adopting sustainable options such as public transport or cycling (other than by necessity i.e not being able to afford a car). Driving is easier and more convenient and so will always dominate unless there is some express means of disincentivising it and incentivising sustainable options. Under this model, without such a platform to change behaviours, the \"sustainable corridors\" would just be even more gridlocked than they are today with larger numbers of estates spilling cars out onto the same roads.","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 1: Urban concentration; Scenario 4: New strategic settlement","","",""]
["Statutory/Specific Consultee","Gloucestershire County Council","","Green Infrastructure","N/A","No","I would like to see greater emphasis on Nature on the Doorstep and Green Infrastructure throughout. It needs to be one of the core areas such as Digital Growth or Housing. Biodiversity is too far done the paragraphs.","No","In point 4. there should be mention specifically of \"Green/Blue Infrastructure\" - there have been cycle schemes recently which have missed opportunities to design cycleways for people and a green corridor for nature. ","All new development must be designed to be liveable without car ownership. Maximising the urban trees in development and improvement works, as well as green/ blue infrastructure such as raingardens as traffic calming, working as SuDS to add flood resilience.","Highest standards of energy efficiency. Heat pump for heating as Standard (some developers are making this their own standard already). A vegetated back garden, as well as front, to encourage new home owners to connect with nature, and for a wildlife habitat for declining nature.","There should be planning incentives for developers to retain and reuse existing buildings such as discounted planning fees and free pre-application advice.","Yes","Yes","The Gloucester Docks in planters, Shirehall in planters, neighbourhood fruit trees across the city/ towns, and more street trees and wildflowers in new rain gardens in streets across the SLP area.","Local convenience stores, pubs, youth clubs, community centres, local parks, local cycleways and traffic free byways/ active travel routes, community allotments, orchards and trim trails and woodland/ wildflower areas.","Yes","Retrofit existing buildings first, all council houses, public buildings, schools etc. If you need help micrositing onshore wind, let me know/ get a bat assessment.","","","","","","","","","","Rural jobs, agroecological jobs, agro-environment surveyors and farm advisors, cycle champions/ active travel officers, new rights of way officers/ countryside rangers, green urban champions and community support officers (accessibility for all)","There needs to be strong vision for a new green and leafy vision for the urban areas. Nestled in a very leafy area, there should be no disconnect entering the urban areas. That and low carbon transport to rival European cities.","More training in agroecology/ agroforestry, more training in agro-schemes farm advisors.","More trees, and rain gardens and wildflowers/ growing spaces.","Greater active travel routes to them, better signage and advertising.","Green and Blue infrastructure and car-free options. SuDS.","New town facitities on the doorstep so no need/ reduced need to drive. New parks and habitats for nature. New allotments. Overland SUDS and water (ponds and lakes).","Does it have existing services? Is the new location on a nature recovery network route and would this affect connectivity for nature.","Yes","Yes","A mixture of all of the scenarios once consultation with emerging LNRS over the best areas to not impact nature recovery and nature connectivity.","No","There could and should be a mixture of these scenarios based on the best place for new houses/ nature recovery.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","","","I do not see any supporting study and mapping for where the green/ blue infrastructure should go."]
["Statutory/Specific Consultee","NHS Gloucestershire Integrated Care Board",15,"","","","References to healthy places and healthy neighbourhoods in the draft vision statement is supported. We would welcome a more specific health reference in the sentence, ‘Growth will have been supported by the provision of a range of essential digital, transport, community and other infrastructure.’","","In respect of the draft objective, ‘Delivering well designed, beautiful and safe places,’ we support the focus in point 2 of ensuring that new development is integrated well with existing communities and providing well-located infrastructure which meets the needs of communities. In respect of the draft objective. ‘Promoting healthy and resilient communities, in point 1. We would suggest health facilities to be specifically added to the list contained within the delivering new developments that are supported by the necessary social and community infrastructure, including….’ We support the ambition that new developments create high quality living environments and prioritise health and mental wellbeing.","","","","","","","","","","","","","","","","","","","","","","In respect of Town & City Centres, we welcome involvement in the strategy for their futures and the role of health in supporting plans. For example, exploring the future provision of health care in Cheltenham Town Centre. Based on February 2024 primary care appointment data, the average Gloucestershire practice of around 10,800 patients generates around 50,000 face to face appointments per year, which could help add vibrancy in local town centres through increased footfall and use of brownfield sites/ conversion of existing buildings.","","In respect of Town & City Centres, we welcome involvement in the strategy for their futures and the role of health in supporting plans. For example, exploring the future provision of health care in Cheltenham Town Centre. Based on February 2024 primary care appointment data, the average Gloucestershire practice of around 10,800 patients generates around 50,000 face to face appointments per year, which could help add vibrancy in local town centres through increased footfall and use of brownfield sites/ conversion of existing buildings.","Regarding the reference that new homes and employment will need to have new infrastructure, for example schools, roads, public transport, health services, and recreation provision and that these will need to be funded through central and local government funding streams and contributions from developers.","","","","","","","","","","[Background & Context] NHS Gloucestershire Integrated Care Board (NHS Gloucestershire) is responsible for planning and buying services to meet the health needs of local people and at April 2024, serves 690,744 registered patients.\nIt also brings partners together in the ‘One Gloucestershire Health & Wellbeing partnership, to ensure the county’s NHS provides the best possible care. It works alongside social care, public and other public, voluntary and community sector organisations ensuring a joined-up approach to health and care as part of an overall Integrated Care System.\nFrom this health and care perspective, the spectrum of service provision covers the following main areas:\n• Primary care -including GP practices, dental practices, pharmacies and optometrists.\n• Community health services- including district nursing, health services, clinics and therapies, Rehabilitation and inpatient care and minor injury and illness Units\n• Mental health services including assessment and crisis prevention, treatment and care and inpatient specialist services.\n• Acute/ secondary Care including diagnostics, specialist medical treatment, surgery and care and accident and Emergency departments.\n• Social care including fostering and Adoption, social care assessments and support, domiciliary care supporting people where they live and carer assessments and short breaks.\n• Ambulance services, including 999 call handling, ambulance and. paramedic attendance and care.\nFrom a health infrastructure perspective, the main points are as follows: -\n• Gloucestershire Hospitals NHS Foundation Trust (GHFT) operate from two main acute hospitals sites located in Gloucester & Cheltenham with some provision at Community Hospitals and Health Centres (e.g., community midwives).\n• Gloucestershire Health & Care NHS Foundation Trust (GHC) operating from over 140 facilities including seven Community Hospitals, two mental health inpatient units and a variety of clinical (e.g., Health Centres and GP practices) and non-clinical buildings.\n• 64 different GP practices operating from 83 buildings (some practices collocating together in the same building and sometimes also including staff from GHC/ GHFT.\nThe two Foundation NHS Trusts, each has an Estates Strategy. There is also a GP Premises Development & Delivery Plan covering the period up to 2031, which is overseen by NHS Gloucestershire ICB. At the time of writing this letter, the ICS is developing an overarch 10 year strategy, which is due to be completed by the end of July 2024. These plans can be shared with the Strategic, Local Plan Team to support the development of plans.\n\n[Q1.] NHS Gloucestershire broadly welcomes the strategic direction set out in the consultation document. It is noted that the National Planning Policy Framework (NPPF) defines that Strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for community facilities such as health. Additionally, that plans should look ahead at least 15 years.\n\n[Q4.] In respect of section 3- the draft vision and objectives, we support the concept of ‘placemaking’ in both the role of health shaping the design and quality of local environmentsalong with the suitable service provision. The key objective around Identifying andfacilitating infrastructure needed to support development, and reference to health;particularly, GP surgeries, is welcomed.\n\n[Infrastructure.] In respect of infrastructure, we fully support the requirement that Plans should set out thepolicy requirements for the contributions expected from different types of development andwhere necessary, from different sites for health and that plans should seek to ensure thetimely provision of the infrastructure required to support the level of development proposed.\nIt should be noted that the challenges for the local NHS will be around availablediscretionary capital and it is expected that there will be significant reliance on development contributions to fund their fair share of the health infrastructure requirements resulting from additional housing.\nIt is noted that over the 20 year period, potentially there could be a combined requirementof 35,700 homes using the standard formula for the three District Councils. We assume fornow, an average household size of around 2.19 people. So, a further 78,183 people.\nSome of our plans, such as the GP Premises Development & Delivery Plan are alreadyconsidering housing developments up to 2031 (including Section 106 and CILcontributions). It is assumed some of these developments are included in the figures in the document. However, it will still be necessary to consider needs arising from residual development through the IDP. Our recent meeting to discuss this was welcomed and I look forward to working with the SLP team on this as the Plan progresses.\nIt is noted that the consultation document is the first step in the preparation of the Strategic, Local Plan. We note it is an opportunity for NHS Gloucestershire to set out key issues, concerns or opportunities and the following are key points to consider as we continue to contribute to plans: -\n• The local NHS will need development contributions from housing developments resulting from the Local, Strategic plan, to help fund infrastructure requirements for these new populations due to a lack of capital.\n• Infrastructure requirements are likely to impact across all sectors (primary, community, acute and ambulance).\n• Development contributions are expected to be actual payments and/ or in kind (e.g., site provided free of charge and contribution offset against agreed commercial value.\n• Infrastructure solutions likely to be a mix of extensions and improvements to existing buildings and new facilities.\n• We are keen to take an integrated approach working with partners to deliver agreed community, health, education and wider wellbeing requirements.\n\n[Scenarios] The different scenarios are likely to require different health care infrastructure requirements.\nFor example, new strategic settlements of no less than 4,000 dwellings are likely to lead to new facilities to accommodate the entire development. Whereas a much more dispersed model of development is more likely to require a focus on the extension of existing facilities, subject to available site capacity. For example, in Gloucester, surgery sites at Cheltenham\nRoad, Longlevens and two sites along Stroud Road are very unlikely to be able to be developed further for any significant increases in population. For some sites (such as Kingsway surgery) there are also implications relating to Stroud District Local Plan e.g., Huntsgrove extension, Whaddon and Hardwicke. In some areas, such as Bishop Cleeve, additional expansion space should be available to commission."]
[null,null,"","","","Yes","","No","In response to objective 6: As you deliberate on urban development plans, I urge you to prioritise strategies that avoid building on Green Belt land. Preserving these areas is crucial for mitigating climate change and maintaining biodiversity.\n\nGreen Belt land serves as a vital carbon sink, absorbing carbon dioxide from the atmosphere and helping to reduce greenhouse gas emissions. Moreover, these natural areas provide essential ecosystem services such as flood control, water purification, and habitat for wildlife.","","","The plan should introduce measures and standards the prioritises the retention and reuse of existing buildings to promote sustainable development and preserve cultural heritage. This was done excellently with the buildings of the quays. \n\nThe plan could courage the retrofitting of existing buildings to improve energy efficiency, reduce carbon dioxide emissions and enhance sustainability. Council should offer incentives for implementing green technologies.","","Yes","Parton Farm, Land to the West of Gloucestershire Airport (CHU015). This farm land is clearly in the green belt land. \n\nFarm land can provide habitats for a diverse range of plant and animal species. By conserving these areas we can promote biodiversity and support wildlife populations. \n\nThis farm land can also mitigate flood risks by absorbing excess water and reducing run off. Protecting farm land, particularly green belt can contribute to effective flood management. \n\nFurthermore, farm land that is adjacent to the busy A40 golden valley can help mitigate air pollution by acting as a barrier to filter pollutants.","Hospitals, health centres and schools.","Yes","It would be good to consider sites for renewable energy, e.g wind farms and solar farms to clearly indicate what land is planned to be used for.","","","","","","","Yes","","Traveler communities should avoid Green Belt land to preserve valuable natural habitats, protect agricultural land and maintain landscape aesthetics. This approach helps conserve biodiversity, support sustainable agriculture, and uphold the integrity of rural landscapes for the benefit of current and future generations.","","","The strategic and local plan should encourage rural employment by providing support for small businesses and start ups in rural areas. The infrastructure of rural areas, e.g transport links, internet etc. should be improved to attract businesses to these locations. This in turn would provide more job opportunities for young people and reduce the amount of people who have to commute from rural locations to seek work, such as the vast number of people who have to commute to Gloucester and Cheltenham from the Forest of Dean.","","","","","","Yes","","","Yes","","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 1: Urban concentration; Scenario 5: Rural dispersal; Scenario 4: New strategic settlement","","","Preserving land around Gloucestershire Airport should be of significant importance. Having open space around the airport helps ensure safety of aircraft operations and allows the availability for emergency landings in the event of aircraft malfunctions. \n\nThe green belt land surrounding Glouceatershire Airport serves as a natural buffer that mitigates the noise generated by aircraft operations protecting the locals nearby in Churchdown."]
["Statutory/Specific Consultee","Woodmancote Parish Council",15,"There needs to be a far better system to review and update sections of plans to keep them relevant. This review and update process should be a policy in itself.","Specific housing need especially around affordable housing\nConstraints and management plans to \n•\tconserve/enhance landscapes, \n•\tmaintain/improve biodiversity and \n•\tmanage the increasing flood risk. \nCharacter Assessments and design Codes\nLocalised knowledge of infrastructure issues\n","No","The vision needs to be set in context of the need to be adaptable because the area will face significant change over the next period especially if green growth, climate change and restoring biodiversity are going to be at the heart of it. \nThe strategic objectives need to be far more specific rather than a wish list of generalisations. \nThe biggest issue in planning is that the presumption in favour of development effectively means that all the strategic objectives are compromised from the outset because its developer led and not plan led.\nParagraphs 2 and 3 are firmly linked. The plan covers areas that area mix of urban deprivation and comparative wealth. Young people – even those on above average earnings struggle to buy a property and renting is also becoming increasingly unaffordable. This forces the young into certain areas – quasi ghettos which defeats the core objective.\n•\t3.3 c) needs to be far more wide reaching to look at the way our residents will both live, work and play now and into the future. This means that the nature of jobs and working patterns will change as will modes of transport.\n•\t3..3 f) needs to differentiate between affordable houses as currently defined and genuinely affordable houses in particular for those working in the delivery of public services.\n•\t3.3.j) needs to look at other infrastructure too including the engineered flood measures and surface water drainage including natural flood measures. However more crucial is the interdependencies of the different types of infrastructure that needs to be considered effectively and not to repeat the issues of the past by managing each of these independently.\nThe strategic Objectives should also start by protecting our current tree population and biodiversity position from ruthless developers whose sole focus is to deliver profit to shareholders.\n2nd or holiday homes are a problem across the cotswolds because they push up prices making houses even more unaffordable. Ultimately this means employers in those areas can’t get staff because its too expensive for them to live there.","No","Include adaptability and a properly integrated approach as a key part of the vision and objectives. \nGenuinely affordable houses ie where people working on average wages eg in the public sector can live happily is a core target. \nSaying that building houses 20% below market value in areas where the affordability ratio is 8+ is the answer are wrong. Then saying we need to build 25% more houses than we need so we can bring down prices and therefore make housing more affordable is flawed thinking. It makes no sense to focus the whole plan on building far more houses than we strictly need on the basis that as a result we will end up with more affordable houses. Similarly, if we build more houses, more people will move into the area – because they can – but if the employment growth is not there – the occupants will be longer distance commuters. This in turn drives up the demand for infrastructure. \nNew Development is not the only objective and the SLP must create the right incentives to address the sixth carbon challenge identified : that every current house needs £10k  to upgrade it and this will produce UK jobs as long as we manufacture the solar panels, wind turbines, heat pumps etc in the UK. This is a major challenge and will not be addressed if we are forced to focus on building new houses we probably don’t “NEED”.\nWhat the data really tells us is that the housing we have is or will be the wrong housing for the future, both in terms of location, size and energy efficiency.  Therefore this should be the focus ie convert what we have if practical and demolish and rebuild if its not practical to convert.\n","The SLP needs to make the climate change challenge provisions “must have’s” and not nice to have’s. For example, \n•\thighways are prevented from recommending refusal unless there is a severe road safety impact. The policy should be that all new development must be in sustainable locations and Highways should be required to state when a location is / is not sustainable IN REAL TERMS. Saying that children walk over a kilometre to school or adults will walk home 1 kilometre with their shopping is simply not realistic. A Car dependent location or areas where public transport is impractical for education, commuting or food shopping purposes are NOT sustainable. \n•\tSurface water flood risk is better addressed by prioritising AONB and Green Belt land to the implementation of natural flood measures and building off site biodiversity net gains.\n•\tThe plan needs to prioritise the enforcement abilities to ensure that landscape and drainage plans are fully implemented and maintained by developers.\nIt also needs to “plan” to set aside land and designate its use to natural flood measures and biodiversity.","These could easily require new development to be designed to work with the landscape rather than contrast against it. Design codes could require any development outside “decent sized villages” with established settlement boundaries, to blend into the landscape and genuinely conserve and enhance it. The current legislation kind of says that but the real application of these provisions is that planning officers allow development that does not materially harm the landscape in isolation. There is a very big difference in these 2 positions. The plan needs to make developers design new types of accommodation that achieve the goals.\nIn an area at risk of pluvial and fluvial flooding, houses may need to float as they do in Netherlands.","Don’t allow new car ports when there is an existing outbuilding that could be re-used. \nKeep agricultural buildings for conversion to hydroponics and not into residential.","Yes","Yes","All AONB and Greenbelt. Specifically:-\n•\tLand below Rising Sun pub that went to auction a few years ago\n•\tLand adjacent to Two Hedges Road in Greenbelt\n•\tThe Mill on Stockwell Lane – especially the stream in front of it but also the 11 acres behind\n•\tChris Hinton’s land on Lockwood Farm – already carried out extensive natural flood measures with WPC and GCC’s flood team\n•\tBarnfield on Stockwell lane has implemented natural flood measures and biodiversity with Gloucestershire wildlife trust \n•\tThe Old donkey Sanctuary on Gambles Lane may have opportunities and a willing owner\n•\tUpper Bottomley Farm may have opportunities and a willing owner\n•\tSpecial Landscape area below Butts Lane all the way to the railway line\n•\tWoodland adjacent to Gambles lane at the top that is neglected by overseas owner. TBC could take action under Riparian Rights and then cease land to pay for works?","Bus services, cycle routes and walkable footpaths that are genuinely safe and accessible 24 hours a day.\nHub and Spoke frequent bus services for work/school are a priority.","","Only small scape hydro generation at the waterfall opposite Washpool as part of a natural flood measure project","No","The current SLP is based on an economic forecasts that is flawed\n•\tFirstly its based on a country wide forecast dated 2014 that uses a fertility rate of 2.1 when the real rate is 1.6 and life expectancy of 87-88 when the current life expectancy is 81-82. Therefore, the whole premis of the forecast starts out wrong.\n•\tThe jobs forecast is also flawed. The document uses 3 different forecast methods and goes into a lot of detail about the reasons why the results vary from a need of 3000 houses to 30000 houses from 2021-2041. The highest forecast acknowledges that its based on more government jobs and a lot of other optimistic assumptions. Personally I don’t believe Government has plans to dramatically increase its workforce in Gloucestershire. Like all businesses, the drive is to increase productivity and achieve a lot more with the same workforce – not employ more people. The forecast mentions high levels of productivity in Gloucestershire but then appears to ignore the fact that more economic activity may not mean more jobs because that economic activity is delivered through increases in productivity. Software development is a great example of this.\n•\tThe data used is pre Ukraine war and cost of living crisis. This has squeezed household incomes and and driven up inflation both of which is damaging economic prosperity. \n•\tThe forecast recognises that there will be more elderly people living alone or as couples and overall household size is falling. It does not take into account the need for more social workers, nurses and police nor does it consider the number of teachers leaving that profession. In essence the modelling is out of date and not adaptable.\n•\tFinally and by no means least, out of the 3 methods considered, the forecaster selected Cambridge Economics forecast and the reason was because it generated a forecast that was closer to the previous forecast level and not because of a logical reason.\nTherefore the standard method generally uses history as a predictor of the future and the selection of the highest forecast appears based on bias and because everyone believes we need more houses and this is something planning teams can do. \nHowever, the changes ahead set out the vision and objectives clearly illustrate that it the past will not be a good predictor for the future. The collapsing birth rate, rapidly aging population and the need to address the climate calamity our children will have to deal with illustrate this point clearly. \nAs for applying a 25% multiple to the housing need (already based on flawed logic) because we have double the affordability ratio is just making the whole planning process more ridiculous and means everyone will be focused on building the houses we don’t need rather than addressing the real problem.. \nThe SLP needs to be based on a far more realistic housing need which is also based on a realistic forecast of job creation after fully taking account of the productivity improvements that have to take place if the economy is not going to implode. We suspect the lower forecast of the 3 is probably far more accurate and we should implement a continuous review process of these underlying forecasts and adapt the plan if we have underforecast. \nThe SLP also needs to look far more closely at the specific types of jobs that will exist and what those jobs will be paid. Then using the suggested multiple of 4 – how can the SLP deliver affordable housing for those people. We suspect a new breed of housing associations will be required to acquire land develop it and rent it out with a very long term view.  \nIf the SLP is not obsessed with chasing a fictitous housing need that only suits developers, it can build a plan that focuses on repurposing existing buildings first and then build new houses. Critically these need to focus on the ones people can afford.  \nThe jobs vs housing requirement needs to be reviewed every 3 years and based on data that is a maximum of 6 months old.","Yes","Repurpose existing buildings, split other properties, look at commercial/residential mixed development in cities and large towns.  \nIf we have establish demand for particular public services, then we need to not just build a hospital but we have to consider the whole ecosystem and in particular where does the labour come from and where will they live and what will be the property affordability whether rent/buy.","Yes","As above, the SLP should look specifically at the jobs it believes it is going to need to fill that cannot be housed by re-purposing existing stock and build these dwellings only. The concept of a local authority being governed by a 5 year land supply that is based on flawed modelling of out of date data is a very very poor approach.","No","It’s not easy and until such time as travellers earn community trust there will always be resistance to allocate land for temporary accommodation for residents with a more transient lifestyle. \n\nFirst and foremost, all communities should contribute to the community if they want the community to provide for them. Specifically, the individuals in traveller communities need to be subject to the same rule of law as the rest of the population and this should extend to the following areas:-\n•\tPay taxes and council tax\n•\tRespect planning enforcement\n•\tChildren attending school\n•\tNo antisocial behaviour or criminal activities\n•\tRespect for other residents\nWe want diverse communities but that can only take place when all emrace a principle of mutual respect. That can also include communities with a nomadic lifestyle but not at the expense of the other communities that are embracing diversity.","As above. WPC has a park homes area that is closely managed and kept clean and tidy and the residents are well integrated into the community of Woodmancote. The community has agreed to the extension of this site under the master plan but no specific planning has been proposed. ","Aging population is drawn to the SLP area because it’s a nice place to be elderly and active. Of course having moved here, the elderly soon become more elderly and less active. This drives up social care and healthcare needs. \nTeachers can’t afford to live in Cheltenham and yet it has some of the best schools in the country.","Capitalise on the cyber legacy (per NCSC) and the green/environment/sustainable energy research","The first and most important change would be to de-prioritise millionaire homes and second homes in the countryside  to the bottom of the pile and accept that these might provide profits for rich housebuilders and some jobs but does not contribute to the housing need. The SLP does not need to make any space for these developments – they will create their own space without anyones help.\nAgriculture is not carried out in traditional ways any longer – its far more mechnaised/productive. To address climate change we need to grow more food for direct consumption rather than to feed livestock (Sixth Carbon Budget) . A significant increase in the % of our consumption to plant based foods is a target of the Sixth Carbon Budget means that localised manufacturing/processing near the fields which process grains into the food we want to buy in supermarkets is required. \nWe also need to grow more for biofuels and this also requires manufacturing/processing. The SLP needs to consider rural employment more seriously as an industrial sector that needs help to build an ecosystem. This would allow for a mix of both scientific, entrepreneurial and skilled agricultural labour in these fields and it would be houses for these people that should be besed in the countryside.. \nWe could be focused on renewable energy and vertical agriculture as the modernisation of the market gardening sector. \nWith Cirencester Agriculture and innovative entrepreneurs like Green Fuels owner James Hygate or james Lloyd-Jones of JFC -Vertical Farming company. \nPlanning should be easy to secure for any genuine project as long as it is in itself sympathetic to the countryside and has a low environmental adverse impact.  \nBuilding houses on agricultural land makes no sense. If we constrain the business of developers to make easy money from agricultural land, they will have to work harder to make money out of densificiation of urban areas and repurposing existing housing stock to meet the changed housing needs. \n","Accessibility is key. There needs to be a clear hierarchy:-\nWalking is top of the last. We have a world expert on walkable cities living in Cheltenham www.walk21.com and yet they do all their work in Europe and South America where their expertise is valued. The key here is to prioritise walking in all respects ie wide pavemnets that are well lit and are secure makes them safe and welcoming. \nThe bike/electric scooter comes next but users of these need to behave responsibly and reckless and dangerous use should be policed and enforced rigorously.\nBuses are essential especially for the elderly and infirm but to be effective you cannot have routes that take an hour to do a 20 minute journey. They should be built around commuting because this prevents car parking disasters.\nIf you want shopping in town centres and tourism, then you will have cars and they all need to park. This needs to be space efficient and so Vertical Parking systems should be closely considered.  https://www.nytimes.com/2014/10/25/automobiles/a-ferris-wheel-for-cars-and-trucks.html. Whilst these are manned, that should not deter the SLP team because it is also providing jobs. Existing small lots in the city centres can increase their capacity 10 fold.","Encouraging farm shops and allowing them to sell a more diverse range of goods not just from their own farm but also from the local economy would be a good idea. Encouraging other rural craft that make and sell things would also be good. A somerset example is the farming of Willow and local manufacture of Willow furniture and baskets. This would help drive the more localised ecosystem.   ","The obvious ones are Schools, social care, roads, buses, trams but also cycling routes and walkable routes. \nHowever what is forgotten is the need to manage more and more surface water run off. It is totally unacceptable to grant planning for housing and allow the developer to discharge into storm drains that are operating at capacity or the combined sewer which then becomes overwhelmed and the utility company is allowed to discharge into watercourses. The entire system has suffered from such under investment it’s a mammoth task to address it with engineered solutions. New development needs to be located where it neither floods nor causes flooding for other downstream. \nNatural flood Measures need to be prioritised in all of our AONB and Greenbelt so the pressure is relieved further upstream. To achieve this there will need to be support like farmers subsidies. The problem is that its land speculators that own much of this land and they just want to sit and wait for planning to build houses. Designate the land as Flood Risk Betterment so no housing can be built on it.","Environmentally friendly public transport that is quick and reliable for commuting purposes especially if the purpose of the development is to provide employees to the nearby city/town.\nProvision for elderly to go to local GP and hospital appointments\nWalking and cycling for all school runs\nMore localised shopping for food but an understanding that economical shopping is still at the supermarket and you need a car.","This is the wrong question. To avoid rural settlements becoming commuter villages, what services and facilities do you need to prevent them becoming commuter towns or full of second homes/millionaire mansions and instead facilitate them maintaining a balanced community with a blend of young families, people working from home, working in local businesses (including modern agriculture), teachers, social workers, nurses as well as commuters.","Yes","Yes","Do NOT use high flawed forecasts to create a phantom housing need but focus the entire planning process on delivering targetted genuinely affordable housing for the jobs the area really needs to fill. Then review growth and housing need every 3 years to review and revise the plan if required.","No","Scenario 1 presumes too much in its assessment of “Cons”. Specifically increased density does not necessarily mean that \n•\tthe setting or heritage assets would be compromised\n•\tclimate change mitigation could be achieved because lower car use and super energy efficient buildings using sustainable materials and incorporating their own renewable energy generation and rainwater harvesting/grey water management.\n•\tIt’s the smaller size which is more affordable and may not need to be owned that is likely to be the housing need\nYou just need to make sure that the proposals are led by the planners and not the developers and their banks. The planners should come up with the plan and its up to the developers to make it work for them.\nFor this scenario to work, the SLP needs to appreciate that developers must not be allowed to make easy money from green field development but will have to innovate and adapt to deliver whats required.\nThis scenario does not need to mean the heart of Cheltenham – it could mean a major focus on redeveloping Whaddon.\nScenario 2\nThere is major political challenge here. However,the primary concern from residents is that the SLP team are really proposing a salami slicing approach which will ultimately destroy all the Greenbelt. If this is considered the only way to achieve a genuine and real housing need - especially for those on average pay that need genuinely affordable houses, then the plan must be to simultaneously invest 1)in those parts of the green belt to build exactly what is required at the same time as 2)converting the remaining greenbelt into natural flood measures to manage surface water flood risk effectively for the urban area it protects as well as bio-diversity havens.  The designation of the Greenbelt will then have 2 additional statutory purposes as natural flood measures and off site biodiversity net gains.\nScenario 3\nThis effectively means that places like Bishops Cleeve would have even more houses stretching out towards Stoke Orchard. The real Con is that planning so far has been so very very short sighted and only focused on hitting the housing target without investing in infrastructure – the failure to plan provision for more school places is top of that list and a monumental embarrassment and failure of local government.\nThis could also be combined with the investment in the Green Belt area for natural flood measures and biodiversity in exchange with environmentally friendly public transport to provide better connectivity to Cheltenham and Tewkesbury\nScenario 4  \nThe Garden Town in Tewkesbury is already part of the plan. This should be part of the solution but again it needs to achieve its target objectives properly and not just pay lipservice to it. To illustrate the point this Garden Town should probably be dominated by green roof design, grey water management, not rely on connecting to existing combined sewers but have new dedicated sewers for storm and foul direct to treatment plants with a network of surface water run off management from the entire development area and not just roof gutters\nConnectivity does not mean you can drive into the towns. Similarly to call it a garden town, it should be innovative in the way it delivers significant outdoor space and garden environment in a sustainable way. Planners should look at places like Vaxjo. https://www.greencitytimes.com/vaxjo/#:~:text=V%C3%A4xj%C3%B6%20was%20the%20first%20city,a%20fossil%20fuel%2Dfree%20economy.\nScenario 5 \nThis the worst plan. First and foremost the idea of spreading development far and wide is by far the most damaging for the environment \n\nScenario 6\nCons do not address the fact that it would essentially mean continuous ribbon development which is a wholesale salami sliceing of every part of the Greenbelt ultimately leading to the destruction of the Green belt purpose. \nIt satisfies public transport needs only but fails in almost every other respect.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement","No","","The Woodmancote NDP has only recently been approved. The SLP team need to work with the teams of communities with NDPs to make sure that their plans are reviewed and updated simultaneously with the SLP and ensure that nothing becomes out of date."]
["I work for a charity or volunteer in the area","Gloucestershire Local Nature Partnership","","","","No","We are very pleased to see the emphasis on nature recovery and responding to climate change, as shown in, for example paragraph 3.3 and in the introduction to the consultation document.  \n\nThis echoes two of Gloucestershire Local Nature Partnership’s main strategy themes, on Nature Recovery and Climate Resilience. \n\nIt would therefore be good to see the language of nature recovery and biodiversity expressed more explicitly in the text of the Vision.  \n\nFor example, paragraph 1 of the draft Vision could also reference nature recovery: “Growth will have afforded the highest possible quality of life for all, in a manner which achieves carbon reductions, addresses the causes and effects of climate change [and supports nature’s recovery].” \n\nIn paragraph 3 of the draft Vision, instead of “to ensure our valuable green spaces and highest quality farmland are preserved” this could use wording more similar to:\n\n“to ensure high quality habitat, priority nature recovery zones and wildlife corridors, valuable green spaces and highest quality farmland are preserved\" \n\nAnd, in paragraph 5 of the draft Vision, you could refer to \t“…a network of [biodiversity-rich] green spaces and waterways…” \n\nThere is also potential to add aims about opportunities to improve existing urban areas, particularly the more deprived areas with the Gloucester, Cheltenham and Tewkesbury areas, to the Vision statement.","","It is really good that the first draft Strategic Objective is:\n\n“Meeting the challenges of climate change.”\n\nIn relation to Part 1 of that draft Strategic Objective on climate change:\n\n“1.  Ensure that growth contributes to decarbonization through reduced reliance on fossil fuels and achievement of biodiversity net gain; and the delivery of zero and low carbon development that is resilient and adaptable to climate change incorporating measures to aid urban cooling and biodiversity such as green walls and tree planting.”\n\nThis text is in strong alignment with Local Nature Partnership strategy and the biodiversity theme of Climate Leadership Gloucestershire.  Green infrastructure is important to help with adaptation to climate change.  Tree, hedge and shelterbelt planting will be important for shade as average temperatures rise, and also helps carbon sequestration  and urban drainage.  It would be good to align tree planting plans with the Gloucestershire Tree Strategy (which is also due to be updated soon).  \n\nThe Climate Leadership Gloucestershire biodiversity theme also recommends exploring the carbon capture and storage potential of creating wetlands and wet woodlands, including identifying sites for such habitat creation and working with the Environment Agency on this .  This would be good to include in the strategy for the Strategic and Local Plan area. In relation to Part 6 of the Strategic Objective on climate change:\n“6. Ensure development is located in areas that are not liable to flooding, considering the implications of climate change, making effective use of sustainable drainage systems and natural flood management techniques.  Ensure that existing infrastructure is adequately protected from the threat of flooding, and that existing flood defences are protected and enhanced.” Development should certainly be avoided in the floodplain, as climate change will exacerbate current flood risks and patterns, due to increased rainfall, sea level rise and more extreme weather events.  Full use should be made of Sustainable Urban Drainage solutions.  Natural Flood Management should be embedded as a core component of flood management response, especially as it brings additional nature recovery and river restoration opportunities .\n\nThe draft Strategic Objective: \n“Making as much use as possible of brownfield land and conserving and enhancing the natural and historic environments”\n\ncould be strengthened by making more explicit reference to nature recovery.  For example, the phrase “supporting nature to recover” could be used, as it is in paragraph 4.1 of the consultation document.  \n\nPart 2 of this draft Strategic Objective on natural environments:\n“2. Conserving, managing and enhancing the area’s unique natural environment and biodiversity, including its waterways, Sites of Special Scientific Interest, the Cotswolds National Landscape, and areas of landscape and biodiversity importance, and maximising the opportunities to use land to manage flood water” Currently Gloucestershire does not have sufficient high-quality habitat to halt the ecological emergency, so the Nature Recovery Network mapping developed under Gloucestershire Local Nature Partnership https://naturalcapital.gcerdata.com/  describes the priority opportunities to create new habitats, extending from and connecting existing high quality habitat, as well as maintaining the quality of existing high quality habitat.   \n\nTherefore, part 2 of this draft Strategic Objective could also use language such as “extending” as well as “conserving”; or talk about maximising opportunities to create and extend new habitat in Nature Recovery Network priority zones.\n\nThe Strategic and Local Plan should have regard to the Local Nature Recovery Strategy, when this is finalised for Gloucestershire, which should be in early 2025.  One role of the Local Nature Recovery Strategy is to be a guide to the areas where offsite Biodiversity Net Gain should ideally be focused, for the most benefit for nature recovery.  The Strategic and Local Plan policy should require offsite biodiversity net gain habitat creation to be as close as feasible to development sites, and within the combined local authority boundaries of Gloucester City, Cheltenham Borough and Tewkesbury Borough.\n\nThe guidance on developing Local Nature Recovery Strategies says:\n“8. The government intends for local nature recovery strategies to inform the local planning process.  Local planning authorities must have regard to them in complying with the strengthened biodiversity duty.”  \n\nPart 2 of this draft Strategic Objective on natural environments could also reference Key Wildlife Sites/ Local Wildlife Sites as sites to be conserved and managed. Part 3 of this draft Strategic Objective on natural environments:\n\n“3. Ensuring developments support green infrastructure and improve existing green infrastructure within urban and rural areas to provide movement corridors for people and wildlife”\n\nIt is very good to see the reference to ensuring high quality Green Infrastructure in part 3 of this draft Strategic Objective, which fits with GLNP strategy to integrate high quality green infrastructure through the planning system.\n\nNatural England Green Infrastructure standards published in 2023 and the Gloucestershire Green Infrastructure Framework published in August 2022 should be used in the development of green infrastructure designs and plans .\n\nIn the draft Strategic Objective:\n“Promoting healthy and resilient communities”\n\nIt could be good to emphasise that part 5 of this applies to existing communities as well as new developments, and you could add “access to nature”, that is:  “5a. Ensure that all homes have useable functioning amenity space [and access to nature] that allows residents the opportunity to live, work and relax outside”\n\nYou could also consider whether you would like this objective to be prioritised towards those communities suffering from health inequalities due to being in currently more deprived areas, such as those areas in the lowest 20% of the index of multiple deprivation.  It is vital for the health and wellbeing of our population that we enhance and increase green spaces near to where people live.\n\nFurthermore both GLNP and Climate Leadership Gloucestershire have an aspiration that everyone lives within 15 minutes walk of accessible biodiversity rich green space.\n\nThey have also agreed that Gloucestershire should use future iterations of Local Plans to help deliver Natural England’s Accessible Natural Greenspace standards (ANGSt), one of the key measures of this being people having a natural green space of at least 2ha within 300m from home.  \n\nTherefore both GLNP and CLG would support the inclusion of:\n‘5b. To support plans which help to deliver our aspiration that that everyone lives within 15 minutes walk of accessible biodiversity rich green space.","","","","","","Nature Recovery Network mapping and Ecosystem Services mapping developed under Gloucestershire Local Nature Partnership can be seen at https://naturalcapital.gcerdata.com/  . \nThe Nature Recovery Network mapping describes the priority opportunities to create new habitats, extending from and connecting existing high quality habitat, as well as maintaining the quality of existing high quality habitat.   \n\nThe core, high and medium priority Nature Recovery Network zones could be referenced in relation to paragraph 4.12 of the consultation document, as the priority areas to project from development and to promote for creation of high quality habitat for nature recovery. The Ecosystem Services mapping highlights opportunities for water flow regulation, local climate regulation, air pollutant removal, recreation, education, interaction with nature; and baselines for carbon storage and food production. The Gloucester Nature Park initiative should continue to be supported, to increase and improve people’s relationship with nature, and also for tree planting and to improve flood water flow.\n\nEarly work on ideal broad wildlife corridors in the Local Nature Recovery Strategy process has identified.\n\n1. The need for any new development proposed between Tredington/ Stoke Orchard and Bishop’s Cleeve to incorporate measures to create effective East-West wildlife corridors in the development design.  This would help deliver a broad wildlife corridor envisaged by Buglife’s B Lines, https://www.buglife.org.uk/our-work/b-lines/  to be insect pathways running through our countryside and towns with plants that are pollen and nectar sources.\n\n2. The potential biodiversity benefits of linking woodland habitats in north Tewkesbury borough to Bredon Hill in Worcestershire, as Bredon Hill is so valuable for many rare species including violet click beetle.\n\nThe Climate Leadership Gloucestershire action plan recommends supporting and liaising with relevant river catchment partnerships, which would help further identify land for environmental purposes.","","","","","","","","",null,"","","","","","","","","","Proposals for a Garden Community in Tewkesbury borough are already being developed. We would urge you to make this a once in a generation opportunity to be truly visionary in planning a new approach to sustainable living with a development design that is in harmony with the landscape, prioritises broad wildlife corridors, creates high quality habitat for wildlife as an integral part of of the development, and strongly involves the local community in the design. When creating wide wildlife corridors it would be ideal to design these in the context of the wider Nature Recovery Network map, with a broader aim of connectivity with those core habitats.  The design of the Garden Community is an opportunity to achieve the design aims and actions listed in paragraph 4.15 of the consultation document in the table about Climate Change, with actions in relation to the Built Environment, Natural Environment, Movement and Renewable Energy.  ","See answer to 24. Proposals for a Garden Community in Tewkesbury borough are already being developed. We would urge you to make this a once in a generation opportunity to be truly visionary in planning a new approach to sustainable living with a development design that is in harmony with the landscape, prioritises broad wildlife corridors, creates high quality habitat for wildlife as an integral part of of the development, and strongly involves the local community in the design. When creating wide wildlife corridors it would be ideal to design these in the context of the wider Nature Recovery Network map, with a broader aim of connectivity with those core habitats.  The design of the Garden Community is an opportunity to achieve the design aims and actions listed in paragraph 4.15 of the consultation document in the table about Climate Change, with actions in relation to the Built Environment, Natural Environment, Movement and Renewable Energy.  ","","","","","","","","","[Q.8] In general terms Gloucestershire Local Nature Partnership would be supportive of efforts to require greater than 10% biodiversity net gain. \n\nHowever we are aware that this would need to be rigorously evidenced in relation to demonstrating more than average historical biodiversity loss.  If there is appetite to scope and research this then Gloucestershire Local Nature Partnership would be happy to discuss this. In any case, wording such as requiring “at least 10% biodiversity net gain” can be used, and a policy could be set that welcomes additional biodiversity net gain in relation to any individual development and does not allow developers to trade any “excess” biodiversity net gain beyond 10% created through a particular development, to count towards biodiversity net gain for other developments. \n\n[The Local Nature Partnership also submitted a pdf map of Gloucestershire B-lines Buglife]"]
["Local Councillor","Vice Chair and Architect",60,"These are all very laudable objectives, but how development is to be meaningfully and appropriately delivered on the ground in any location is of great importance.\nThere is no provision for master planning in any locality. It is a concern there will be a mismatch between high level assessment of the SLP and the delivery of clear and  meaningful development at community level.","The traffic on the B4215 which passes through Highnam. \nThis is a 'B' Classification Road, but due to the bridgehead status of Gloucester with through traffic and commuter traffic converging from easterly and westerly directions, the A40 Northern Bypass frequently becomes congested. This traffic passing around Gloucester dissipates in a westerly direction largely onto the B4215, which is too narrow a road to safely take the volume of traffic using the highway, with inadequately designed and unsafe footpaths for pedestrians.\nThe traffic is busy throughout every day and comprises the full range of commercial, business, public service and private vehicles. What needs to be recognised is that this road not only serves the growing communities west of Highnam, being Newent, Ross-on-Wye and the surrounding area, including the M50, but also further afield.  It has become a major trunk road for vehicles originating and completing their journeys from a south westerly direction beyond Swindon, the M4 and Oxford, to the River Severn bridgehead at Gloucester, with destinations in Herefordshire, and further afield into Wales. The B4215 in used in preference to the A40, as it is less undulating and a more direct, linking with the M50 at a motorway junction. \nFor those wanting to travel by rail from Gloucester station and travelling from the West, they largely pass through Highnam along the B 4215.\nThis is a route under pressure and which is also vulnerable. Whenever the A417 is closed, due to the A 417 being closed, due to flooding from the River Severn breaking its banks, or the M5 closed due to accidents, the B4215 is impacted, resulting in queues and tailbacks through the village at times gridlocking the community.\nThe A40 Gloucester Northern Bypass also floods periodically making emergency access for emergency service vehicles to Gloucester and Cheltenham impossible.\nWith the ‘missing link’ highways development improvement work between Crickley Hill and the Cowley Roundabout on the A417, as well as connecting with the M5, more traffic will be funnelling along the Northern Bypass around Gloucester heading Westwards towards Herefordshire and Wales, adding further traffic to the B4215  through Highnam.\nThe Highways authority have not engaged with this problem, but it needs to be addressed and considered in the emerging Strategic & Local Plan.","Yes","It is difficult to argue with the Draft Vision. The challenge is how to deliver the aspiration? The vision sounds utopian and whilst supporting the aims, the method of delivery on the ground in a comprehensive manner is the challenge and needs to be addressed.\nIt would be appropriate for the vision to be longer than 15 years. There are several reasons for this:\nWe are living in a rapidly changing world technologically, with increases in population, greater diversity, major demographic changes, along with with considerable political, socioeconomic and environmental challenges.\nA strategy is required which looks at the long term, say 60 years; the midterm, say 30 years and the short term, say 15 years, which has been referred to earlier. The short term is the SLP which will be revised in time, but at each revision it is adapted according to changing priorities in the mid to long term. Also, with each re-examination the mid and longer terms stretch out proportionally. \nIt is crucially important to have a longer perspective. The longer term provides important context especially for infrastructure projects and particularly in an age with Carbon Neutral targets, global warming with some of the highest levels of migration in history and worldwide government fiscal challenges. ","Yes","Items 1, 3 and 5 have been absent from developments granted planning approval around the village Highnam in recent years. New development needs to be granted alongside a provision for appropriate social and community facilities, including schools, open space, playing fields, with green and blue infrastructure. All these aspects enable a community to thrive, enabling community cohesion and sustainability. Such facilities along with successful infrastructure provision can only be delivered with local neighbourhood or master planning.  This kind of Local Planning needs to be an integral part of the Strategic Local Plan.","Climate Change is happening and it is becoming an everyday reality.\nThe best way the Strategic and Local Plan could be most effective is as a facilitator to work with other agencies to create a comprehensive set of policies which together have impact and become effective.\nFrom the viewpoint of the Parishes close to the Severn Vale, flooding is a major consideration and is already having a deleterious impact on Highnam. There are those properties directly affected which flood, whilst all the communities are affected by the lack of appropriate roads, drainage, maintenance and adequate highway infrastructure. The increase of traffic on an inadequate road infrastructure on the A40 and B4215 is exacerbating the problem.\nIf we are to become less reliant on cars, properly considered public transport systems which are affordable, convenient, reliable and operate at times when passengers need them are essential. Unless the appropriate services are in place to meet people’s needs, transport services will not and cannot be properly utilised. \nThere seems to be a belief amongst governing authorities that people will change their behaviours by force, through cost penalties or making using cars undesirable. A better, more popular and successful strategy would be through inducements and transport systems which actually work better than the conventional reliance on cars. \nThe present provision for the use of bicycles through cycle lanes is eating up financial resources and space, to such an extent that in certain localities up to a third of the highway is taken up with dedicated lanes carrying proportionally far fewer riders than the highway carries car drivers and passengers.\nCycle lanes are however a positive innovation, but they have to work and are not a panacea for low carbon transport. Too many road users; HGVs, the disabled, emergency service vehicles, longer distance travellers, van drivers and tradesmen etc., are excluded from using bicycles and dedicated cycle lanes create only a very partial solution to the problem of polluting traffic and global warming. \nWith the current public sector strictures on finance and investment in the community, there has been an increasing reliance on the private sector to pay more towards public infrastructure and services. There is a tilting point beyond which the private sector cannot and will not pay to supplement the funding of public projects. Their motive of the private sector has to be profit: the higher the financial burden and the tighter the imposed strictures, the poorer will be the private sector product, as with modern estate housing, alternatively development will stop all together. \nThe emerging Strategic & Local Plan should be a facilitative document, enhancing and supporting communities to thrive as beautiful places to live. All the necessary facilities should be made available to emerging communities through a comprehensive and well considered set of policies. ","","","Yes","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","[Q1] 60 - The vision needs to be longer than 15 years. There are several reasons for this: We are in a rapidly changing world with considerable political, socioeconomic and environmental challenges.\nA strategy which looks at the long term, say 60 years; the midterm, say 30 years and the short term, say 15 years would create a better policy making process. The short term is the plan which will be revised in time, but at each revision it is adapted according to changing priorities in the mid to long term. Also, with each re-examination, the mid and longer terms stretch out proportionally.\nIt is important to have a longer perspective. The longer term provides important context especially for infrastructure projects and particularly in an age with Carbon Neutral targets, global warming, some of the highest levels of migration in history and worldwide government fiscal challenges. \nGCHQ, University of Worcester and other organisations look at the World through different prisms and their analytical input and insights over a longer period would prove useful.\nIf the Plan is only for 15 years, the effective period will be shorter as it gradually becomes outdated. This was was the situation with the last Plan. Rather than making a wholesale revision, it would be better to take a more global view of direction over a longer period to run alongside and inform the short-term plan.\n\n[Q8] Whilst biodiversity is important and the loss of wildlife habitat and plant species significant, care has to be taken how restorative action is taken. \nThe causes of the reduction in biodiversity are complex and targeting development and setting a 10% target might be inadequate. This alone without comprehensive policy covering all sectors of the economy will not achieve the desired results. It may have the effect of stifling much needed balanced development for employment and providing homes for people to live in. Planning policy needs to be mindful of the complexities involved and the risk of unintended consequences of poorly informed and executed policy decisions. \n1\tThe Consultation Document Questionnaire\n1.\tThere are a number of problems with the Regulation 18 Document and the Consultation Document Questionnaire. It appears that the Questionnaire has been compiled without sufficient market testing, or awareness of how easy it is for respondents to complete. There is also some question about how useful or relevant the submitted information will prove to be. The successful canvassing of public opinion requires specialist expertise and it is evident the exercise has been undertaken with inadequate specialist advice and skill. The likely consequence is the exercise will not produce the quality or volume of response hoped for, and therefore as a consultation exercise it will fail and not deliver on its intent. \nThe following points are some pointers where the Questionnaire is flawed:\n1.\tFinding the Regulation 18 Document and Consultation Document Questionnaire.\n1.1\tThe first challenge is to find the relevant website. Any individual member of the public needs to be aware of the existence of the website in the first instance and then source the website address.\n1.2\tWhen entering the site, it is not easy to immediately understand how to navigate it and where to look for information.\n1.3\tTo find the Regulation 18 Document is complicated. (The title of the document is not self-explanatory and may also be confusing to the lay person). It takes 5 separate stages and link pages to reach the Regulation 18 Document and the same number of windows to find the Consultation Document Questionnaire.\n2.\tQuestion numbering \n2.1\tThere are 31 questions. These are numbered when referred to in the Regulation 18 Document, but the numbers are omitted in the Questionnaire, which makes cross-referencing difficult.\n2.2\tThe Question titles and the questions themselves, including the yes/no answers, between the Regulation 18 Document and the Questionnaire, do not always tally, requiring further cross-referencing and effort. \n3.\tCompleting the Questionnaire.\n3.1\tTo answer the different questions, the Regulation 18 Document has to be referred to. Ideally two screens are required, but few people would have two screens or two computers to view the Document and Questionnaire simultaneously. Short of having two screens, the process involved would involve constantly having to navigate between two documents on line, repeatedly going backwards and forwards opening and closing the different documents for every question answered.\n4.\tSaving the answers\n4.1\tAnswering the questions and referring back to the Regulation 18 Document is a time consuming and energy sapping process. To not be able to save questions once answered, is problematic. Few people will have the time to answer the questions at one sitting, with the result that there is a risk of the answers being lost if the Questionnaire page is accidentally closed down, or the computer requires rebooting. \n\nOn Monday 4th March 2024, with 10 days left for the consultation period, for a total combined population in Cheltenham, Gloucester and Tewkesbury Council areas of 346,200 people, (Taken from the Office of National Statistics), the main Questionnaire has only had 38 participants. 19 people have responded to the Strategic Objectives, 25 to the Draft Vision, 17 for questions addressed to 13 – 25-year-olds and 58 to questions for young people. By any standards, this is a poor response, which runs the risk of invalidating the entire consultation exercise.  \nBy the end of the Consultation period, when the website Consultation Portal was closed, only 105 responses had been received.\n\n2\tHousing for Later Life \n\nCurrently 1 in 4 people in the United Kingdom are over 60 years of age. By 2040 it is predicted over 6 million of the population will be over 60. By 2040, the proportion of people aged 60 and over in the United Kingdom (UK) is projected to increase significantly. According to the Office for National Statistics (ONS), the share of elderly individuals within the UK population is expected to reach 24.7%1. This demographic shift reflects the ongoing trend of population ageing.\nIn the United Kingdom, 23% of the population is currently aged 60 or over, which amounts to over 15.5 million people1. This demographic group plays a significant role in shaping various aspects of society, including healthcare, social services, and community engagement. Interestingly, the population of England is projected to grow by approximately 4.1 million (7.5%) by mid-2024. Among different age groups, the fastest-growing segment is people aged 65 and over, projected to increase by 20.4% over the next 10 years and nearly 60% over the next 25 years in England2. This is not just a UK phenomenon, bring the trend throughout most western countrues.\nThe challenges for later life living are multi-faceted. There is no one solution for any age group, but a variety of solutions is recognised to be the answer. There is no doubt that more of a new type of house needs to be built, known as a ‘house for life’, to keep us all as we age in our houses for longer. This along with more independent living and active care is not only necessary, but urgently required, and the need for such housing is growing.\nWhen existing housing is examined, for the 66 + age group, half of all households are living in underoccupied properties. If nothing is done to rectify the situation it will result in 4.5 million homes by 2040 being underoccupied. This is a huge waste of a rare resource, so it is important for Local Authorities to make appropriate provision for later living accommodation in their policy planning. \nAs we look ahead, understanding the needs and contributions of our older population becomes increasingly important for creating inclusive and supportive communities. The need to help those over 60 to remain active and/or productive economically, physically and socially has never been more pressing. It is recognised the Planning System is a major instrument to facilitate appropriate housing for later life living. It is also widely recognised the categories of C2 and C3 designations are not working and are providing obstacles for the provision of retirement and older living accommodation.\nWith the demographic changing throughout the country and especially locally, the new Strategic and Local Plan provides an ideal opportunity to take a strategic view and introduce measures to make adequate provision for later living in the future. This is applicable for all three Authorities, but particularly Tewkesbury Borough.\nSome Local Authorities are already introducing new housing strategies for later life. The authorities recognised as making useful progress are notably North Yorkshire County Council, Sunderland City Council and Central Bedfordshire Council, and they have achieved this by working in close collaboration with Housing LIN, along with other organisations such as the Housing and Ageing Alliance (HAA), who are partially government funded, who are an acknowledged authority, have joint research programmes with universities are undertaking ongoing research in the area.\nHousing LIN have considerable experience working with local authorities in developing planning strategies and policy. They would be a useful source of advice and assistance in developing the Strategic & Local Plans. Their contact information is: \nHousing LIN, C/o PRP, the Ideas Store, 10 Lindsey Street, Clerkenwell, London EC1A 9HP\nChief Executive - Jeremy Porteus – \nEmail: info@housinglin.org.uk"]
["Statutory/Specific Consultee","Highnam Parish Council ",60,"These are all very laudable objectives, but how development is to be meaningfully and appropriately delivered on the ground in any location is of great importance.\nThere is no provision for master planning in any locality. It is a concern there will be a mismatch between high level assessment of the SLP and the delivery of clear and meaningful development at community level.","The traffic on the B4215 which passes through Highnam. \nThis is a 'B' Classification Road, but due to the bridgehead status of Gloucester with through traffic and commuter traffic converging from easterly and westerly directions, the A40 Northern Bypass frequently becomes congested. This traffic passing around Gloucester dissipates in a westerly direction largely onto the B4215, which is too narrow a road to safely take the volume of traffic using the highway, with inadequately designed and unsafe footpaths for pedestrians. \nThe traffic is busy throughout every day and comprises the full range of commercial, business, public service and private vehicles. What needs to be recognised is that this road not only serves the growing communities west of Highnam, being Newent, Ross-on-Wye and the surrounding area, including the M50, but also further afield. It has become a major trunk road for vehicles originating and completing their journeys from a south westerly direction beyond Swindon, the M4 and Oxford, to the River Severn bridgehead at Gloucester, with destinations in Herefordshire, and further afield into Wales. The B4215 in used in preference to the A40, as it is less undulating and a more direct, linking with the M50 at a motorway junction. \nFor those wanting to travel by rail from Gloucester station and travelling from the West, they largely pass through Highnam along the B 4215. \nThis is a route under pressure and which is also vulnerable. Whenever the A417 is closed, due to the A 417 being closed, due to flooding from  the River Severn breaking its banks, or the M5 closed due to accidents,the B4215 is impacted, resulting in queues and tailbacks through the village at times gridlocking the community.\nThe A40 Gloucester Northern Bypass also floods periodically making emergency access for emergency service vehicles to Gloucester and Cheltenham impossible.\nWith the ‘missing link’ highways development improvement work between Crickley Hill and the Cowley Roundabout on the A417, as well as connecting with the M5, more traffic will be funnelling along the Northern Bypass around Gloucester heading Westwards towards Herefordshire and Wales, adding further traffic to the B4215 through Highnam.\nThe Highways authority have not engaged with this problem, but it needs to be addressed and considered in the emerging Strategic & Local Plan.","Yes","It is difficult to argue with the Draft Vision. The challenge is how to deliver the aspiration? The vision sounds utopian and whilst supporting the aims, the method of delivery on the ground in a comprehensive manner is the challenge and needs to be addressed.\nIt would be appropriate for the vision to be longer than 15 years. There are several reasons for this:\nWe are living in a rapidly changing world technologically, with increases in population, greater diversity, major demographic changes, along withwith considerable political, socioeconomicand environmental challenges.\nA strategy is required which looks at the long term, say 60 years; the midterm, say 30 years and the short term, say 15 years, which has been referred to earlier. The short term is the SLP which will be revised in time, but at each revision it is adapted according to changing priorities in the mid to long term. Also, with each re-examination the mid and longer terms stretch out proportionally. \nIt is crucially important to have a longer perspective. The longer term provides important context especially for infrastructure projects and particularly in an age with Carbon Neutral targets, global warming withsome of the highest levels of migration in history and worldwide government fiscal challenges.","Yes","Items 1, 3 and 5 have been absent from developments granted planning approval around the village Highnam in recent years. New development needs to be granted alongside a provision for appropriate social and community facilities, including schools, open space, playing fields, withgreen and blue infrastructure. All these aspects enable a community to thrive, enabling community cohesion and sustainability. Such facilities along with successful infrastructure provision can only be delivered with \nlocal neighbourhood or master planning. \nThis kind of Local Planning needs to be an integral part of the Strategic Local Plan.","Climate Change is happening and it is becoming an everyday reality. The best way the Strategic and Local Plan could be most effective is as a facilitator to work with other agencies to create a comprehensive set of policies which together have impact and become effective.\nFrom the viewpoint of the Parishes close to the Severn Vale, flooding is a major consideration and is already having a deleterious impact on Highnam. There are those properties directly affected which flood, whilst all the communities are affected by the lack of appropriate roads, drainage, maintenance and adequate highway infrastructure. The increase of traffic on an inadequate road infrastructure on the A40 and B4215 is exacerbating the problem.\nIf we are to become less reliant on cars, properly considered public transport systems which are affordable, convenient, reliable and operate at times when passengers need them are essential. Unless the appropriate services are in place to meet people’s needs, transport services will not and cannot be properly utilised. \nThere seems to be a belief amongst governing authorities that people will change their behaviours by force, through cost penalties or making using cars undesirable. A better, more popular and successful strategy would be through inducements and transport systems which actually work better than the conventional reliance on cars.\nThe present provision for the use of bicycles through cycle lanes is \neating up financial resources and space, to such an extent that in certain  localities up to a third of the highway is taken up with dedicated lanes  carrying proportionally far fewer riders than the highway carries car drivers and passengers.\nCycle lanes are however a positive innovation, but they have to work and are not a panacea for low carbon transport. Too many road users; HGVs, the disabled, emergency service vehicles, longer distance travellers, van drivers and tradesmen etc., are excluded from using bicycles and dedicated cycle lanes create only a very partial solution to the problem of polluting traffic and global warming. \nWith the current public sector strictures on finance and investment in the community, there has been an increasing reliance on the private sector to pay more towards public infrastructure and services. There is a tilting point beyond which the private sector cannot and will not pay to supplement the funding of public projects. Their motive of the private sector has to be profit: the higher the financial burden and the tighter the imposed strictures, the poorer will be the private sector product, as with modern estate housing, alternatively development will stop all together. \nThe emerging Strategic & Local Plan should be a facilitative document, enhancing and supporting communities to thrive as beautiful places to live. All the necessary facilities should be made available to emerging communities through a comprehensive and well considered set of policies.","","","Yes","","","","","","","","","","","","","","","","","","","","","","","","","","No"," There are pros and cons of each, some affecting Highnam more than others.\n1.Urban Concentration, this would involve increasing the density and height of the buildings within Gloucester and Cheltenham. This would rejuvenate city centres and use some unused previously developed sites.\nThis scenario would not affect Highnam unless the urban expansion did not produce enough houses etc.\n2.Urban Extensions, this option looks at extending all three towns/cities where this works best, an example of this would be Northway, Abbeymead, Churchdown etc.This may involve green belt areas.\nThis would mean public transport is more cost-effective, as these extensions can be easily supported from the centre. It may also produce nicer places to live, with lower densities.\nFrom the Highnam perspective, we should be protected by the river from urban creep of houses.\n3. Urban Extensions, this option is as no.2 but not involving the green belt. The green belt was agreed Nationally to manage urban growth and comes with National policies. The extensions in this would include the areas that were moved from the green belt when the JCS was written.\n4. New strategic developments and settlements, these are seen to be independent settlements with their own built-in infrastructure from the offset.\nThese typically will consist of 4000 houses as a minimum. Three options have been suggested in the SLP. Ashchurch has already been granted Garden Town status with a significant grant from central Government. It has employment opportunities with a new business park and easy access to the motorway.Boddington a rural area has been suggested, this falls between the M5 corridor and A38 so good road infrastructure to help with the development. There would be a loss of good agricultural land.\nThe third suggestion was the Highnam / Churcham triangle. This area has a poor, oversubscribed road network, not near any motorway junctions. The land and whole area is subject to frequent flooding with knock on effects to the neighbouring villages.\nPrime arable land would also be lost. This, third site, of this scenario is unsuited to this type of development.\nThis option only identifies land in the TBC area, and doesn’t share the responsibility with Gloucester and Cheltenham.\n5. The Rural Dispersal, option looks at the distribution of the housing requirement throughout the whole area, not just service villages and centres. This would enlarge existing communities, making them more viable in some areas, but for others, this would be over capacity for existing infrastructure and resources, like the schools, Drs etc. They would also lack a good transport network as this would not be cost effective.\nIn Highnam, being a service village development has already occurred and continues to receive development. It is already at the point of the infrastructure not coping with demand. The roads are too busy, the school is over capacity and local children have to travel fair distances to a school by car, as there is no public transport and they are too far to walk or cycle. This goes against developing a good carbon footprint, which has been agreed as a common understanding between Councils.\n6. Sustainable Transport option, this suggestion looks at development along existing / potential public transport corridors, including cycle routes and walking routes. The development is linked to areas of good transport networks, promoting more sustainable travel, and reducing carbon emissions from transport.\nThis option prioritizes housing and economic development in areas where travel choices can be maximized.\nThis option ticks the boxes for sustainability and reducing the carbon footprint. It can also be linked with the Urban extensions in a lot of cases.\nSummary\nThese options can not be seen in isolation and a mixture of some of the options may be the best fit. The Ashchurch Garden Town has already been decided upon and meets the criteria for a new strategic development. This does not mean this is the best option for all areas. \nRural dispersal to a degree has already been achieved in service villages and centres, and is nearing, or has reached its infrastructure capacities. More of the same is not an option.\nUrban extensions, retaining as much green belt as possible would be the best choice, to achieve nice places to live, better transport networks and links to larger urban facilities. If people want to move to a more rural location, this can then be available if they choose. Variations in the way people live should be celebrated and welcomed as all people are individuals. One size does not fit all.","","","","[Q1] The vision needs to be longer than 15 years. There are several reasons for this: We are in a rapidly changing world with considerable political, socioeconomic and environmental challenges. A strategy which looks at the long term, say 60 years; the midterm, say 30 years and the short term, say 15 years would create a better policy making process. The short term is the plan which will be revised in time, but at each revision it is adapted according to changing priorities in the mid to long term. Also, with each re-examination, the mid and longer terms stretch out proportionally. \nIt is important to have a longer perspective. The longer term provides important context especially for infrastructure projects and particularly in an age with Carbon Neutral targets, global warming, some of the highest levels of migration in history and worldwide government fiscal challenges. \nGCHQ, University of Worcester and other organisations look at the World through different prisms and their analytical input and insights over a longer period would prove useful. If the Plan is only for 15 years, the effective period will be shorter as it gradually becomes outdated. This was was the situation with the lastPlan. Rather than making a wholesale revision, it would be better to take a more global view of direction over a longer period to run alongside and inform the short-term plan.\n\n[Q8.] Whilst biodiversity is important and the loss of wildlife habitat and plant species significant, care has to be taken how restorative action is taken. \nThe causes of the reduction in biodiversity are complex and targeting development and setting a 10% target might be inadequate. This alone \nwithout comprehensive policy covering all sectors of the economy will not achieve the desired results. It may have the effect of stifling much needed balanced development for employment and providing homes for people to live in. Planning policy needs to be mindful of the complexities involved and the risk of unintended consequences of poorly informed and executed policy decisions.\n\nThe Consultation Document Questionnaire\n1. There are a number of problems with the Regulation 18 Document and the Consultation Document Questionnaire. It appears that the Questionnaire has been compiled without sufficient market testing,or awareness of how easy it is for respondents to complete. There is also some question about how useful or relevant the submitted information will prove to be. The successful canvassing of public opinion requires specialist expertise and it is evident the exercise has been undertaken with inadequate specialist advice and skill. \nThe likely consequence is the exercise will not produce the quality or volume of response hoped for, and therefore as a consultation exercise it will fail and not deliver on its intent.\nThe following points are some pointers where the Questionnaire is flawed:\n1. Finding the Regulation 18 Document and Consultation Document Questionnaire.\n1.1 The first challenge is to find the relevant website. Any individual member of the public needs to be aware of the existence of the website in the first instance and then source the website address.\n1.2 When entering the site, it is not easy to immediately understand how to navigate it and where to look for information.\n1.3 To find the Regulation 18 Document is complicated. (The title of the document is not self-explanatory and may also be confusing to the lay person). It takes 5 separate stages and link pages to reach the Regulation 18 Document and the same number of windows to find the Consultation Document Questionnaire.\n2. Question numbering \n2.1 There are 31 questions. These are numbered when referred to in the Regulation 18 Document, but the numbers are omitted in the Questionnaire, which makes cross-referencing difficult.\n2.2 The Question titles and the questions themselves, includingthe yes/no answers, between the Regulation 18 Document and the Questionnaire, do not always tally, requiring further cross-referencing and effort.\n3. Completing the Questionnaire.\n3.1 To answer the different questions, the Regulation 18 Document has to be referred to. Ideally two screens are required, but few people would have two screens or two computers to view the Document and Questionnaire simultaneously. Short of having two screens, the process involved would involve constantly having to navigate between two documents on line, repeatedly going backwards and forwards opening and closing the different documents for every question answered.\n4. Saving the answers\n4.1 Answering the questions and referring back to the Regulation 18 Document is a time consuming and energy sapping process. To not be able to save questions once answered, is problematic. Few people will have the time to answer the questions at one sitting, with the result that there is a risk of the answers being lost if the Questionnaire page is accidentally closed down, or the computer requires rebooting.\nOn Monday 4th March 2024, with 10 days left for the consultation period, for a total combined population in Cheltenham, Gloucester and Tewkesbury Council areas of 346,200 people, (Taken from the Office of National Statistics), the main Questionnaire has only had 38 participants. 19 people have responded to the Strategic Objectives, 25 to the Draft Vision, 17 for questions addressed to 13 – 25-year-olds and 58 to questions for young people. By any standards, this is a poor response, which runs the risk of invalidating the entire consultation exercise.\n"]
["","",20,"These are all very laudable objectives, but how development is to be meaningfully and appropriately delivered on the ground in any location is of great importance. \nThere is no provision for master planning in any locality. It is a concern there will be a mismatch between high level assessment of the SLP and the delivery of clear and meaningful development at community level\n\nBuilding on rural land near existing rural communities like Highnam and Churcham adversely effects the rural balance in thee areas. People who live in rural communities have made that choice and do not want that choice of a rural environment taken away.","Highnam and Churcham communities are under threat here by the proposed areas of development, Highnam have already taken a large development over recent years and should not be expected to take any more. The number of houses in the existing Highnam neighbourhood plan has been almost completely been met. Furthermore, the recently approved (after Tewkesbury Borough did not defend the appeal) development opposite the golf course will add a further ~70 houses. Highnam has already had a disproportionate number of houses compare to other areas.\n\nThe traffic on the B4215 which passes through Highnam.\nThis is a 'B' Classification Road, but due to the bridgehead status of Gloucester with through traffic and commuter traffic converging from\neasterly and westerly directions, the A40 Northern Bypass frequently becomes congested. This traffic passing around Gloucester dissipates in a westerly direction largely onto the B4215, which is too narrow a road to safely take the volume of traffic using the highway, with inadequately designed and unsafe footpaths for pedestrians.\nThe traffic is busy throughout every day and comprises the full range of commercial, business, public service and private vehicles. What needs to be recognised is that this road not only serves the growing communities west of Highnam, being Newent, Ross-on-Wye and the surrounding area, including the M50, but also further afield. It has become a major trunk road for vehicles originating and completing their journeys from a south westerly direction beyond Swindon, the M4 and Oxford, to the River Severn bridgehead at Gloucester, with destinations in Herefordshire, and further afield into Wales. The B4215 in used in preference to the A40, as it is less undulating and a more direct, linking with the M50 at a motorway junction.\nFor those wanting to travel by rail from Gloucester station and travelling from the West, they largely pass through Highnam along the B 4215.\nThis is a route under pressure and which is also vulnerable. Whenever the A417 is closed, due to the A 417 being closed, due to flooding from the River Severn breaking its banks, or the M5 closed due to accidents, the B4215 is impacted, resulting in queues and tailbacks through the village at times gridlocking the community.\nThe A40 Gloucester Northern Bypass also floods periodically making emergency access for emergency service vehicles to Gloucester and Cheltenham impossible.\nWith the ‘missing link’ highways development improvement work between Crickley Hill and the Cowley Roundabout on the A417, as well as connecting with the M5, more traffic will be funnelling along the Northern Bypass around Gloucester heading Westwards towards Herefordshire and Wales, adding further traffic to the B4215 through Highnam.\nThe Highways authority have not engaged with this problem, but it needs to be addressed and considered in the emerging Strategic & Local Plan.","Yes","It is difficult to argue with the Draft Vision. The challenge is how to deliver the aspiration? The vision sounds utopian and whilst supporting the aims, the method of delivery on the ground in a comprehensive manner is the challenge and needs to be addressed. It would be appropriate for the vision to be longer than 15 years. There are several reasons for this: We are living in a rapidly changing world technologically, with increases in population, greater diversity, major demographic changes, along with with considerable political, socioeconomic and environmental challenges. A strategy is required which looks at the long term, say 60 years; the midterm, say 30 years and the short term, say 15 years, which has been referred to earlier. The short term is the SLP which will be revised in time, but at each revision it is adapted according to changing priorities in the mid to long term. Also, with each re-examination the mid and longer terms stretch out proportionally. It is crucially important to have a longer perspective. The longer term provides important context especially for infrastructure projects and particularly in an age with Carbon Neutral targets, global warming with some of the highest levels of migration in history and worldwide government fiscal challenges.","Yes","Items 1, 3 and 5 have been absent from developments granted planning approval around the village Highnam in recent years. New development\nneeds to be granted alongside a provision for appropriate social and community facilities, including schools, open space, playing fields, with green and blue infrastructure. All these aspects enable a community to thrive, enabling community cohesion and sustainability. Such facilities along with successful infrastructure provision can only be delivered with local neighbourhood or master planning.\nThis kind of Local Planning needs to be an integral part of the Strategic Local Plan.","Climate Change is happening and it is becoming an everyday reality.\nThe best way the Strategic and Local Plan could be most effective is as a facilitator to work with other agencies to create a comprehensive set of policies which together have impact and become effective.\nFrom the viewpoint of the Parishes close to the Severn Vale, flooding is a major consideration and is already having a deleterious impact on Highnam. There are those properties directly affected which flood, whilst all the communities are affected by the lack of appropriate roads, drainage, maintenance and adequate highway infrastructure. The increase of traffic on an inadequate road infrastructure on the A40 and B4215 is exacerbating the problem.","","","","","","Access to work, GP surgeries, transport, schools, community sporting and leisure facilities access to a shop(s)","","","","","","","","","No","","Small sites seem to work better in terms of being better kept and fitting in.","","Good access (transport /road infrastructure) to employment sources.","","Good transport links and cycle routes\nAccessible and free/low cost parking. \nTax incentives for new businesses.\nClean streets.\n\nSustainable brown field development of unused buildings for housing. This would in turn encourage further brown filed investment for shops, eateries and entertainment in town centres.","","Ensuring capacity of existing roads, decent transport systems and routes, schools, health facilities, sporting/leisure facilities and water sewage systems.  ","","Excellent transport routes. ","","","","","","","","","[Q1] - 20 years as a minimum\n\n[Q28] - I note that one of the new settlements proposed is between Highnam and Churcham straddling the A40. A proportion of this land is in the Forest of Dean District Council area, being in the same location as the site previously proposed by Forest of Dean District Council for a new town in their local plan in 2020 and which was resolutely dismissed by Forest of Dean residents and the Council for a whole raft of evidenced and documented reasons. I understand that this evidence will be included in the response to this consultation from the Forest of Dean Council. A new town in this area (straddling the A40) is not proposed in the new Forest of Dean local plan and, I firmly believe, should not be included as part of the SLP.  \n\nPlease be aware that by far the vast majority of Forest of Dean residents \n(a)\twill not be aware that this is a proposal by the Cheltenham, Gloucester and Tewkesbury SLP \n(b)\twill not have had the opportunity to respond to this consultation and;\n(c)\twill not, therefore, have been part of the democratic process for a decision that may potentially affect their district.\n\n[General] - Please remember some people living rurally are happy with that existing settlement (that’s why they live there) and positively do not want interference from councils to change the character of the place they are in. ie: people live in rural places because they are rural. Not everyone wants a local shop/bowling alley/shopping centre/supermarket/stadium/gangs/drugs etc. \n\nHighnam and Churcham communities are under threat here by the proposed areas of development, Highnam have already taken a large development over recent years and should not be expected to take any more. The number of houses in the existing Highnam neighbourhood plan has been exceeded excessively with the recently approved (after Tewkesbury Borough did not defend the appeal against the initial refusal) development opposite the golf course will add a further ~70 houses. Highnam has already had a disproportionate number of houses compared to other areas. I am therefore, strongly against building on all areas around Highnam HIG006, HIG007 HIG008, HIG009 HIG010, HIG011, HIG012, HIG013.\n\nAdditionally, I would be strongly against building on the areas HIG007 and HIG013 (Monkey Back Hill) for the following reasons:\n•\tThis is an area of outstanding natural beauty with uplifting and extensive views in almost all directions, taking in Wales, the Malverns and the Cotswolds.\n•\tThe hill is heavily and regularly used by Highnam residents including dog-walkers, nature lovers, families and older residents.\n•\tThe public footpath across the hill is part of a longer pathway from the village, across the playing fields, through the woods, out onto the hill and out the other side over the stile onto the spine track. This route provides pleasure, exercise and mental wellbeing to many. \n•\tBuilding on Monkey Back Hill would deprive residents of a beautiful natural asset and would be detrimental to their mental and physical health by curtailing their opportunities to get out into the natural environment.\n\n\nThe survey is difficult to access:\nOn Monday 4th March 2024, with 10 days left for the consultation period, for a total combined population in Cheltenham, Gloucester and Tewkesbury Council areas of 346,200 people, (Taken from the Office of National Statistics), the main Questionnaire has only had 38 participants. 19 people have responded to the Strategic Objectives, 25 to the Draft Vision, 17 for questions addressed to 13 – 25-year-olds and 58 to questions for young people. By any standards, this is a poor response, which runs the risk of invalidating the entire consultation exercise.\n\n"]
["","",15,"","","Yes","Kemerton Conservation Trust agrees with the aspirations that are set out in the draft Vision. However, we would like to make the following suggestions to improve the draft Vision.\nThe first paragraph of the draft Vision states that ‘Growth will have afforded the highest possible quality of life for all in a manner which achieves carbon reductions and addresses the causes and effects of climate change’.  Achieving carbon reductions is not aspirational enough. Instead, the Vision should set out an aspiration to achieve ‘net zero’. \nThe fourth paragraph of the draft Vision refers to ‘Growth in sustainable locations’. We propose the insertion of ‘ecologically’ before sustainable.  \n\nThe fifth paragraph of the draft Vision refers to ‘conserving the area’s special landscapes’. We support the inclusion of aspirations relating to landscape within the draft Vision. However, we do not consider that this statement is aspirational enough and does not reflect national policy relating to landscapes. Firstly, we consider that this statement should make explicit reference to the Cotswolds National Landscape (CNL) and its setting, reflecting the national importance of this designation. Secondly, the statement should make explicit reference to the statutory purpose of CNL designation, which is to conserve and enhance the natural beauty of the area. We suggest that this statement should be changed to:\n\n•\tConserving and enhancing the natural beauty of the area’s special landscapes, including the Cotswolds National Landscape and its setting. \nThe fifth paragraph also refers to ‘a network of green spaces’ helping to secure ‘a high-quality environment for people and nature’. It also refers to ‘improvements to biodiversity’. Again, these statements are not aspirational enough. The aspiration, with regards to biodiversity, should be to deliver a nature recovery network that is of sufficient quality, scale and connectivity to secure nature’s recovery. It should be borne in mind that this connectivity will be required across neighbouring authorities. This might be acceptable, provided that the type and scale of renewable energy generable / storage that would be accommodated in the allocation is compatible with the statutory purpose of conserving and enhancing the natural beauty of the Cotswolds National Landscape and other protected landscapes. \n\nAllocations for large-scale renewable energy schemes in the CNL or to a lesser extent its setting would not be compatible. \n\nWe consider that the identification of ‘suitable areas’ for renewable energy (specifically wind and solar energy) is a higher priority than the allocation of specific sites. ","Yes","Kemerton Conservation Trust supports the draft Strategic Objectives, but please take note of our comments under Question 4.","With regards to climate change adaptation, priority issues should include nature recovery, sustainable drainage and flood management. Our particular focus is how these might apply to the floodplain of the  Carrant and Waterlet Brooks. With regards to nature recovery, consideration should be given to the Cotswolds National Landscape Board’s Nature Recovery Plan.","Kemerton Conservation Trust’s objectives are limited to the conservation of nature and landscape for the public benefit. However, the plan should recognise that new buildings will affect the landscape, and therefore that design codes should reflect the local vernacular on which the landscape depends. This is particularly true of the areas bordering the Cotswolds.","","Yes","Yes","Kemerton Conservation Trust has responded to previous consultations on the JCS and the Tewkesbury Borough Local plan providing evidence of the ecological and historical importance of the lower Carrant Valley. We see the issue as being preventing the biodiversity loss which would arise from adjacent development to it rather than providing further net gain. However, a major scheme to restore the original course of the Carrant Brook might provide BNG in addition to flood risk mitigation. Its present importance depends partly on the lack of disturbance to breeding waders and so increased public access could offset any gain.","Shops, schools, health services, green infrastructure and public transport (at a level that is sufficient to enable access to and from key services / facilities and to enable commuting to and from jobs in local employment centres).","Yes","This might be acceptable, provided that the type and scale of renewable energy generable / storage that would be accommodated in the allocation is compatible with the statutory purpose of conserving and enhancing the natural beauty of the Cotswolds National Landscape and other protected landscapes. Allocations for large-scale renewable energy schemes in the CNL or to a lesser extent its setting would not be compatible. \nWe consider that the identification of ‘suitable areas’ for renewable energy (specifically wind and solar energy) is a higher priority than the allocation of specific sites.","","","Yes","As well as the CNL and Green Belt, an additional constraint on the plan area is its vulnerability to flooding. The need to avoid development in flood zones, and the need to ensure that new development does not increase downstream flood risk, may result in a lower housing number than provided for by the Standard Method.","","","","","","","","","","","","If a strategic scale new settlement at Ashchurch/Tewkesbury were to form part of the plan, a comprehensive solution to acute traffic congestion on the Strategic Road Network at A46/M5 J9 would be needed for any large-scale allocations to become viable. This would have serious implications for the landscape and biodiversity of the lower Carrant Valley and the views over it from the CNL.\nComprehensive downstream flooding prevention measures may also be needed, as well as enhanced capacity to water supply and sewerage infrastructure.","","Yes","Yes","Kemerton Conservation Trust recommends that consideration should be given to a scenario that doesn’t involve major development within the CNL or its setting that would harm the natural beauty or biodiversity of the area.","Yes","\"Kemerton Conservation Trust considers that the pros and cons identified for the six development scenarios are fair and accurate. However, there are some additional points that should be reflected within the pros and cons, as outlined below.\n\nScenario 1 – Urban concentration\n\nThe ‘pros’ should include reducing development pressure on the CNL.\n\nScenario 2 – Urban extensions\n\n The ‘cons’ should include:\n\n•\tAdverse impacts on views from and to the CNL, with regards to development in the setting of the CNL.\n\nScenario 3 – Urban extensions, avoiding the Green Belt\n\n The ‘cons’ should include:\n\n•\tAdverse impacts on views from and to the CNL, with regards to development in the setting of the CNL.\n•\tPotential increased development pressure on the CNL and its setting.\n\nScenario 4 – New Strategic Settlements\n\nWith regards to the potential new strategic settlement at Ashchurch, the ‘cons’ should include:\n\n•\tPotential adverse impacts on views from the CNL.\n•\tPotential adverse impacts on downstream flood risk\n•\tPotential adverse impacts on biodiversity and natural beauty\n•\tPotential adverse impacts on dark skies.\n\nScenario 5 – Rural Dispersal\n\nThe ‘cons’ should include:\n\n•\tExcessive development pressure on the CNL and its setting.\n•\tPotential adverse effects on the natural beauty of the CNL.\n•\tPotentially excessive increase in traffic movements.\"","Scenario 1: Urban concentration; Scenario 2: Urban extensions","","","Kemerton Conservation Trust would like to highlight the new statutory duty on relevant authorities to seek to further the purpose of designation (i.e. to conserve and enhance the natural beauty of the CNL), which came into effect on 26 December 2023. The three local authorities will need to take this statutory duty into consideration as they progress the Strategic and Local Plan.\n\nWe recommend that the Strategic and Local Plan should require development proposals to demonstrate the measures that have been taken to further the statutory purpose of conserving and enhancing the natural beauty of the CNL.\n\nWe also note the requirement for local authorities to prepare a Local Nature Recovery Strategy. Kemerton Conservation Trust is represented on the Worcestershire LNRS Steering Group and is helping to co-ordinate linkage with the Gloucestershire LNRS across the Carrant Catchment."]
["Resident",null,100,"Power generation, power distribution, district heating / cooling, Carbon emissions, Fire fighting,","Public rights of way, footpaths, cycle ways.","Yes","Growth will have afforded the highest possible quality of life for all in a manner which reduces the counties carbon emissions to zero and flood risk to the same as in 1990.","No","Low carbon developments should not be permitted, all developments require to be carbon negative including infrastructure energy consumption.","","","","","No","","Railway station","Yes","Mixed balance of Nuclear, solar and wind.","","","","","Yes","The SLP should prohibit low density residential dwellings, such as bungalows and houses less than three stories.","Yes","","","SLP should designate all land within 1/2 mile of train stations as preferred locations for businesses.\nBusiness locations should be supported with provision of sufficient vehicle parking.","","Rural employment should not be encouraged as carbon intensive compared to urban areas. ","Increase residential density, promote change of use to residential and increase vehicle parking provision for residents and visitors.","","Storm water drainage,\nSewer drainage and treatment\nPower distribution\nTelecommunications\nCarbon free transport links","","","Yes","","","No","","Scenario 2: Urban extensions; Scenario 1: Urban concentration; Scenario 4: New strategic settlement","No","","Developments should provide sufficient off-road parking to eliminate parking on roads.\nResidential developments should provide footways separated from roads with a min 1.8m grass strip planted with trees / shrubs."]
["Local Councillor","Down Hatherley Parish Council",10,"Keeping green spaces and not merging villages into a large town","","No","More protection for green spaces and segregation of villages","No","More protection for green spaces and segregation of villages","Not building on meadows and flood plains","Existing sewage systems are not able to cope with all the new builds","Existing buildings should be repurposed first","No","","","Schools and doctors","No","","","","","","Yes","Bungalows for elderly people ","Yes","","","","","","","Cheaper rent and rates","","","","","","","","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt;","","",""]
["Local Councillor","Hucclecote Parish Council","","","","No","Review housing targets as at the moment there seems to be very little evidence that the targets are legitimately to provide much needed housing as developers are allowed to build a very small percentage of affordable housing for first time buyers as this allows them to maximise profits","No","More protection for our greenbelt which is being decimated by the objectives. There also needs to be land set aside for wildlife on any development. The impact of this draft on our wildlife is quite devastating and we have a duty as custodians of this planet to protect all creatures that live on it. Wildlife mitigations on each development need to be maximised. existing trees and hedgerows need to be incorporated into every development not just removed if they stand in the way of developers profiteering","No planning for areas that annually flood. Retention of all trees and hedgerows on developments. Creation of natural flood prevention measures on all developments","Charging points and solar panel for all new builds","Compulsory purchase orders on all houses unoccupied for more than a year","Yes","Yes","I have areas near me in Abbeydale GL4 which could be used for flood prevention and as wildlife areas and for community food growing areas","parks and green spaces","No","","No","create a data base so anyone waiting to buy a home can register. Waiting for a council house to rent is not the same as looking to buy your own home. Also liaise with developers to get data on the take up of new homes.","Yes","The impact on wildlife, flooding in the development areas and the impact of developments on existing communities","Yes","one and two bedroom homes","Yes","","","","","","","","green spaces and parks","","The impact on the existing community","Yes","","","","","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 1: Urban concentration;","","","Our greenbelt and wildlife cannot be sacrificed for our needs. We have to protect both at all cost and accommodate our needs where it will have the least impact on them. All existing trees and hedgerows need to be incorporated into all developments, biodiversity gains increased massively and wildlife mitigation measures need to be improved to world class standards  "]
["Local Councillor","Norton Parish Council","","Projected changes in population resulting from housing and employment provision.","Speculative housing development in Tewkesbury Borough Council's area resulting from a lack of a five-year housing land supply.","Yes","","No","My answer is actually \"yes\" in part. More emphasis needs to be placed on the needs of an ageing population","","Effective and comprehensive local design codes.","Effective and comprehensive local design codes.","","","","Public transport, employment opportunities, schools, local shops, doctors and dentists surgeries.","Yes","More charging points in public locations for electric vehicles.","Yes","The standard method isn't ideal, but it represents the best calculation method available.","Yes","The Strategic and Local Plan should take note of the number of unbuilt dwellings on sites with planning permission that haven't been implemented when calculating the local annual housing need.  The need figure should be reduced by the number of unbuilt dwellings to avoid over-development,","Yes","There is an urgent need for more properties to rent, for both families and young, single people.","","","","Local businesses, including small shopkeepers, need to be encouraged back to town centres in order to maintain vibrant local communities.","Consider offering discounts on business rates to encourage inward investment from larger employers, especially in main centres of population.","Yes.\n(a) By allowing more houses to be built in rural areas specifically for rural workers. The occupancy of those houses should be restricted to specific occupations suitable for a rural location, such as agriculture or tourism-related employment.\n(b) By promoting tourism in this picturesque county, particularly to people living outside the UK.\n(c) By improving rural bus services, including links from the main areas of population in Gloucester and Cheltenham.","No response.","Improve public transport and local short-term parking so that customers can visit these shops, services and facilities more easily.","Good public transport, employment opportunities, schools, local shops, and doctors and dentists surgeries.","Good public transport, employment opportunities, schools and pre-school nurseries, leisure facilities, shops, charging points for electric vehicles, and doctors and dentists surgeries.\nHowever, the Strategic and Local Plan needs to recognise that it covers an area prone to flooding, particularly from the River Severn. Covering green fiels with concrete and tarmac to provide additional housing can only make the problem worse. Therefore flood prevention measures should be a crucial part of the Plan.","Good public transport, local employment opportunities, schools and pre-school nurseries, local shops, and doctors and dentists surgeries.","Yes","No","","Yes","","Scenario 1: Urban concentration; Scenario 4: New strategic settlement; Scenario 6: Sustainable transport scenario","No","","Yes. The cost of providing the necessary infrastructure, services and facilities needed in this part of the county should not be borne solely by local communities. Developers should be required to make significant contributions towards the cost of providing the local infrastructure, services and facilities that will be required to meet the draft Vision set out in this document."]
["","",20,"","Tewkesbury – Flooding Tewkesbury – Traffic (A46 and M5J9)","No","Mostly agree. One point that needs to be highlighted is industry. Plan should clearly set out a vision for industrial development. This will enable people to work within walking, cycling, bus distance from their homes. Otherwise its just a plan to create a vast commuterland with all the problems of congestion, air quality etc.","No","Need to address Landfill waste. The Landfill at Wingmore Farm near Bishops Cleeve has been expanded many times because successive councils refuse to address the problem. I remind you that it was originally a quarry and the original permission was for landfill up to the original level of the land. Due to successive relaxations of permissions its now a small mountain. This MUST be addressed as part of any strategic plan.","Require all new build houses and industry to have solar panels on roof. Industrial estates to have wind turbine in the site as at Green Park near Reading. Vision should include upgrading existing stocks of housing, offices, schools, industry to be more environmentally efficient.","Require all new build houses and industry to have solar panels on roof. Industrial estates to have wind turbine in the site as at Green Park near Reading.","Vision should include upgrading existing stocks of housing, offices, schools, industry to be more environmentally efficient.","No","","","Doctors surgeries, Schools, Local shops","Yes","Require all new build houses and industry to have solar panels on roof. Industrial estates to have wind turbine in the site as at Green Park near Reading. Vision should include upgrading existing stocks of housing, offices, schools, industry to be more environmentally efficient. Energy storage – make use of battery banks BUT these must be a long way from housing/employment because of toxic fumes if there’s a fire. Generally support anerobic digesters to generate power But the recent explosion of one near Oxford tells me that these must be a long way from housing/employment . Farmland – NO MORE SOLAR FARMS. Every acre of farmland taken out of production for energy production or housing reduces our food security.","No","Any housing need must be calculated on the basis of what jobs are available in the area. Otherwise all you create is a giant commuterland. Which is entirely contrary to the vision set out in this plan. Just look at the Highways Agency figures for traffic joining M5 at Junctions 9, 10 and 11.","Yes","Infrastructure – Roads, Rail. A46/M5J9 relief needs to be resolved before starting large scale developments. Railway – Ashchurch Railway halt needs to be improved by giving it a siding loop. This will enable more trains to stop at the halt without affecting the through (express trains","","","","","","","","","","","Roads - A46/M5J9 relief needs to be resolved before starting large scale developments. Railway – Ashchurch Railway halt needs to be improved by giving it a siding loop. This will enable more trains to stop at the halt without affecting the through (express trains) Landfill - The Landfill at Wingmore Farm near Bishops Cleeve has been expanded many times because successive councils refuse to address the problem. I remind you that it was originally a quarry and the original permission was for landfill up to the original level of the land. Due to successive relaxations of permissions its now a small mountain. This MUST be addressed as part of any strategic plan.","Transport – Road, Rail, Trams","Local shops, Schools, Doctors Surgeries,","Yes","","","","","Scenario 1: Urban concentration; Scenario 6: Sustainable transport scenario","","","Development scenarios LEAST appropriate for the Strategic and Local Plan? Scenario 4 – New Strategic Settlements Scenario 5 – Rural Dispersal. \nRailway – Ashchurch Railway halt needs to be improved by giving it a siding loop. This will enable more trains to stop at the halt without affecting the through (express trains)."]
["Business owner","Pulhams Coaches Ltd.",18,"No","None","No","Pulhams consider that the draft Vision or the SLP is broadly comprehensive but fails to properly direct the plan strategy where the pressing need to secure a more sustainable balance of travel choices by sustainable modes is concerned, and public transport in particular.\n\nOn page 15, g) fails to state clearly that high quality sustainable travel choices that are competitive with driving must consistently be delivered across the plan area to secure the Vision, and conformity with both the adopted GLTP4 and national transport policy, and planning policy expressed at paragraphs 108-110 of NPPF.\n\nPoint j) makes reference, as an example to “Mass Transit Corridors”. Notwithstanding the policies in GLTP4, these are yet to be defined. The plan must have a clear and unremitting focus on deliverable sustainable transport outcomes, without being spatially tied to a specific unfunded and undefined solution. Without such a focus, the strategy would be subject to material delivery risks, that could go to the heart of the soundness of the plan. The focus of the plan should accordingly be on “high quality public transport corridors”.\n\n4) No \n\nPulhams consider that the draft Vision or the SLP is broadly comprehensive but fails to properly direct the plan strategy where the pressing need to secure a more sustainable balance of travel choices by sustainable modes is concerned, and public transport in particular.\n\nOn page 15, g) fails to state clearly that high quality sustainable travel choices that are competitive with driving must consistently be delivered across the plan area to secure the Vision, and conformity with both the adopted GLTP4 and national transport policy, and planning policy expressed at paragraphs 108-110 of NPPF.\n\nPoint j) makes reference, as an example to “Mass Transit Corridors”. Notwithstanding the policies in GLTP4, these are yet to be defined. The plan must have a clear and unremitting focus on deliverable sustainable transport outcomes, without being spatially tied to a specific unfunded and undefined solution. Without such a focus, the strategy would be subject to material delivery risks, that could go to the heart of the soundness of the plan. The focus of the plan should accordingly be on “high quality public transport corridors”.\n\n4a) If not, what changes would you like to see?\n\nTo address the above points, Pulhams consider that the draft Vision or the SLP should be altered as follows:\n\nDraft Vision \nBy 2041, and beyond for larger scale developments, the Cheltenham, Gloucester and Tewkesbury area will have …\n\nInvestment in training, skills and development will have attracted and retained a younger workforce and provided new premises and flexible workspaces to support a flourishing circular economy in both urban and rural areas, and the delivery where necessary of facilities to support expanded public services. Inward investment, innovation and growth in key sectors including, amongst others, cyber and digital-tech, food/agri-tech, advanced engineering and tourism will have been fostered. \n\nPeople’s housing needs will have been met through the provision of sustainable, high-quality market, affordable and other specialist homes set in beautiful, safe places and conforming to sustainable standards of design and construction. The focus will have been on making best possible use of brownfield sites in built up areas and large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved. The vital role of the area’s city centre, town centres and high streets, as those places most accessible by sustainable modes will have been improved will increasingly be the focus of major trip generating land uses through careful management of development and land uses opportunities across the plan area. \n\nGrowth in sustainable locations will take advantage of and if necessary have enabled the provision of healthy, accessible and walkable neighbourhoods, the promotion of maximising the use of active travel and sustainable travel public transport, effectively rebalancing the and provision of new transport systems that work effectively to secure sustainable local mobility for local people existing and new neighbourhoods. \n\nGrowth will have been supported by the provision of a range of essential the digital, transport, community and other infrastructure necessary to secure the plan’s strategic objectives and in support of wider national policy. \n\nEqually, …”","No","No. \n\nPulhams consider that the draft Strategic Objectives of the SLP again, address the main areas identified in a broadly comprehensive way, but lack sufficient clarity of intent to properly direct the plan strategy and policy where the pressing need to secure a more sustainable balance of travel choices by sustainable modes is concerned, and public transport in particular.\n\na) If not, what changes would you like to see?\nPulhams consider that the draft Vision or the SLP should be altered as follows:\nDraft Strategic Objectives \nMeeting the challenges of climate change\n1. …\n2. Ensuring growth takes place in sustainable locations that minimise the need to travel and provide genuine sustainable transport and active travel options sufficient to be competitive with car use, and secure high levels of use. \n3. Making the most effective use of previously developed land, including higher density development both in city and town centres and other locations well served by public transport. \n4. Ensure development effectively provides excellent access to local services by active travel modes through integration with existing adjoining development, and/or secures credibly high levels of self-containment at a suitably early stage.  is a self-contained development that provides shops, services, facilities through walking, cycling or public transport. Public transport should be the natural first choice for trips beyond the neighbourhood.\n…\nPrioritising sustainable transport and active travel \n1.\tReducing the need to travel, and the need to travel long distances by motorised means, by pursuing a compact development strategy and compact forms of development creating real options that make active travel and public transport the natural first choice  for healthy, accessible and walkable neighbourhoods where to access key services are available without the need to use motorised transport; \n2.\tPromoting the use of sustainable travel modes by focusing development in locations that are sustainable by virtue of their active travel and public transport connectivity offer, taking necessary opportunities to further improveing existing safe walking and cycling routes and providing new frequent public transport links and in all new developments, where necessary securing new links to meet identified deficits; \n3.\tMaterially reducing reliance on the private vehicle by improving access to services in rural and urban areas through new development, improved integrated transport links and supporting local and community led transport initiatives in the Local Transport Plan;\n4.\tCreating a genuine choice between different modes of transport by integrating new development with existing networks and enhancing these wherever possible. \n\n","If national legally binding targets for carbon mitigation are to be secured, then an unprecedented mode shift away from private car use is unavoidable in every scenario set out by Government. This is made very clear in the National Transport Decarbonisation Plan. \n\nThe role of development plans in facilitating this by aligning development strategies with the need to reduce the energy intensity and distance of travel should not be underestimated. This is made explicit in Section 5 of the NTDP. While this is still yet to be made explicit in NPPF, the direction of policy travel is very clear.\n\nThe language at 4.14 of the condoc fails to recognise this at all, which is disappointing. It focuses only on urban design and building specification, having no regard to the fact that extensive patterns of development that extend journey distances make car dependency inevitable. Active travel and public transport can never be competitive with the car in developments thus located. \nIn fact, active travel or public transport too often is not even a credible choice, much less the genuine choice that NPPF paragraph 108 expects plan strategies to facilitate.\n\nPublic transport is not even mentioned in the table at 4.15 under the “movement” theme, though it is in the supporting memorandum. The plan needs to have a clear and consistent vision, that is evidentially well-founded, for the role of public transport in securing sustainable mobility. For this to happen, this will require the plan evidence base to pay careful regard to those appropriate sites that can take advantage of existing of potential high quality public transport corridors, and the development strategy should be appropriately steered by this evidence. Furthermore, if the plan is to be soundly based, the deliverability and effectiveness of envisaged public transport interventions to support the plan ought to draw on operator experience, in this regard, especially where improved or new public transport links are necessary. \n\nThis new strategic plan needs therefore to pursue a spatial strategy that appropriately prioritises urban intensification, thereafter a relatively compact form of development building on existing neighbourhoods and existing high quality public transport corridors to the extent that this is possible and appropriate, before extending the search to new stand-alone neighbourhoods and settlements, which, again, should be located on demonstrably effective existing or potential high quality public transport corridors.","No comment","No comment","No","No","","Traffic counts expose the degree to which peak car-borne journeys reduce at school holiday periods. Thus, the provision of sustainable choices to reach primary and secondary education sites should be paramount. 1200-1400 dwellings are typically considered sufficient to support economic and effective 2-form entry primary school provision. \n\nThe ability to meet daily convenience shopping needs within a 5-minute each way walk (about 400-500m) ought to credibly be achievable even at net densities of 35 dwellings per hectare, given that this radius would put up to about 1700 dwellings within range. Factoring in of the land uses, a 1400-dwelling exclusive catchment is considered commercially capable of sustaining a sound convenience store offer. \n\nFor off-site trips, a bus service operating no less than every 20 minutes with a journey time to a major town of no more than 30 minutes, should be considered the minimum baseline offer to achieve even the current public transport mode share. A 15-minute frequency and 25 minute journey time is the minimum necessary to secure any prospect of higher bus mode shares than those typical in the urban areas within the plan. 30-minute frequency on evening and Sunday hours of operation is also necessary. Such services should typically be available within 500m of all dwellings on new developments, and ideally, closer.\n","","","No","No. \n\nThe Standard Method is clearly stated in NPPF to be the “starting point” for calculating housing need, not the methodology in its entirety.\n\na.\tIf no, please set out what you consider the councils should use instead.\nThe Councils should seek to follow the guidance published by Government to establish how far other factors, including economic growth potential, affordability and the ability to deliver sufficient affordable housing tenures, should inform the potential to justify a higher requirement.\n\nThe failure of the JCS to fail to deliver against current housing needs is serious and compounds a situation that was already chronic especially in and around Cheltenham. This has directly impacted the ability of service providers including bus operators, to staff their operations. That this has disproportionately affected Cheltenham, of all the bus operating centres in Gloucestershire, manifestly reflects the particularly severe lack of housing availability at any price, much less so affordable costs.\n\nThere is an immediate need to bring housing land forward at policy compliant levels of affordable housing delivery. This justifies allocation of further land capable of early delivery in the plan period, immediately adjoining the existing main settlements and well placed with regard to local facilities, especially secondary school provision, and public transport corridors.  Given the extent of the statutory Gloucester and Cheltenham Green Belt, further limited tactical releases might be required.","No","","Yes","Yes. \n\nThere is an argument that the plan should set out to provide a proportion of new homes as social rent, where viability permits. There seems little need for intermediate tenures given that the national First Homes policy already demands this as a matter of course. Affordable rent homes hypothecated to “key worker” housing are also justifiable to address severe local skills shortages in public services. \n\na. If so, please explain further.\nMultiple above inflation pay awards have still not entirely addressed the ability of some bus companies to recruit sufficient staff in and around Cheltenham in particular. Other service providers have similar problems. We urge the Councils to engage with providers, including the NHS, to establish the nature of these issues in more depth as part of the housing need evidence base.\n","","No comment","No comment","The plan needs to have much more regard to the underlying service economy that typically supports about half of all the jobs in a locality. Many of these are in the public sector, but far from all of them. \n\nOperational sites for key transport infrastructure and service providers are essential to maintain and enhance their operational capabilities. There is no meaningful room to deliver significant additional increases in bus mileage during the core daytime hours in the plan area, because depot facilities are at or close to capacity in the plan area. As it is, Pulhams is running significant numbers of vehicles into the heart of the area from its operating centre a considerable distance away in Bourton-on-the-Water at the start and end of the operating day. This is neither efficient nor especially sustainable having regard to the energy consumption involved in this “dead” operated mileage.\n\nIf the area is to see the electrification of the bus fleet, merely maintaining existing operating fleet resource will require more space. This is because the parking space needed to accommodate charging infrastructure generally reduces capacity by about 15-20% over the maximum diesel capacity. Much depends on the size and configuration of the depot site.\nEven assuming that only current bus mode share is achieved from committed new development, there is a clear requirement for more bus resource to be supported. Looking further ahead beyond 2031, the need to support this base level of organic growth cannot be supported by current depot capacity.\n\nIf even relatively unambitious mode shift targets in GLTP4 are to be achieved, this would involve a near doubling of bus passenger boardings by 2031, and a greater figure beyond that point. The implications of this for planning operational support infrastructure needs to be carefully considered by GCC and the Councils.\n\nBus depots do not fit into the statutory Use Classes Order. They are a sui generis use. There is high demand for general employment land across the plan area, and there is even more development pressure near main bus route corridors and town centres, both from commercial, employment, residential and other uses. Maximising urban capacity as the plan seeks to do, will also directly serve to remove land that might well be suitable for the necessary expansion of bus operations through redevelopment for other uses. \n\nOne only need look at the situation within 1 mile of Stagecoach’s existing Gloucester and Cheltenham premises to see that the few remaining areas of low-intensity commercial uses, for example near the railway, are already being allocated and proposed for residential redevelopment. Land adjacent to the Stagecoach Cheltenham depot site, that was occupied under a short-term lease, is now the subject of a residential redevelopment proposal – reducing the capacity of the depot as a direct result.\n\nThere is thus a direct requirement to examine how the plan might make specific provision to support the relocation and expansion of bus depots to support the County’s transport objectives set out in GLTP4 and the plans own transport strategy.","Employment growth needs to be properly provided for, not least to prevent further overheating in the commercial land and property market. \n\nThe tendency, already apparent, will otherwise be for important employment and service activities within the plan area to be suppressed. Where existing employment cannot sustain the rental or other land values that are being demanded, these smaller established local businesses which are a crucial part of the heathy social and economic functioning of the plan area, are less likely to move, and more likely to contract or to close altogether. This kind of economic “sanitisation”, while superficially attractive on an aesthetic level, has a profoundly corrosive effect on society.\n\nLooking beyond the existing employer ecosystem, the plan area is remarkable in the breadth and diversity of the economic base, and the range of UK and multinational businesses present, many of which engaged in strategically significant knowledge based and high value-added sectors. Many of these firms are sited on legacy sites that benefit from being on existing public transport routes, for example at Staverton, of south of Bishops Cleeve. It is important that these companies can expand and reconfigure their operations without the significant costs and risks of moving. One of these would be that a technically suitable site is remote from credible sustainable access opportunities.\n\nWhere inward investment is concerned, this must be directed to sites, whether specifically identified and allocated or not, that can support a high proportion of personal access requirements being met by walking, cycling and high quality public transport.","No comment","For the last 20 years, national planning policy has sought to ensure that major trip-generating land uses are directed to town centres, and where comparison retail is concerned, a formal hierarchy was established that was based on a “town centres first” prioritisation. \n\nThis policy was justified by a need to ensure that the central location and exceptionally high accessibility of town centres by public transport would support the location of such uses such that over time, a reversal of car dependency and use would be achieved. \n\nLocally and nationally, this has been all but entirely resiled from in the development control arena, faced by the economic strength of retailers who source the bulk of their revenue from affluent households for whom almost every adult has exclusive use of their own car. The rise of retail parks in peripheral locations has been to a very great result, the failure of the planning system, and this cannot just be put down to market forces, strong though they undoubtedly are.\n\nThe role of town centres as places to meet and interact, across a full spectrum of backgrounds, is something the plan condoc does not recognise. It should do if it is serious about achieving the full range of Strategic Objectives it already is intending to place at the heart of plan making. There are already clear signs that town centres are becoming vacated as much by the affluent as they are by retailers, leaving town centres increasingly dependent on and occupied by the most socio-economically disadvantaged, helping feed a vicious spiral of decline.\n\nThe SLP area is fortunate that in Gloucester, after many years the regeneration of the Kings Quarter is taking place; and at least as important, the large and prominent Debenhams building has found an exciting and highly productive new role. These are adjacent to the County’s most accessible point by sustainable modes, especially public transport.  The consolidation of the University and many halls of residence into Gloucester’s central area is an extremely significant and welcome development, and further development of the post-16 Further and Higher Education into the main town centres can and should be facilitated as far as possible.  \nThis builds on the success of Gloucester Quays, which is now showing signs of positive consolidation as further investment has taken place at the northern end around the Customs House, and where the links with the historic city centre look likely to gradually strengthen as a result of the Castle redevelopment.\n\nSubstantial primary research was undertaken in 2012 which showed the value of bus passengers to town and city centres. This work was based on Cheltenham and Gloucester. It showed that bus passengers spend less per trip than car-borne visitors, but generally visited a good deal more often, and thus their actual spend per head exceeded that of car-borne shoppers. Bus passengers are more loyal to town centres, which in terms of underpinning a sustainable town centre economy, less geared to increasingly “zero-sum” competition between venues requiring long car-borne journeys, is clearly in every sense more sustainable.\n\nStrong town centres, able to develop and thrive as safe, animated venues, are crucial to a sustainable low-carbon future. \n\nThe absolute and relative attractiveness of car-borne retail parks is already waning, as the ongoing long-term vacancies at many across the plan area testifies. Many of these represent excellent opportunities for residential redevelopment, or for other edge-of centre uses, including, potentially, R+D and laboratory space.    \n\nIt is therefore vital that existing and future levels of bus services can be properly facilitated in the town and city centres. There is already little if any space capacity at bus stops and stands in Gloucester City Centre, including at the Transport interchange. In Cheltenham the convoluted circulation of buses through Cheltenham town centre, particularly from north to south, is something that is inefficient and makes no positive contribution to townscape or the visitor experience in the strongest town centre, which is relatively resilient. Notwithstanding this, Frasers plc has announced the closure of the Cavendish House department store on Upper Promenade.  The large and unremarkable building is in effect a legacy asset, which could easily be stranded. However we have long pointed out the merits of allowing buses to operate southbound only down this part of the Promenade, which would be likely to allow both more efficient bus access and circulation, and also allow other vibrant parts of the town centre, such as High Street west, to become fully pedestrianised. \n\nWe are also in deep discussions with Gloucestershire County Council about how better access for cycling across Gloucester and Cheltenham City Centres can be facilitated without prejudicing access by bus services and their reliable operation.","\nThe minimum turnover to sustain a convenience store is substantial, and in rural areas where car ownership and use is already very high, it is very hard to sustain any range of local shops and services, unless there is already a significant cluster of established businesses, where access to passing trade on a main through route also greatly assists.\n\nThere may be a case, in some local villages where a local service centre function is identifiable, to focus sufficient additional new development to securely anchor convenience retail provision, or, in some cases, re-establish it.\n\nHowever, it is at least as important to ensure that as many villages as possible retain access by public transport to higher-order centres. These services need to operate at least 6 days per week, at least hourly. Focusing appropriate levels of additional development in the few larger villages on existing regular bus services might be considered as a logical option to maintain rural accessibility across quite large extents of rural Tewkesbury Borough. \n","As we have already stressed, the development strategy must ensure that further allocated development sites are located where existing high-quality public transport exists and/or where it can credibly be provided bus priority.\n\nBeyond that, where strategic allocations are concerned that are considered to require bus services to enter the development, it is vital that policy demands that both master-planning and phasing facilitates this in an efficient and rational manner at all points during the development life-cycle. In a very large number of cases, access by car is the only practical option, until the very last phases where primary streets are finally connected through and buses are able to enter. By this point high levels of car ownership and use are “baked in”. \n\nA clear policy expectation therefore needs to be set that phased deployment of high-quality bus services on large-scale development will take place, and that further development will not be permitted beyond established triggers set through development obligations in accordance with policy. Attempts to forestall and circumvent this by developers, formally or informally, needs to be met with robust enforcement action. \n\nBus circulation and access strategies, including indicative bus stop locations on or adjacent to development, need to form part of the application and consent of all large applications at the initial Outline Application stage, if the site is not brought forward as a full application.  There is neither justification nor need for this to be left to planning condition. There are several examples, including Gloucester Business Park within the plan area, where conditions to agreed permanent bus stop permissions have never been discharged, nor enforced.\n\nBeyond development sites, there is a clear need for urgent effective measures to protect bus services from chronic and increasingly unpredictable delay. We have been saying this for about 20 years. This is recognised in GLTP4 and the Gloucestershire Bus Service Improvement Plan (BSIP).  This needs the SLP to have due regard to and align with these strategies, and, furthermore, to identify where the development strategy might justify and/or help facilitate additional bus priority measures.","For new settlements there is an even greater need to ensure off-site trips can be conveniently performed using public transport as by definition, they are likely to be sited such that cycling will be a less attractive option. \n\nThus, it is essential that new settlement sites are located where existing high quality public transport corridors pass the site and/or where it can credibly be provided by augmentation or limited extension of existing services.","The settlement in its existing or expanded form needs to provide at the least for a 1 FE primary school, and a convenience store. A community hall and formal and informal public open space should also be available, or deliverable including playing pitches.\n\nThe settlement should have, or justify the augmentation of bus services running at least hourly 6 days a week to at least one town centre, and ideally two.","Yes","No","","No",{"$cut":{"chars":17715,"head":"\nWhile the advantages and disadvantages are described in reasonably broad and fair terms there are some clearly unsupportable assumptions and statements made, that we need to challenge.\na.\tIf not, which one(s) and what are your reasons?\n\n1.\tUrban Intensification\nThis should made much clearer that development needs would not be met by a substantial margin, aggravating housing availability and affordability problems and suppressing economic potential. This is a serious disadvantage and would go the heart of the soundness of the plan.\n\n2.\tUrban extensions\nWe broadly agree that the summary of pros and cons is fair and reasonable.\nWe recognise that there are some good options, of a limited but still strategic scale south of Hatherley Way, and East of Churchdown that avoid the vast majority of disbenefits and secure advantages, including the ability to take advantage of high-quality public transport from first occupations, and the availability of secondary education within walking and cycling distance. However, they are relatively few and far between, and could not accommodate the majority of the likely residual development requirement that needs to be identified.\n\n3.\tUrban extensions, avoiding the Green Belt\n6.23 makes the very helpful distinction between Green Belt policy and other protections to landscapes and habitats that have more objective and legally-based rationales:\n“Green Belt land is, as a matter of national policy, designated as a means of managing urban growth, rather than providing environmental protection. This scenario would include land which was previously removed from the Green Belt in the JCS and ‘safeguarded’ to meet longer term needs.” \n\nThe JCS removed and “safeguarded” some additional land from the green belt at Twigworth and at Hayden, adjoining existing strategic allocations A1 and A7, to help meet longer term development needs. These areas are included in this scenario. These areas are most likely to help consolidate demand for bus services already likely to be necessary at West of Cheltenham. At Twigworth, bringing forward the safeguarded land should seek to ensure that a bus route corridor from the eastern boundary of the current allocation is secured to the east towards Innsworth and/or Hatherley.  These are significant inherent advantages offered by these options.\n\nThe transport implications of these options are highly site-specific and not amenable to be broadly categorised. If options are on existing or potential high quality bus corridors – such as the A38 between Gloucester ad Tewkesbury or even north or west of Bishops Cleeve, they may offer some potentially good options, though mostly not as good as options that are closer to Gloucester and Cheltenham in particular, such as east of Churchdown.\n\nWe do recognise that credible options on these sites would probably not be sufficient to meet the development needs of the plan area in full. \n\nHowever, that said, there is clear evidence that credible and potentially very sustainable options exist adjoining the Gloucester Urban area in Stroud District, both at Whaddon and at Hardwicke Green. These have been tested through the Stroud District Local Plan Review EiP within the last year. It is somewhat surprising and inexplicable that there is no reference to these in the condoc, especially since they were highlighted by the previous EiP Inspector for the JCS as being worthy of a future collaborative approach with Stroud District Council, who then brought these both forward as proposed allocations in a Regulation 19 plan within the last 2 years.\nThe options south of Tewkesbury on the A38, as well as at Mitton that already have some planning status within the South Worcestershire Development Plan, are very well located on public transport corridors – though south of Tewkesbury needs very careful urban design to take advantage of the main Tewkesbury-Gloucester and Tewkesbury-Cheltenham bus corridors.\n\n4.\tNew strategic settlements\nParagraph 6.29 refers to this option in the following terms:\n“This option would mean seeking to deliver development through o"}},"Scenario 6: Sustainable transport scenario","No","","This document represents the response of Pulhams and Sons (Coaches) Limited (“Pulhams”) to the current consultation to the Issues, Objectives and Spatial Options for the Cheltenham Gloucester and Tewkesbury Strategic and Local Plan (“SLP”). It is made in close alignment with Cheltenham and Gloucester Omnibus Company Limited trading as Stagecoach West. (“Stagecoach”) who we understand are replying, as the largest operator, with a separate document.\n\nPulhams and Sons (Coaches) Limited joined the Go-Ahead Group in June 2023, with a continuous heritage serving the public with bus and coach services extending over 100 years. Its main operations lie in Cotswold District, run from a modern base at Bourton-on-the-Water. However, it also runs significant mileage in the plan area, most under contract to the County Council. An important exception is the 99 route that runs between the two main hospitals in Cheltenham and Gloucester, linking these to Arle Court, where the major upgraded Transport Hub scheme is shortly to open, as well as the town centres.  It is pertinent to add that the company runs an increasing number of services in Cheltenham Town, as well as much of the mileage in the rural north of Tewkesbury Borough, where significant growth has taken place, with more anticipated, outside the plan led system.\n\nStagecoach and Pulhams between them in Gloucestershire account for public transport boardings at a level more than ten times that of the railway.\n\nWe are aware that Stagecoach West was deeply engaged in the preparation of the current statutory local plan containing strategic policies, being the Gloucester, Cheltenham and Tewkesbury Joint Core Strategy (JCS). This was adopted in late 2017 after an especially protracted genesis, and at the end of the Examination in Public, HM Planning Inspector concluded that the plan remained significantly deficient in a number of areas, even after post-submission main modifications, but that it could be adopted nevertheless, subject to a commitment to immediate review. \n\nAmong other things, the plan’s housing trajectory failed to meet the news of Tewkesbury in full; and also presented a deficit in supply to meet Gloucester City’s needs at the end of the plan period approaching 2031.  There was no agreed deliverable transport mitigation strategy that would allow the development allocated in the plan to take place without serious risks of unacceptably overwhelming local roads infrastructure, though a notional package of schemes was set out that if all funded and delivered, would probably address the mobility needs satisfactorily subject to a 16% reduction in single occupancy car journey trip rates over the plan period. The implications of this for mode shift and the specific means of achieving these wider sustainable travel objectives was never set out. \n\nWe are informed that Stagecoach nevertheless was prepared to support the JCS through its final stages on the basis that the spatial strategy and the strategic allocations were in its view, evidentially those that were most likely to support the objectives set out in NPPF for sustainable transport. They represent a relatively compact form of development, much of it on major public transport corridors, and where adjacent, there was sufficient scale to suggest that a relevant commercial bus service could be provided. While there was no comprehensive public transport strategy, Stagecoach was able to assure the Inspector that ongoing collaboration was underway with virtually all the promoters of strategic allocations within the plan and that the Company considered that the Plan “could be made to work” in ongoing discussion and collaboration with the County Council and the developers. This continues to take place.  \n\nFinally, the JCS is highly dependent on a small number of very large strategic allocations, in effect urban extensions, on land released from the statutory Green Belt. The largest of these lies adjacent to Cheltenham: North West (“Elms Park”), Allocation A4; and West (“Golden Valley”) Allocation A7. These represent the largest planned expansions in the plan area since the early 2000s, and the largest in Cheltenham since the early 1950s. While smaller extensions at Twigworth, Innsworth, Churchdown (in part) and Brockworth have been brought forward propitiously and are building out at some scale and in some cases, encouraging pace, a start has still to be made on the largest allocations. Allocations have all been submitted for West of Cheltenham, and a consent has, finally, been issued for the vast majority of Elms Park, nearly 8 years after the applications were submitted in parallel to the two relevant planning authorities.\nThere has, at least, been important and welcome progress made in bringing forward the largest and most challenging highways mitigation schemes, the West of Cheltenham Improvements Package funded through Local Growth Fund (LGF3) and the M5 Junction 10 and associated A4019 Improvements, funded largely through Housing Infrastructure Fund (HIF). This latter has a value exceeding £200m, and is one of the largest capital schemes ever promoted by the County Council. Stagecoach has consistently recognised that these schemes must form a part of the transport strategy for the plan area, though Pulhams shares Stagecoach’s concern that similar progress has not been made in defining and bringing forward measures to make public transport more relevant and attractive, principally through reducing bus journey times and increasing service reliability. There is clear evidence that the management of the network in the plan area is contributing to ongoing serious deterioration in the unpredictable unreliability of services.\n\nThe results of the situation described above are that not one of the planning authorities have been able to demonstrate a rolling 5-year supply of housing, for most of the period since the plan was adopted. In fact, given that at adoption, the trajectory that supported the plan had no credible means of being met even on the most ambitious and optimistic of assumptions, it is arguable that a 5-year supply has ever been demonstrable. The JCS can thus only be judged to have failed in meeting its key role in providing for the development needs of the area.\n\nThe consequence of this has been an increasing rate of consent of small-scale development, each as a departure from the adopted plan, under the presumption in favour of sustainable development set out at paragraph 11 c)-d) of the National Planning Policy Framework (NPPF). Much of this has been small and widely dispersed villages in Tewkesbury Borough. In many of these, public transport choices have been highly restricted, being limited to a few buses per day, with lengthy journey times to settlements offering a meaningful range of social, economic and other opportunities. In some, most notably Twyning, multiple developments have been consented with no public transport provision at all. The cumulative impact of this in making the plan area that much more fundamentally car dependent, is real, but has never been properly assessed. This includes the aggravation of existing congestion at multiple points in the wider network, affecting the efficient reliable operation of bus services, often far from the developments themselves.\n\nThe “immediate review” of the JCS never took place. Halting progress started to emerge in 2019. Importantly, Stagecoach was a participant in a transport stakeholders’ working group, and was thus able to offer insight and commentary on the emerging methodology for the transport evidence base for the JCS Review, and aspects of the site selection methodology. \n\nHowever, just prior to this, Tewkesbury Borough Council initiated a very public promotion of a very large-scale “Garden Town” at Ashchurch (AGT), which secured substantial public funding commitments, including for infrastructure, despite having absolutely no planning status and no meaningful transparent technical evidence base to either demonstrate its appropriateness, much less its deliverability. We are aware that Stagecoach wrote to the Chief Executive of the Council at the earliest possible stage warning of the risks surrounding this strategy. Central to concerns was that neither highway capacity, nor any meaning baseline level of public transport provision was available to support most of the putative area identified, except a small area immediately west of the Bristol to Birmingham rail line.\n\nWe recognise that most of the AGT land north of the A46 is now under developer control, and active promotion. Weremain concerned that the development potential of the area is properly tested against all the reasonably alternative options, having regard in particular to both the broad location of the site at the far northern edge of the plan area, its infrastructural requirements, and its ability to secure a meaningful level of provision and use of sustainable modes. NPPF expects this. We continue to advise that for most of the site east of the railway, to provide relevant genuine choices to car use will prove to be quite challenging and costly. We consider the area south of the A46 east of the railway even more problematic as that will require an entirely separate set of services, with minimal ability to benefit from synergy with land to the north, from which the MOD Ashchurch site largely severs it. Internal self-containment across most of AGT will also take years to achieve in the absence of the early provision and developer subsidy of the operating as well as capital costs of a full range of services. The degree to which AGT will be dependent on delivery of major upgrade and/or relocation of the A46 Trunk Road between Teddington Hands and the M5, including relocation of Junction 9, presents a major unanswered question.\n\nWe thus note and welcome that the previous JCS Review has been abandoned. Previously we are aware that Stagecoach had serious concerns about the effectiveness of emerging approaches to assessing sustainable transport connectivity and the potential for public transport. A “clean sheet” approach is certainly advisable.  In truth, there is clear evidence that the JCS delivery is starting to gain some momentum and accordingly, the plan-making process can rightly be afforded the time it needs to arrive at a robust and rigorous development strategy, founded on proportionate, relevant and up-to-date evidence, as NPPF continues to expect.\n\nAmongst other things this evidence base is the recently prepared Gloucestershire Local Transport Plan (GLTP4) adopted in Summer 2022. There is also now important new national policy, including the National Transport Decarbonisation Plan, which at Part 5 is explicit that it expects local land-use plans to align with transport planning much better and to progress development strategies that are much more tightly tied to achieving the patterns of development that reduce the need to travel, the distance of spatial interactions, and maximise the potential for sustainable modes and the wider achievement of mode shift away from private car use. “Business-as-usual” approaches as have been used over the years since 1998 have had little or no impact on car dependency and use across England. Indeed, with few exceptions, Census data in 2011 and 2021 show that in development completed since 1994 across England, car dependency is at the highest levels of any typically found in a locality, with relatively few exceptions.\n\nWe note the new Strategic and Local Plan (SLP) as it is now called, is an entirely new unitary joint Local Plan containing both strategic and non-strategic policies. As such, it replaces both the JCS and the “Part 2” individual non-strategic local plans (which didn’t include strategic policies). We welcome and support this approach.\n\nIn so doing, we expect properly prepared, thorough transport evidence to support the plan strategy. For this to take place, a much greater focus needs to be placed on evidence of the effectiveness and deliverability of high-quality public transport choices, to new developments, including the potential to boost further the sustainability of travel options at existing planning commitments in build and yet to commence, where synergies are identifiable on key corridors, for example. It is for this kind of reason that NPPF expects plans to be prepared with ongoing engagement and collaboration with “transport infrastructure and service providers” (Para 15 c)). \n\nRecent experience with the Stroud Local Plan Review and its submission and examination shows just how important this is. Stagecoach was consistent in advising the preparation of that plan from the very outset, through duly-made representations, though at no time was the Council willing to meaningfully engage with the Company. Stagecoach, alongside many other stakeholders, became increasingly alarmed that the development strategy was advanced ahead of and indeed despite very substantial transport evidence deficits. The Planning Inspectorate was clear that these concerns were fundamental and very well-founded. The cost including to the public purse, and delays to the delivery of much needed development associated with this serious failure are as regrettable as they are evident. It is essential that all the lessons of this are learned as the SLP is advanced, which is even more crucial for the environmental, social and economic future of the area.\n\nWith the requirements explicitly set out in NPPF in view, we urge the SLP authorities to reconvene the transport stakeholder group, including a bus operator representative, as well as the railway, National Highways and the County Council who also have statutory status.\n\nPulhams have set our comments out above for the benefit of the Councils and other key stakeholders in the Plan, and we trust that they can be received as duly made, and a helpful intervention at this most important initial stage. If the foundational objectives and spatial approach of the plan are sound this offers the greatest prospect for the plan-making process as a whole to be rigorous and soundly based.\n\nWe look forward to working collaboratively with you and other stakeholders to bring a sound and effective SLP forward propitiously.\n"]
["Statutory/Specific Consultee","Southam Parish Council ",20,"Infrastructure – reservoir/water treatment\nInfrastructure – traffic routes – making improvements to safety on existing roads and dealing with congestion on existing roads\nEmployment – a study should be conducted to assess where and how people travel to work as the policy is not adequately supported by facts\nProviding adequate homes – should include improvement of existing homes\nProviding adequate local services and amenities proportionate to the developments being proposed including schools.\nIntegration with neighbouring Local Authorities re their development strategy and how it impacts on CBC, GCC and TBC e.g. development in Evesham impacting roads in TBC.","None – they are generalised","","Not 100%","","Not 100%","Preservation of the Green Belt\nCreation of new Parks and Gardens as part of all new developments\nSolar and renewable energy on all new homes – help for existing homes\nElectric charging points – county wide and on new homes & help for existing homes\nNo more out of town retail parks\nProvision of community gardens/orchards for food growth","(a)\tstandards in relation to construction already exist i.e. The Building Regulations which define insulation standards, energy efficiency etc, so new standards are not required, but adoption of the existing standards should be mandated.\n","(b)\tSet a new benchmark standard and assist where necessary to achieve it","Yes","Yes","Common land could be used for recreation if properly managed i.e. not over populated","Provide facilities at an early stage in the development process and proportionate to the scale of the development to include\nGPs/Dentists/Chemist\nFood store\nCharging points/petrol station\nSchools and nurseries.\nPlay areas and formal parkland\nCommunity hubs/Youth activities/Nightlife & Music venues\nLeisure/Sports facilities/Exercise routes.\nCare homes.\nAdequate transport links\nAdequate parking on plot to avoid pavement obstruction.\nRetention of A & E in Cheltenham and improvement to hospital services there\nAllotments or Community Orchards\nPolice Station and CCTV coverage of shopping centres/leisure facilities","No"," – because this will ultimately be reducing agricultural land, better to put solar on all existing retail parks, factories","Yes","– if this method is approved by the Planning Inspectorate","","Tewkesbury should be able to count housing taken in for Gloucester and Cheltenham ","","Cheltenham should not be able to use prime land for grand design homes and not provide affordable housing.\nFor younger generation, 1st time buyer flats.\nDetached bungalows within mixed developments for older people instead of over 55s developments","Yes"," this should be prescriptive at say 0.25% of the housing stock being created, either within the development site or provided in a separate location but still as a consequence of the approved development.\nThe criteria for measuring traveller site need should also be reviewed. \n\nThey can only be met as part of housing site allocation","\nBrownfield sites/Local to highway routes/Away from sensitive landscaped areas e.g. AONB, SLAs.\n","High standard comms/wifi.\nGood transport links\nLocal touchdown space/Growth hubs.","Keep employment sites adjacent to motorway for ease of transport and commuting employees\nClose to facilities for staff to use.\nGood transport links.","Reuse of farm buildings as workshops and small businesses.","Densification so that all services are central.\nEncourage employment close to shops, parking convenience, safe environment/patrolled.","Ensure demographic is sustained to ensure businesses remain commercial.","New service roads and less reliance on existing roads\nAdequate drainage.\nHigh quality comms/wifi.\n+ THOSE LISTED IN Q10 ABOVE.","As Q10 and Q23\n\nProvide facilities at an early stage in the development process and proportionate to the scale of the development to include\nGPs/Dentists/Chemist\nFood store\nCharging points/petrol station\nSchools and nurseries.\nPlay areas and formal parkland\nCommunity hubs/Youth activities/Nightlife & Music venues\nLeisure/Sports facilities/Exercise routes.\n\nNew service roads and less reliance on existing roads\nAdequate drainage.\nHigh quality comms/wifi.\nCare homes.\nAdequate transport links\nAdequate parking on plot to avoid pavement obstruction.\nRetention of A & E in Cheltenham and improvement to hospital services there\nAllotments or Community Orchards\nPolice Station and CCTV coverage of shopping centres/leisure facilities","As in 10\n\nProvide facilities at an early stage in the development process and proportionate to the scale of the development to include\nGPs/Dentists/Chemist\nFood store\nCharging points/petrol station\nSchools and nurseries.\nPlay areas and formal parkland\nCommunity hubs/Youth activities/Nightlife & Music venues\nLeisure/Sports facilities/Exercise routes.","Yes","Yes","Small developments in rural villages proportionate to the scale and character of the village.","No","Scenario 5 has been deliberately weighted with Cons to draw the participant away from choosing it.  Yet it offers the most sustainable option to ensure that small rural schools are supported, that young people are not driven away from rural settlements to seek work, that elderly people are supported by a thriving community around them.  The argument that it increases reliance on the car is ignoring the fact that even in urban areas buses drive around empty of passengers and everyone relies on a car to shop, work, attend appointments etc. ","Scenario 1: Urban concentration;  Scenario 4: New strategic settlement","","Duty to cooperate with the Cotswolds","Do the needs of the homeless need to be considered?\n\nA more defined plan for the use of brownfield sites, both former housing and employment sites, to help satisfy future housing need.\n\nLand assessed for housing within the HELAA exercise should respect previous planning/appeal decisions and take into consideration green belt status of land, together with the impact that development would have close to AONB and SLAs, therefore we believe such sites should be written out of the plan. \n\nComments regarding 3 opportunity sites bordering Southam Village. (SOU006, 007,008)\n[Q1] 15 -20 years to allow an adequate time span for larger strategic developments to be fully implemented.\n \n1 Southam is situated on highly visible rising ground on the lower slopes of Cleeve Hill and adjoining the Cotswold AONB.\n\n2 The sites in question are situated in Green Belt or Special Landscape Area or both, and constitute part of the valuable green wedge between Prestbury and Bishops Cleeve/Woodmancote. This protection was put in place for good reasons which should not be forgotten.\n\n3 As green spaces, all sites contribute to the special setting of Southam, the boundaries of which have remained protected for many years, presumably due visibility and proximity to the AONB. One quoted definition of a Special Landscape Area is that it 'provides protection for locally significant and attractive landscapes that are of comparable quality to AONB. They should be protected and enhanced through the planning process.' \n\n4 All sites are highly visible from Cleeve Hill and the Cotswold Way, Southam being one of the closest settlements on the rising ground at the foot of the hill. Any major development of these sites would constitute enormous intrusion into these views. See attached photographic overlays.\n\n5 The potential capacity of these sites together generates in excess of 500 new homes which would effectively double the size of the village, and put an end to the nature of Southam as we know it. How is need assessed and does this capacity reflect a fairly apportioned need? Ideally the strategy should fairly assess housing needs on a parish by parish basis rather than 'maxing out' any available green belt just because it's there.\n\n6 Even a partial development of these sites will put additional pressure on an existing highway network that even now fails to cope with the 'short cut' nature of Southam Lane, particularly when major events are held at Cheltenham Racecourse.\n\n7 One of the sites, with a reported capacity of 131 new homes, has a suggested access via Ratcliff Lawns. This quiet residential road is unadopted, and is a place where children play and horse riders, dog walkers, and elderly people enjoy the calm. Such a new development would create a massive and irrecoverable loss of amenity to local residents.\n\n8 Surface water drainage in parts of the village is unable to cope and lower Southam Lane is nearly always wet. The fields around the village act as a giant sponge to slow run off from the hillsides. Imagine how bad things would be if those fields were replaced by the hard standing and road systems to service 500 homes.\n\n9 One of the sites borders the area of Cheltenham Racecourse which is currently used as a temporary airfield during race weeks.\n\n10  Bishops Cleeve has been over-developed and we have seen a rise in crime statistics.  Reducing the opportunity for crime might be a priority for the plan. "]
["Resident",null,"","","","No","There seems very little consideration of the actual impact of major development on small communities. There is something very unique about villages and hamlets. Residents chose to move to them for the quality of life they offer and are understanding that if they choose to live in them they may have compromised local services - access to local transport, medical and education services for example. Building more homes without ensuring adequate infrastructure is mindless. Plans to develop the area around Minsterworth, Highnam and Churcham do not consider the very inadequate road system. The A40/A48 are already clogged morning and evening. Access to the M5 is either down to Cheltenham or through Gloucester City. But the basic concern we have is building on green belt and flood plain land, establishing large developments that will spoil for ever the unique rural spaces we have.","No","Not regarding our local area. Proposed development is too large for an area that is struggling now to support traffic flow, access to schools, medical support etc. Any long-term plan should include another Severn crossing easing traffic flow from Ross/FoD areas","The additional traffic flow on the A40/48 will only add to the pollution especially traffic slowing trying to get through traffic jams and Gloucester City","Please consider the greenbelt and the beauty of the landscape. We do not want huge estates attached to villages and hamlets. We do not want to see small semi-rural communities subsumed into large towns and cities. More development of brown field sites and refurbishment of existing housing stocks please","As above!","Yes","Yes","Land between Minsterworth and Churcham is flood plain. The area is criss-crossed with numerous ditches and streams on clay soil. Any development will affect the water table and push any rainfall elsewhere. This has been noted this year in Longford which flooded badly and no coincidence that nearby land has been developed","Road structure. Schools. Medical support","Yes","A new Severn crossing would provide an excellent opportunity for developing wind power","No","Is there any consideration of where all these people are going to work? Are there significant plans for any new local businesses moving to the area? Are we in danger of building dormitory areas with no community feel??","","","Yes","Probably more social housing required","No","Consideration of where these are located. Tewkesbury already has significant traveller sites along with Gloucester (there are several already in Minsterworth)","We wouldn't support the development of any existing sites","Government grants??","","There won't be any rural areas they way we are going? Building on farm land destroys agricultural employment!","This is absolute key. Brown field sites and refurbishment of existing buildings. Debehnhams in Gloucester is a great example of urban renewal. Reducing rates for businesses and at least some free parking would all help towns and city business to thrive - and not just coffee shops!","","Improve the road network!! Build a bridge!!","as above","Roads. Schools. Medical facilities","Yes","Yes","Brown field development. How can we secure our food supplies if we continue to build on green field farm land??","No","Already answered. Plans around my area are just too extensive","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 1: Urban concentration; Scenario 2: Urban extensions","","Possibly look more at the M5 corridor?","We remain very concerned at the constant drive (national not just local) to build on green belt and over-develop rural areas. It's part of a much bigger picture. Food security is a huge issue yet we allow land agents to buy up farmland instead of looking to see how much more we can support farmers and help them diversify their business model (this would support rural employment - farm shops, farm experiences).\nConcerned that the consultation process seems to have been largely IT-focussed which many elderly people in the population have little or no access to computers"]
["Statutory/Specific Consultee","Bredon Parish Council ",15,"No","","Yes","Overall, Bredon & Bredon’s Norton Parish Council (the parish council) agrees with the aspirations that are set out in the draft Vision. However, we would like to make the following suggestions to improve the draft Vision.\nThe first paragraph of the draft Vision states that ‘Growth will have afforded the highest possible quality of life for all in a manner which achieves carbon reductions and addresses the causes and effects of climate change’.  Achieving carbon reductions is not aspirational enough. Instead, the Vision should set out an aspiration to achieve ‘net zero’.\nThe fifth paragraph of the draft Vision refers to ‘conserving the area’s special landscapes’. We support the inclusion of aspirations relating to landscape within the draft Vision. However, we do not consider that this statement is aspirational enough and does not reflect national policy relating to landscapes. Firstly, we consider that this statement should make explicit reference to the Cotswolds National Landscape (CNL) and its setting, reflecting the national importance of this designation. Secondly, the statement should make explicit reference to the statutory purpose of CNL designation, which is to conserve and enhance the natural beauty of the area. We suggest that this statement should be changed to:\n•\tConserving and enhancing the natural beauty of the area’s special landscapes, including the Cotswolds National Landscape and its setting. \nThe fifth paragraph also refers to ‘a network of green spaces’ helping to secure ‘a high-quality environment for people and nature’. It also refers to ‘improvements to biodiversity’. Again, these statements are not aspirational enough. The aspiration, with regards to biodiversity, should be to deliver a nature recovery network that is of sufficient quality, scale and connectivity to secure nature’s recovery.","Yes","Overall, the parish council agrees with the draft Strategic Objectives.\nPlease also have regard to our comments on the draft Vision.","In principle, the parish council supports the measures that are set out in the Strategic and Local Plan consultation document.\nIt would be helpful if the Strategic and Local Plan could differentiate between climate change mitigation and climate change adaptation, where appropriate.\nWith regards to climate change adaptation, priority issues should include nature recovery, sustainable drainage and flood management. With regards to nature recovery, consideration should be given to the Cotswolds National Landscape Board’s Nature Recovery Plan.","The plan should adopt a design code based on different character areas. Within a ‘Cotswolds character area’ (including areas bordering the Cotswolds CNL), particular emphasis should be given to preserving and enhancing locally distinctive Cotswold character as set out in the CNL Management Plan 2023-2025 and associated guidance (cf also the draft Wychavon Design Code).","The plan should adopt a design code based on different character areas. Within a ‘Cotswolds character area’ (including areas bordering the Cotswolds CNL), particular emphasis should be given to preserving and enhancing locally distinctive Cotswold character as set out in the CNL Management Plan 2023-2025 and associated guidance (cf also the draft Wychavon Design Code).","Yes","Yes","The parish council recommends that the Lower Carrant valley be identified as an area of existing high ecological importance with the potential for further enhancement. \n","The parish council considers that the key services and facilities that are most important to be provided within easy reach of developments include shops, schools, health services, green infrastructure and public transport (at a level that is sufficient to enable access to and from key services / facilities and to enable commuting to and from jobs in local employment centres).","","The parish council considers that the allocation of sites specifically for renewable energy generation or storage, could potentially be acceptable provided that the type and scale of renewable energy generable / storage that would be accommodated in the allocation is compatible with the statutory purpose of conserving and enhancing the natural beauty of the Cotswolds National Landscape and other protected landscapes. \nAllocations for large-scale renewable energy schemes in the CNL or to a lesser extent its setting would not be compatible. \nWe consider that the identification of ‘suitable areas’ for renewable energy (specifically wind and solar energy) is a higher priority than the allocation of specific sites. ","","The parish council does not object to the ‘standard method’ figure being used as a starting point for identifying the housing requirement that will be set out in the Strategic and Local Plan. However, we strongly object to the principle of this figure being used as a target.\nThis reflects paragraph 11bi and footnote 7 of the National Planning Policy Framework (NPPF), which set out the circumstances in which it may not be necessary for strategic policies to meet objectively assessed needs (i.e. the standard method figure) in full. Also, the recent (December 2023) change to paragraph 61 of the NPPF, which now clarifies that ‘the outcome of the standard method is an advisory starting-point for establishing a housing requirement for the area’.\nIt also reflects the Government’s planning practice guidance on the ‘Natural Environment’, in relation to development in protected landscapes, which states that the NPPF’s policies for protecting these areas ‘may mean that it is not possible to meet objectively assessed needs for development in full through the plan-making process’ , as well as planning practice guidance on ‘Housing and economic land availability assessment’, which addresses the way in which ‘constraints’ should be addressed when identifying housing requirement figures in local plans. \nIt is important also to note The Secretary of State, Michael Gove, has recently stated that the number of homes identified using the standard method ‘was supposed to be advisory’. He went on to state that the new NPPF ‘now, more clearly, upholds the spirit of the original intention. Local authorities have the comfort of knowing that they need not re-draw the green belt or sacrifice protected landscapes to meet housing numbers’. \nConsideration will need to be given to whether it is realistic to achieve the Standard Method figure without causing (significant) harm to relevant assets, including the CNL and the green belt. If it is not possible the deliver this amount of housing without causing significant harm to these assets, consideration should be given to a lower housing number.\n  https://www.gov.uk/guidance/natural-environment#landscape. Paragraph 041. \n  https://www.gov.uk/guidance/housing-and-economic-land-availability-assessment \n  https://www.gov.uk/government/speeches/falling-back-in-love-with-the-future ","","Please refer to the parish council’s response to question 12.","Yes","The parish council recommends that 100% affordable housing should be provided on Rural Exception Sites, with a lower percentage being permitted only in exceptional circumstances; with the absolute minimum being 75%.","Yes","No","","","","","","","","If a strategic scale new settlement at Ashchurch/Tewkesbury were to form part of the plan, a comprehensive solution to acute traffic congestion on the Strategic Road Network at A46/M5 J9 would be needed for any large-scale allocations to become viable. Comprehensive downstream flooding prevention measures may also be needed, as well as enhanced capacity to water supply and sewerage infrastructure.","","Yes","Yes","The parish council recommends that consideration should be given to a scenario that doesn’t involve major development within the CNL or its setting that would harm the biodiversity or natural beauty of the area. ","","The parish council considers that the pros and cons identified for the six development scenarios are fair and accurate. However, there are some additional points that should be reflected within the pros and cons, as outlined below. \nScenario 1 – Urban concentration\n\nThe ‘pros’ should include reducing development pressure on the CNL.\n\nScenario 2 – Urban extensions\n\n The ‘cons’ should include:\n\n•\tAdverse impacts on views from and to the CNL, with regards to development in the setting of the CNL.\n\nScenario 3 – Urban extensions, avoiding the Green Belt\n\n The ‘cons’ should include:\n\n•\tAdverse impacts on views from and to the CNL, with regards to development in the setting of the CNL.\n•\tPotential increased development pressure on the CNL and its setting.\n\nScenario 4 – New Strategic Settlements\n\nWith regards to the potential new strategic settlement at Ashchurch, the ‘cons’ should include:\n\n•\tPotential adverse impacts on views from the CNL.\n•\tPotential adverse impacts on downstream flood risk\n•\tPotential adverse impacts on biodiversity and natural beauty\n•\tPotential adverse impacts on dark skies.\n\nScenario 5 – Rural Dispersal\n\nThe ‘cons’ should include:\n\n•\tExcessive development pressure on the CNL and its setting.\n•\tPotential adverse effects on the natural beauty of the CNL.\n•\tPotentially excessive increase in traffic movements.","Scenario 1: Urban concentration; Scenario 2: Urban extensions","","","Q8) The parish council recommends that the Strategic and Local Plan should require more than the mandatory minimum 10% Biodiversity Net Gain through development, particularly in the CNL and in locations that are identifies as priority locations for nature recovery. It is noted that the CNL Management Plan 2023-2025 recommends that ‘development proposals should provide a net gain in biodiversity of at least 20%’ (policy Policy CE7).\n\nQ26) The parish council recommends that consideration should be given to safeguarding sites or route for longer term infrastructure projects. \nA key issue, in this regard, is the proposed ‘M5 Junction 9 and A46 (Ashchurch) Transport Scheme’, which would involve a new or re-configured M5 junction and would re-route the existing A46 around Ashchurch to the Teddington Hands roundabout.  Housing schemes (and other development) are being permitted on the proposed route. If this were to continue, it would potentially make such a scheme unviable.\nThe proposed scheme is located within the setting of the CNL. As such, consideration would need to be given to the potential impacts of the scheme on views from the CNL and to potentially increases in traffic movements through – and along the boundary of – the CNL.   https://www.gloucestershire.gov.uk/highways/major-projects-list/m5-junction-9-and-a46-ashchurch-transport-scheme/ \n\nThe parish council would like to highlight the new statutory duty on relevant authorities to seek to further the purpose of designation (i.e. to conserve and enhance the natural beauty of the CNL), which came into effect on 26 December 2023. The three local authorities will need to take this statutory duty into consideration as they progress the Strategic and Local Plan.\n\nWe recommend that the Strategic and Local Plan should require development proposals to demonstrate the measures that have been taken to further the statutory purpose of conserving and enhancing the natural beauty of the CNL.\nWe note the requirement for local authorities to produce a Local Nature Recovery Strategy.\nThe parish council considers that a combination of Scenario 1 and Scenario 2 are likely to lead to the best outcomes for future residents."]
[null,null,15,"Conserving and enhancing Best and Most Versatile Agricultural Land / promoting local food production","Staverton Airport /Cheltenham Spa waters","No","a greater emphasis on the conservation and enhancement of existing rural areas and countryside and local food production","No","please refer to 5 above","Reducing private car dependancy and HGV usage by promoting alternative forms of transport including waterways","High standards as to aesthetics and function and strict compliance with regulations","With discretion, as much as possible","Yes","Yes","Land (including Grade 1 Agricultural Land) to the North West and West of Cheltenham  for environmental purposes and local food production","Doctors, Dentists, Vets, Police, Community Hospital / Health Centre, Allotments, Crematorium  and Community Centre with library and for provision of food and drinks and events","Yes","Hydroelectric power harnessed from the Severn estuary and Wind turbine power generated off the Cotswold escarpment","No","In accordance with the principles of subsidiarity and devolution of as many powers as possible Local Authorities should decide  based on their unique knowledge of the local area, its historical and current uses and future potential","Yes","please see reply to 12 above","Yes","for ageing population and disabled / special needs","Yes","Their traditional lifestyle should be respected and not impeded","Grazing / access to unpolluted water  / toilet and washing facilities","Those which are of benefit to the community and environment, non polluting and taking place in in attractive and sensitively designed buildings / units.  Good transport with an emphasis on reduction of private car and `HGV usage","please see 18 above","please see 18 above and to promote local food production","Acceptance and response to the probably irreversible decline in the retail trade in city and town centres.  Consequently, serious thought should be given to the conversion of redundant retail space to a mixture of attractive and well designed residential use with generous green and open spaces encouraging a sense of community.  Combined with the release of a vast area of redundant car parks through a major transition to alternative forms of transport away from the private car could be exciting and of enormous benefit","To actively promote this policy and its evolution","Good public transport / cycle tracks / footpaths / please see reply to 10 above","Please see reply to 23 above","Good public transport / Community centre providing a variety of services / please see reply to 10","No","No","","Yes","","Scenario 1: Urban concentration","","","Protection of the countryside is also needed for healthy lifestyle\n\nAll policies should be directed to the substantial mitigation of noise, air pollution and flooding\n\nIt is not accepted, in practice, the process to alter Green Belt boundaries is as robust as presented @ para 6.21 on page 39\n\nWhilst populations are ageing they may numerically be falling\n\nThe deprivation factor has to be addressed.  In Gloucester it is high.  In Cheltenham it is moderate.\n\n\n\n"]
["Planning agent or developer","Boyer Planning ","","Please refer to the accompanying Written Representation and associated technical documents.","Please refer to the accompanying Written Representation and associated technical documents. ","Yes","Please refer to the accompanying Written Representation and associated technical documents.","Yes","Please refer to the accompanying Written Representation and associated technical documents. ","Please refer to the accompanying Written Representation and associated technical documents.","Please refer to the accompanying Written Representation and associated technical documents.","Please refer to the accompanying Written Representation and associated technical documents.","No","","","Please refer to the accompanying Written Representation and associated technical documents. ","","","Yes","Please refer to the accompanying Written Representation and associated technical documents.","Yes","Please refer to the accompanying Written Representation and associated technical documents. ","","","","","","Please refer to the accompanying Written Representation and associated technical documents.","Please refer to the accompanying Written Representation and associated technical documents. ","","","","Please refer to the accompanying Written Representation and associated technical documents.","Please refer to the accompanying Written Representation and associated technical documents. ","","","","","Yes","","Scenario 2: Urban extensions","","","Please refer to the accompanying Written Representation and associated technical documents for further details."]
["Statutory/Specific Consultee","Environment Agency ","","Within Cheltenham Town Centre the presence of the Chelt Flood Alleviation Scheme and uncertainties on the impacts of climate change mean some types of development i.e. basement residential dwellings may be deemed unsuitable and should form a council specific policy. This may also be relevant within Gloucester City Council in relation to the local urban watercourses.","","","","","Point 5 Should differentiate between new development and energy infrastructure. It is considered as it stands this gives developers the opportunity to avoid contributing directly to the wider goal of providing opportunities to deliver renewable energy supplies. Point 6 It should be made clear the term flooding relates to all forms of flooding.","","Make the installation of solar panels on all new built development mandatory within the local plan area and encourage installation retrospectively on brownfield sites for change of use. This will help to effectively meet the target of delivering and reducing the impacts on other parts of the vision delivery and potential conflict with other existing or newly adopted policies within the SLP.","Make the installation of solar panels on all new built development mandatory within the local plan area and encourage installation retrospectively on brownfield sites for change of use. This will help to effectively meet the target of delivering and reducing the impacts on other parts of the vision delivery and potential conflict with other existing or newly adopted policies within the SLP.","","","","","Yes","Both large scale solar generation and battery storage. We would also highlight major solar regeneration is also included within the Built Environment section of the table in 4.15. The strategy needs to be meaningful and link all strategic key visions to avoid contradiction within key policies. Hence location of major solar projects should abide by the key policy points for all other development in relation to other key principles such as flooding, loss of productive farmland, impacts on the environment and preference of use on brownfield sites that would also encourage retro fitting. In the absence of any meaningful national guidance, the SLP provides an appropriate opportunity for a co-ordinated and more imaginative approach to delivering sustainable energy for the wider council area.","","","","","","","","","","","","","","","","","","Yes","","","","Scenario 1 within the cons the fact that this approach may conflict with other existing principles within the National Planning Policy Framework such as flood risk may make them both unsustainable and inappropriate for delivery, especially in relation to the potential impacts of climate change.","","","",{"$cut":{"chars":22903,"head":"During the consultation period I have liaised with our various internal teams covering different environmental matters. Those teams have provided me with comments; some include answers to the consultation questions, some have provided general advice, and some have provided succinct points to raise. It has not been possible to precis the more lengthy comments and so I have included them in their entirety either in the body of this letter or as an appendix at the end. Where they appear in the appendix I have provided brief paragraphs in the body of the letter to give an introduction to that environmental theme. We welcome the opportunity to work with you on the evidence base for the SLP. As discussed some of the more detailed elements of this are likely to come under our Cost Recovery Service. We welcome that you have notified us of your intent to carry out Strategic Flood Risk Assessment (SFRA) and Water Cycle Study (WCS) and we look forward to working with you on these documents – they will be essential to delivering a sound plan. To help inform your options and ensure a sound plan, you will need to undertake a Strategic Flood Risk Assessment (SFRA) as part of the Local Plan evidence base. We understand you wish to update the Level 1 SFRA (the original Gloucestershire wide version is dated 2008 so we believe this may be prudent. The Level 2 SFRA will be required to really focus in on those areas where land is expected to be allocated for development. It should be used to assess and justify your options and possible allocations. It should help ensure that any sites, particularly those associated with higher levels of growth, are sequentially tested so that they are demonstrated to be located in areas of lowest flood risk - preferably Flood Zone 1 and outside of the 1% climate change floodplain. Strategic Flood Risk Assessment guidance is available on gov.uk at: \nhttps://www.gov.uk/guidance/local-planning-authorities-strategic-flood-risk-assessment \n\nWith regard to managing wastewater and water resources, a Water Cycle Study (WCS) will need to be undertaken to inform the Plan. This will inform wastewater infrastructure delivery and requirements, water resources and water efficiency requirements (for example within a locally specific criteria based policy) linked to more stringent ‘optional’ water efficiency targets where justified. We recommend early liaison with the water companies to identify which sewage treatment works will serve future development, whether there is capacity in the network and when any infrastructure improvement projects are envisaged. This will help to inform sustainable development locations as well as any necessary phasing constraints for development. We would not wish to see any strategic allocations being located in areas that will not be served by mains foul drainage. \n\nLarge parts of the current sewerage system serving Gloucester/Cheltenham and Tewkesbury are being overwhelmed due to hydraulic flows that discharge raw sewage into our watercourses at times of high rainfall. Planned development will only make this worse without considerable and expensive enlargements to the sewer network that will take a long time. The pumping stations and rising mains are under considerable pressure and there is increased risk of burst sewers without considerable investment There is additionally capacity issues at the large sewage works that have suffered from under investment and this has resulted in more pollution incidents and reduced water quality. New or upgraded sewage works will be required.  Storm sewage overflows are in the national media and again further development will only increase this pressure. This emphasises the need for the WCS to help deliver infrastructure alongside planner growth to avoid such instances. Severn Trent Water should be a consultee to provide their expertise. Sewage treatment is a big issue and needs to be higher up the profile of infrastructure.  \n\nThe latest guidance on the preparation of WCS can be found on the Gov.Uk website:\nWater cycle studies - GOV.UK (www.gov.uk) The SPL"}}]
["Business owner","Pulhams Coaches Ltd.","","Pulhams considers that the strategic policy topics set out are comprehensive and this is welcomed.","Pulhams consider that the strategic policy topics set out are applicable across the plan area.","No","Pulhams consider that the draft Vision or the SLP is broadly comprehensive but fails to properly direct the plan strategy \nwhere the pressing need to secure a more sustainable balance of travel choices by sustainable modes is concerned, and public transport in particular. On page 15, g) fails to state clearly that high quality sustainable travel choices that are competitive with driving must consistently be delivered across the plan area to secure the Vision, and conformity with both the adopted GLTP4 and national transport policy, and planning policy expressed at paragraphs 108-110 of NPPF. Point j) makes reference, as an example to “Mass Transit Corridors”. Notwithstanding the policies in GLTP4, these are yet to be defined. The plan must have a clear and unremitting focus on deliverable sustainable transport outcomes, without being spatially tied to a specific unfunded and undefined solution. Without such a focus, the strategy would be subject to material delivery risks, that could go to the heart of the soundness of the plan. The focus of the plan should accordingly be on “high quality public transport corridors”. To address the above points, Pulhams consider that the draft Vision or the SLP should be altered as follows: Draft Vision By 2041, and beyond for larger scale developments, the Cheltenham, Gloucester and Tewkesbury area will have … Investment in training, skills and development will have attracted and retained a younger \nworkforce and provided new premises and flexible workspaces to support a flourishing circular economy in both urban and rural areas, and the delivery where necessary of facilities to support expanded public services. Inward investment, innovation and growth in key sectors including, amongst others, cyber and digital-tech, food/agri-tech, advanced engineering and tourism will have been fostered. People’s housing needs will have been met through the provision of sustainable, high-quality market, affordable and other specialist homes set in beautiful, safe places and conforming to sustainable standards of design and construction. The focus will have been on making best possible use of brownfield sites in built up areas and large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved. The vital role of the area’s city centre, town centres and high streets, as those places most accessible by sustainable modes will have been improved will increasingly be the focus of major trip generating land uses through careful management of development and land uses opportunities across the plan area.\nGrowth in sustainable locations will take advantage of and if necessary have enabled the provision of healthy, accessible and walkable neighbourhoods, the promotion of maximising the use of active travel and sustainable travel public transport, effectively rebalancing the and provision of new transport systems that work effectively to secure sustainable local mobility for local people existing and new neighbourhoods. Growth will have been supported by the provision of a range of essential the digital, transport, community and other infrastructure necessary to secure the plan’s strategic objectives and in support of wider national policy. Equally, …”","No","Pulhams consider that the draft Strategic Objectives of the SLP again,\naddress the main areas identified in a broadly comprehensive way, but \nlack sufficient clarity of intent to properly direct the plan strategy and policy where the pressing need to secure a more sustainable balance of travel choices by sustainable modes is concerned, and public transport in particular.\n\nPulhams consider that the draft Vision or the SLP should be altered as follows:\n\nDraft Strategic Objectives Meeting the challenges of climate change\n\n1. … 2. Ensuring growth takes place in sustainable locations that minimise the need to travel and provide genuine sustainable transport and active travel options sufficient to be competitive with car use, and secure high levels of use. \n\n\n3. Making the most effective use of previously developed land, including higher density development both in city and town centres and other locations well served by public transport. \n\n4. Ensure development effectively provides excellent access to local services by active travel modes through integration with existing adjoining development, and/or secures credibly high levels of self-containment at a suitably early stage. is a self-contained development that provides shops, services, facilities through walking, cycling or public transport. Public transport should be the natural first choice for trips beyond the neighbourhood. Prioritising sustainable transport and active travel \n1. Reducing the need to travel, and the need to travel long distances by motorised means, by pursuing a compact development strategy and compact forms of development creating real options that make active travel and public transport the natural first choice for healthy, accessible and walkable neighbourhoods where to access key services are available without the need to use motorised transport; \n2. Promoting the use of sustainable travel modes by focusing development in locations that are sustainable by virtue of their active travel and public transport connectivity offer, taking necessary opportunities to further improving existing safe walking and cycling routes and providing new frequent public transport links and in all new developments, where necessary securing new links to meet identified deficits; \n3. Materially reducing reliance on the private vehicle by improving access to services in rural and urban areas through new development, improved integrated transport links and supporting local and community led transport initiatives in the Local Transport Plan; \n4. Creating a genuine choice between different modes of transport by integrating new development with existing networks and enhancing these wherever possible.","If national legally binding targets for carbon mitigation are to be secured, then an unprecedented mode shift away from private car use is unavoidable in every scenario set out by Government. This is made very clear in the National Transport Decarbonisation Plan. \nThe role of development plans in facilitating this by aligning development strategies with the need to reduce the energy intensity and distance of travel should not be underestimated. \n\nThis is made explicit in Section 5 of the NTDP. While this is still yet to be made explicit in NPPF, the direction of policy travel is very clear. The language at 4.14 of the consultation document fails to recognise this at all, which is disappointing. It focuses only on urban design and building specification, having no regard to the fact that extensive patterns of development that extend journey distances make car dependency inevitable. Active travel and public transport can never be competitive with the car in developments thus located. \nIn fact, active travel or public transport too often is not even a credible choice, much less the genuine choice that NPPF paragraph 108 expects plan strategies to facilitate. Public transport is not even mentioned in the table at 4.15 under the “movement” theme, though it is in the \nsupporting memorandum. \n\nThe plan needs to have a clear and consistent vision, that is evidentially well-founded, for the role of public transport in securing sustainable mobility. For this to happen, this will require the plan evidence base to pay careful regard to those appropriate sites\nthat can take advantage of existing of potential high quality public transport corridors, and the development strategy should be appropriately steered by this evidence. Furthermore, if the plan is to be soundly based, the deliverability and effectiveness of envisaged public transport interventions to support the plan ought to draw on operator experience, in this regard, especially where improved or new public transport links are necessary. This new strategic plan needs therefore to pursue a spatial strategy that appropriately prioritises urban intensification, thereafter\na relatively compact form of development building on existing neighbourhoods and existing high quality public transport corridors to the extent that this is possible and appropriate, before extending the search to new stand-alone neighbourhoods and settlements, which, again, should be located on demonstrably effective existing or potential high quality public transport corridors.","","","","","","Traffic counts expose the degree to which peak car-borne journeys reduce at school holiday periods. Thus, the provision of sustainable choices \nto reach primary and secondary education sites should be paramount. 1200-1400 dwellings are typically considered sufficient to support economic and effective 2-form entry primary school provision. The ability to meet daily convenience shopping needs within a 5-minute each way walk\n (about 400-500m) ought to credibly be achievable even at net densities of 35 dwellings per hectare, given that this radius would put up to about 1700 dwellings within range. Factoring in of the land uses, a 1400-dwelling exclusive catchment is considered commercially capable of sustaining a sound convenience store offer. For off-site trips, a bus service operating no less than every 20 minutes with a journey time to a major town of no more  than 30 minutes, should be considered the minimum baseline offer to achieve even the current public transport mode share. A 15-minute frequency and 25 minute journey time is the minimum necessary to secure any prospect of higher bus mode shares than those typical in the urban areas within the\n plan. 30-minute frequency on evening and Sunday hours of operation is also necessary. Such services should typically be available within 500m of all \ndwellings on new developments, and ideally, closer.","","","No","The Councils should seek to follow the guidance published by Government to establish how far other factors, \nincluding economic growth potential, affordability and the ability to deliver sufficient affordable housing tenures,\nshould inform the potential to justify a higher requirement. The failure of the JCS to fail to deliver against  current housing needs is serious and compounds a situation that was already chronic especially in and around Cheltenham. This has directly impacted the ability of service providers including bus operators, to staff their operations. That this has disproportionately affected Cheltenham, of all the bus operating centres in \nGloucestershire, manifestly reflects the particularly severe lack of housing availability at any price, much less so\n affordable costs. There is an immediate need to bring housing land forward at policy compliant levels of affordable housing delivery. This justifies allocation of further land capable of early delivery in the plan period, immediately adjoining the existing main settlements and well placed with regard to local facilities, especially \nsecondary school provision, and public transport corridors. Given the extent of the statutory Gloucester and Cheltenham Green Belt, further limited tactical releases might be required.","","","Yes","There is an argument that the plan should set out to provide a proportion of new homes as social rent, where viability permits. There seems little need for intermediate tenures given that the national First Homes policy already demands this as a matter of course. Affordable rent homes hypothecated to “key worker” housing are also justifiable to address severe local skills shortages in public services. a. If so, please explain further. Multiple above inflation pay awards have still not entirely addressed the ability of some bus companies to recruit sufficient staff in and around Cheltenham in particular. Other service providers have similar problems. We urge the Councils to engage with providers, including the NHS, to establish the nature of these issues in more depth as part of the housing need evidence base.","","","","The plan needs to have much more regard to the underlying service economy that typically supports about half of all the jobs in a locality. Many of these are in the public sector, but far from all of them. Operational sites for key transport infrastructure and service providers are essential to maintain and enhance their operational capabilities. There is no meaningful room to deliver significant additional increases in bus mileage during the core daytime hours in the plan area, because depot facilities are at or close to capacity in the plan area. As it is, Pulhams is running significant numbers of vehicles into the heart of the area from its operating centre a considerable distance away in Bourton-on-the-Water at the start and end of the operating day. This is neither efficient nor especially sustainable having regard to the energy consumption involved in  this “dead” operated mileage. If the area is to see the electrification of the bus fleet, merely maintaining existing operating fleet resource will require more space. This is because the parking space needed to accommodate charging infrastructure generally reduces capacity by about 15-20% over the maximum diesel capacity. Much depends on the size and configuration of the depot site. Even assuming that only current bus mode share is achieved from committed new development, there is a clear requirement for more bus resource to be supported. Looking further ahead beyond 2031, the need to support this base level of organic growth cannot be supported by current depot capacity. If even relatively unambitious mode shift targets in GLTP4 are to be achieved, this would involve a near doubling of bus passenger boardings by 2031, and a greater figure beyond that point. The implications of this for planning operational support infrastructure needs to be carefully considered by GCC and the Councils. Bus depots do not fit into the statutory Use Classes Order. They are a sui generis use. There is high demand for general employment land across the plan area, and there is even more development pressure near main bus route corridors and town centres, both from commercial, employment, residential and other uses. Maximising urban capacity as the plan seeks to do, will also directly serve to remove land that might well be suitable for the necessary expansion of bus operations through redevelopment for other uses. One only need look at the situation within 1 mile of Stagecoach’s existing Gloucester and Cheltenham premises to see that the few remaining areas of low-intensity commercial uses, for example near the railway, are already being allocated and proposed for residential redevelopment. Land adjacent to the Stagecoach Cheltenham depot site, that was occupied under a short-term lease, is now the subject of a residential redevelopment proposal – reducing the capacity of the depot as a direct result. There is thus a direct requirement to examine how the plan might make specific provision to support the relocation and expansion of bus depots to support the County’s transport objectives set out in GLTP4 and the plans own transport strategy.","Employment growth needs to be properly provided for, not least to prevent further overheating in the commercial land and property market. The tendency, already apparent, will otherwise be for important employment and service activities within the plan area to be suppressed. Where existing employment cannot sustain the rental or other land values that are being demanded, these smaller established local businesses which are a crucial part of the heathy social and economic functioning of the plan area, are less likely to move, and more likely to contract or to close altogether. This kind of economic “sanitisation”, while superficially attractive on an aesthetic level, has a profoundly corrosive effect on society. Looking beyond the existing employer ecosystem, the plan area is remarkable in the breadth and diversity of the economic base, and the range of UK and multinational businesses present, many of which engaged in strategically significant knowledge based and high value-added sectors. Many of these firms are sited on legacy sites that benefit from being on existing public transport routes, for example at Staverton, of south of Bishops Cleeve. It is important that these companies can expand and reconfigure their operations without the significant costs and risks of moving. One of these would be that a technically suitable site is remote from credible sustainable access opportunities. Where inward investment is concerned, this must be directed to sites, whether specifically identified and allocated or not, that can support a high proportion of personal access requirements being met by walking, cycling and high quality public transport.","","For the last 20 years, national planning policy has sought to ensure that major trip-generating land uses are directed to town centres, and where comparison retail is concerned, a formal hierarchy was established that was based on a “town centres first” prioritisation. This policy was justified by a need to ensure that the central location and exceptionally high accessibility of town centres by public transport would support the location of such uses such that over time, a reversal of car dependency and use would be achieved. Locally and nationally, this has been all but entirely resiled from in the development control arena, faced by the economic strength of retailers who source the bulk of their revenue from affluent households for whom almost every adult has exclusive use of their own car. The rise of retail parks in peripheral locations has been to a very great result, the failure of the planning system, and this cannot just be put down to market forces, strong though they undoubtedly are. The role of town centres as places to meet and interact, across a full spectrum of backgrounds, is something the plan consultation document does not recognise. It should do if it is serious about achieving the full range of Strategic Objectives it already is intending to place at the heart of plan making. There are already clear signs that town centres are becoming vacated as much by the affluent as they are by retailers, leaving town centres increasingly dependent on and occupied by the most socioeconomically disadvantaged, helping feed a vicious spiral of decline. The SLP area is fortunate that in Gloucester, after many years the regeneration of the Kings Quarter is taking place; and at least as important, the large and prominent Debenhams building has found an exciting and highly productive new role. These are adjacent to the County’s most accessible point by sustainable modes, especially public transport. The consolidation of the University and many halls of residence into Gloucester’s central area is an extremely significant and welcome development, and further development of the post-16 Further and Higher Education into the main town centres can and should be facilitated as far as possible. This builds on the success of Gloucester Quays, which is now showing signs of positive consolidation as further investment has taken place at the northern end around the Customs House, and where the links with the historic city centre look likely to gradually strengthen as a result of the Castle redevelopment. Substantial primary research was undertaken in 2012 which showed the value of bus passengers to town and city centres. This work was based on Cheltenham and Gloucester. It showed that bus passengers spend less per trip than car-borne visitors, but generally visited a good deal more often, and thus their actual spend per head exceeded that of car-borne shoppers. Bus passengers are more loyal to town centres, which in terms of underpinning a sustainable town centre economy, less geared to increasingly “zero-sum” competition between venues requiring long car borne journeys, is clearly in every sense more sustainable. Strong town centres, able to develop and thrive as safe, animated venues, are crucial to a sustainable low-carbon future. The absolute and relative attractiveness of car-borne retail parks is already waning, as the ongoing long-term vacancies at many across the plan area testifies. Many of these represent excellent opportunities for residential redevelopment, or for other edge-of centre uses, including, potentially, R+D and laboratory space. It is therefore vital that existing and future levels of bus services can be properly facilitated in the town and city centres. There is already little if any space capacity at bus stops and stands in Gloucester City Centre, including at the Transport interchange. In Cheltenham the convoluted circulation of buses through Cheltenham town centre, particularly from north to south, is something that is inefficient and makes no positive contribution to townscape or the visitor experience in the strongest town centre, which is relatively resilient. Notwithstanding this, Frasers plc has announced the closure of the Cavendish House department store on Upper Promenade. The large and unremarkable building is in effect a legacy asset, which could easily be stranded. However we have long pointed out the merits of allowing buses to operate southbound only down this part of the Promenade, which would be likely to allow both more efficient bus access and circulation, and also allow other vibrant parts of the town centre, such as High Street west, to become fully pedestrianised. We are also in deep discussions with Gloucestershire County Council about how better access for cycling across Gloucester and Cheltenham City Centres can be facilitated without prejudicing access by bus services and their reliable operation.","The minimum turnover to sustain a convenience store is substantial, and in rural areas where car ownership and use is already very high, it is very hard to sustain any range of local shops and services, unless there is already a significant cluster of established businesses, where access to passing trade on a main through route also greatly assists. There may be a case, in some local villages where a local service centre function is identifiable, to focus sufficient additional new development to securely anchor convenience retail provision, or, in some cases, re-establish it. However, it is at least as important to ensure that as many villages as possible retain access by public transport to higher-order centres. These services need to operate at least 6 days per week, at least hourly. Focusing appropriate levels of additional development in the few larger villages on existing regular bus services might be considered as a logical option to maintain rural accessibility across quite large extents of rural Tewkesbury Borough.","As we have already stressed, the development strategy must ensure that further allocated development sites are located where existing high-quality public transport exists and/or where it can credibly be provided bus priority. Beyond that, where strategic allocations are concerned that are considered to require bus services to enter the development, it is vital that policy demands that both master-planning and phasing facilitates this in an efficient and rational manner at all points during the development life-cycle. In a very large number of cases, access by car is the only practical option, until the very last phases where primary streets are finally connected through and buses are able to enter. By this point high levels of car ownership and use are “baked in”. A clear policy expectation therefore needs to be set that phased deployment of high-quality bus services on large-scale development will take place, and that further development will not be permitted beyond established triggers set through development obligations in accordance with policy. Attempts to forestall and circumvent this by developers, formally or informally, needs to be met with robust enforcement action. Bus circulation and access strategies, including indicative bus stop locations on or adjacent to development, need to form part of the application and consent of all large applications at the initial Outline Application stage, if the site is not brought forward as a full application. There is neither justification nor need for this to be left to planning condition. There are several examples, including Gloucester Business Park within the plan area, where conditions to agreed permanent bus stop permissions have never been discharged, nor enforced. Beyond development sites, there is a clear need for urgent effective measures to protect bus services from chronic and increasingly unpredictable delay. We have been saying this for about 20 years. This is recognised in GLTP4 and the Gloucestershire Bus Service Improvement Plan (BSIP). This needs the SLP to have due regard to and align with these strategies, and, furthermore, to identify where the development strategy might justify and/or help facilitate additional bus priority measures.","For new settlements there is an even greater need to ensure off-site trips can be conveniently performed using public transport as by definition, they are likely to be sited such that cycling will be a less attractive option. Thus, it is essential that new settlement sites are located where existing high quality public transport corridors pass the site and/or where it can credibly be provided by augmentation or limited extension of existing services.","The settlement in its existing or expanded form needs to provide at the least for a 1 FE primary school, and a convenience store. A community hall and formal and informal public open space should also be available, or deliverable including playing pitches. The settlement should have, or justify the augmentation of bus services running at least hourly 6 days a week to at least one town centre, and ideally two.","Yes","No","No. Pulhams consider the six scenarios represent the full range of realistic alternatives that should be considered.","",{"$cut":{"chars":17751,"head":"[No was not specifically answered but the following text was given]\nWhile the advantages and disadvantages are described in reasonably broad and fair terms there are some clearly unsupportable assumptions and statements made, that we need to challenge. a. If not, which one(s) and what are your reasons? \n\n1. Urban Intensification This should made much clearer that development needs would not be met by a substantial margin, aggravating housing availability and affordability problems and suppressing economic potential. This is a serious disadvantage and would go the heart of the soundness of the plan. \n\n2. Urban extensions We broadly agree that the summary of pros and cons is fair and reasonable. We recognise that there are some good options, of a limited but still strategic scale south of Hatherley Way, and East of Churchdown that avoid the vast majority of disbenefits and secure advantages, including the ability to take advantage of high-quality public transport from first occupations, and the availability of secondary education within walking and cycling distance. However, they are relatively few and far between, and could not accommodate the majority of the likely residual development requirement that needs to be identified. \n\n3. Urban extensions, avoiding the Green Belt 6.23 makes the very helpful distinction between Green Belt policy and other protections to landscapes and habitats that have more objective and legally-based rationales: “Green Belt land is, as a matter of national policy, designated as a means of managing urban growth, rather than providing environmental protection. This scenario would include land which was  previously removed from the Green Belt in the JCS and ‘safeguarded’ to meet longer term needs.” The JCS removed and “safeguarded” some additional land from the green belt at Twigworth and at Hayden, adjoining existing strategic allocations A1 and A7, to help meet longer term development needs. These areas are included in this scenario. These areas are most likely to help consolidate demand for bus services already likely to be necessary at West of Cheltenham. At Twigworth, bringing forward the safeguarded land should seek to ensure that a bus route corridor from the eastern boundary of the current allocation is secured to the east towards Innsworth and/or Hatherley. These are significant inherent advantages offered by these options. The transport implications of these options are highly site-specific and not amenable to be broadly categorised. If options are on existing or potential high quality bus corridors – such as the A38 between Gloucester ad Tewkesbury or even north or west of Bishops Cleeve, they may offer some potentially good options, though mostly not as good as options that are loser to Gloucester and Cheltenham in particular, such as east of Churchdown. We do recognise that credible options on these sites would probably not be sufficient to meet the development needs of the plan area in full. However, that said, there is clear evidence that credible and potentially very sustainable options \nexist adjoining the Gloucester Urban area in Stroud District, both at Whaddon and at Hardwicke Green. These have been tested through the Stroud District Local Plan Review EiP within the last year. It is somewhat surprising and inexplicable that there is no reference to these in the condoc, especially since they were highlighted by the previous EiP Inspector for the JCS as being worthy of a future collaborative approach with Stroud District Council, who then brought these both forward as proposed allocations in a Regulation 19 plan within the last 2 years. The options south of Tewkesbury on the A38, as well as at Mitton that already have some planning status within the South Worcestershire Development Plan, are very well located on public transport corridors – though south of Tewkesbury needs very careful urban design to take advantage of the main Tewkesbury-Gloucester and Tewkesbury-Cheltenham bus corridors. \n\n4. New strategic settlements\nParagraph 6.29 refers to this option in the following terms:"}},"Scenario 6: Sustainable transport scenario","No","",{"$cut":{"chars":17518,"head":"[Q.1] The Consultation proposes a baseline date of 2022 and a horizon of 2042. NPPF is clear that plans must run for a minimum of 15 years beyond the date of adoption. Thus 2042 would be the earliest prudent horizon having regard to preparation and examination timescales. The Councils ought already to be aware that, after over 30 months of confusion and stasis at national level while major reform of the planning system has been deliberated over, a very large number of local plans are now being reprised and taken forward in parallel. This is going to cause a substantial issue in resourcing what could be an unprecedented requirement for Local Plan Examinations in the Planning Inspection National Service (PINs). Section 2.9 in the Consultation Document (“condoc”) states that “Some sites are large enough to justify a longer period if they were to be chosen.” This is plainly the case for AGT, which was always going to involve a very extended delivery period, and one likely to both dependent and follow on from investment on the A46 and M5, which for part of the national SRN; as well as the railway. Both are subject to 5-year planning periods. As such it may be prudent to align the plan period with National Highway Road Periods (“RP”). 2042 lies at the start of RP5 (2040-2045). It may be prudent for this and other reasons to look ahead to that date, to align the delivery of development with the need to secure major funding for highways infrastructure on the SRN, that may already be partly justified and to give the necessary certainty that these investments will align with the housing trajectory. The development quantum is plainly of a scale that is likely to make at least one very large strategic allocation necessary, which would be likely to extend beyond the plan period as currently defined. Irrespective, the base date of the plan should be 2020 or 2021. There has been a deficit in housing delivery against assessed need to date. The plan should not seek to “write this deficit off”, in effect moving homes that are already allocated to meet existing needs, and re-hypothecate them in effect to meet future needs.\n\n[Q.26] [This is a response to the question: Should the Strategic and Local Plan safeguard sites or routes for longer term infrastructure projects?] \n\nCertainly yes. This will be a necessary measure to demonstrate the deliverability of the plan and the key infrastructure needed to support it. This is likely to include transport measures already identified in GLTP4 and any successor Local Transport Plan. It should also include the committed infrastructure measures already progressing, in the plan area, but yet to commence or be completed. It is recognised that key interventions are not fully defined and preferred routes are not yet identifiable. This may well be the case on the A46 between Teddington Hands and the M5. It may be that a broad wider corridor needs to be identified for this and other schemes when there is sufficient certainty that they feature in the delivery programmes of transport infrastructure providers. We also invite the Councils to discuss with us the potential to identify suitable sites that might be necessary to accommodate future bus depot sites.\n\n[The followings are general comments] This document represents the response of Pulhams and Sons (Coaches) Limited (“Pulhams”) to the current consultation to the Issues, Objectives and Spatial Options for the Cheltenham Gloucester and Tewkesbury Strategic and Local Plan (“SLP”). It is made in close alignment with Cheltenham and Gloucester Omnibus Company Limited trading as Stagecoach West. (“Stagecoach”) who we understand are replying, as the largest operator, with a separate document. Pulhams and Sons (Coaches) Limited joined the Go-Ahead Group in June 2023, with a continuous heritage serving the public with bus and coach services extending over 100 years. Its main operations lie in Cotswold District, run from a modern base at Bourton-on-the-Water. However, it also runs significant mileage in the plan area, most under contract to the County Council. An imp"}}]
["Statutory/Specific Consultee","Stroud District Council",null,"SDC supports use of the NPPF as a basis for identifying the SLP’s remit in terms of strategic policies. We also support Gloucester, Cheltenham and Tewkesbury councils in taking the opportunity during plan-making to reconsider which issues are of cross-boundary importance, where a shared overarching policy approach would be necessary or desirable for you (described at para 2.7). \nIn addition to addressing issues of cross-boundary importance to the three local authorities involved, there are likely to be issues arising that are of importance to surrounding Gloucestershire authorities (Stroud, Forest of Dean and Cotswold). As hubs for employment, retail, services and leisure, Cheltenham and Gloucester act as significant focal points for Stroud District and for communities within a catchment that is much wider than the SLP area. Surrounding Gloucestershire authorities also share some major infrastructure issues with the SLP area. Whilst the SLP’s focus is naturally going to be on the three SLP authority areas, SDC would welcome a slightly greater emphasis on this wider functional relationship in future consultation documents and draft plan iterations.  \nAs the consultation document highlights (para 1.13 – 1.14), councils have a legal ‘duty to co-operate’ with other local authorities and SDC looks forward to continuing to engage constructively on various strategic planning matters, throughout the plan-making process.  ","SDC does not wish to comment specifically on the sorts of policy topics that are unique to individual council areas, neighbourhoods or communities. However, Gloucester and Tewkesbury (who are Stroud District’s immediate neighbours) may wish to have some regard to ‘locality policies’ in our own local plan (the Stroud District Examination Local Plan 2021 / eSDLP 2021) and to the broad strategic approach set out for adjoining areas of Stroud District – particularly the mini visions, key issues, top priorities and guiding principles for the ‘Cotswold Cluster’ of parishes, the parishes on ‘Gloucester’s Rural Fringe’ and those on the ‘Severn Vale’, where there may be opportunities to achieve complementary strategic outcomes. Some of our communities have extremely close cross-boundary functional and/or visual relationships (such as at Hardwicke/Quedgeley, Upton St Leonards/Matson and Coopers Edge/Brockworth); whilst direct ‘parity’ may not be appropriate in locality policies, SDC will support policies that seek to reinforce local distinctiveness and achieve cohesive, high-quality placemaking, regardless of local authority boundaries.\nYou may be interested in Stroud’s use of ‘parish clusters’ during our local plan review. The eight clusters appear as a thread, running through both the current adopted SDLP 2015 and the eSDLP 2021. By grouping parishes that share some geographic and functional similarities (originally during the plan-making process for the 2015 SDLP), we have been able to build up a picture of the particular needs and opportunities that most concern different parts of the district. The idea of parish clusters is an integral part of the portrait of our district and a useful place-shaping tool, which is carried through some evidence base documents and is increasingly becoming embedded into other SDC strategies and studies, beyond the Local Plan. Key issues and guiding principles are drawn from evidence and consultation – and these aspects, as well as the area-specific “mini visions”, provide a policy framework and useful hooks for communities involved in neighbourhood planning.  ","Yes","SDC broadly supports the draft Vision. However, we consider there should be specific acknowledgement of the role played by Gloucester and Cheltenham as major urban hubs, with a wider catchment than just the SLP area. It will be important to bear this role in mind throughout the plan making process. \n\nFor reference, Stroud District’s own Vision to 2040 (eSDLP 2021, p19) references our district’s “network of market towns, well connected to their rural hinterlands and complementary to the role of wider regional centres” – which should be taken to include both Gloucester and Cheltenham. ","Yes","SDC supports the review of the existing JCS strategic objectives, taking the publication of the new NPPF into account. SDC particularly supports a stronger emphasis and priority being given to climate change and individual councils’ commitments over the coming years. This accords with and complements SDC’s own commitment to address the Climate and Ecological Emergency by being carbon neutral by 2030.\nSDC welcomes the commitment to prioritising sustainable transport and active travel but would like to emphasise the importance of support existing sustainable transport links and improving access to services between Stroud district’s communities and Gloucester / Cheltenham.",null,null,null,null,null,"SDC’s Strategic Lead for Nature Recovery and Biodiversity would welcome the opportunity to work with the SLP authorities on nature recovery as the draft plan emerges, with particular reference to the development of the Gloucestershire Local Nature Recovery Strategy.  \n\nThe provision of significant good green space is imperative to maintaining health and wellbeing, but also to add to the nature recovery network and create effective habitat corridors.  \n\nSDC would also like to highlight the fact that the joint SLP, due to the size of the SLP area and its geographic location within the heart of our county, offers exciting potential to tackle multiple cross-cutting environment issues (several of which are succinctly articulated in this chapter of the consultation document). For example, the identification of land for something on the scale of a country park (perhaps in association with a development strategy similar to scenario 4 or 6) could introduce more accessible natural green space for the benefit of the whole county’s residents, whilst delivering BNG, floodwater storage, food production, enhanced greenbelt, leisure and recreation (including relieving recreational pressures within the Cotswolds National Landscape and on sensitive habitats such as the Cotswold beechwoods, Stroud District’s commons and the Severn estuary), and efficient, joined-up walking and cycling routes on relatively flat ground, for both leisure and active travel / commuting. ",null,"Yes","SDC supports the SLP authorities’ preparation of a Renewable Energy Study and investigation of locations that offer potential for different forms of renewable energy generation or storage, including wind and solar. To ensure strategic, cross-boundary compatibility, SDC would draw attention to our own 2019 Stroud District Renewable Energy Resources Assessment (Local Plan examination library ref. EB56) and the maps contained at Appendix B of the examination Local Plan 2021, which identified areas suitable in principle for ground-mounted solar development and wind energy development as part of the Stroud District Local Plan Review. ",null,null,null,"The consultation document acknowledges (at para 5.19) that the housing requirement will need to be determined based on an understanding of individual site constraints and opportunities. \nSDC recognises that preferred development sites have not yet been identified (para 2.9) and agrees that this is entirely valid at Regulation 18 stage. However, if there is any question about the capacity of the SLP area to meet Gloucester City’s longer term housing needs in full, then SDC considers this should be clearly flagged up as a potential constraint, as early as possible in the plan-making process. Future consultation documents should be explicit about whether delivery in full might require the use of land outside the SLP area. \nSDC remains committed to working with our neighbouring authorities to identify potential sustainable locations to meet longer term housing needs, and the jointly-produced 2019 ‘Assessment of Strategic Development Opportunities in Parts of Gloucestershire’ formed a key piece of evidence for our own Local Plan review. However, Stroud District’s examination Local Plan 2021 identifies the potential shortfall in available land to meet Gloucester City’s future housing needs as a key challenge to our district’s own development strategy (eSDLP 2021, para. 2.3.26 – 2.3.28). \nAs you will be aware, the 2019 Assessment identified land within Stroud District as offering potential to meet Gloucester’s future housing needs. In response, the eSDLP 2021 proposes to “safeguard” the site known as ‘G2 Land at Whaddon’, with a view to confirming it as an allocation, subject to: \ni)\tThe site being required in order to meet Gloucester city’s needs\nii)\tThe site being favourably considered against reasonable alternatives\niii)\tThe site being consistent with the eventual SLP spatial development strategy.  \nAt the point of submission to the Inspectorate (winter 2021), SDC anticipated that by the time the eSDLP 2021 had been examined and adopted, the City Council would be able to clearly articulate the nature of unmet needs and the preferred direction of growth, so that the G2 allocation could be confirmed (or not, if not required).  This is explained in the supporting text for the draft site allocation (eSDLP 2021, para 3.4.23). \nThe site G2 is not envisaged as contributing to Stroud District’s own housing requirement. The location on Gloucester’s rural fringe (unconnected to any Tier 1 -3 settlement) is otherwise not in conformity with the overall spatial development strategy set out in the eSDLP 2021, which is based primarily upon the principle of concentrated growth at a selection of urban extensions, new settlements and commercial market areas, but with some dispersal to ensure local needs can be met and our settlements can respond to wider economic and demographic challenges.  \nSDC would welcome clarity on this matter, as the consultation document does not explicitly mention the use of land within Stroud District - although it appears to be alluded to through the placement of symbols on the maps for Development Scenarios 2, 3 and 6. ",null,null,null,"This could be explored through direct engagement with representatives of those varied communities to help identify specific site needs and locations. The Council look forward to continued close working and co-operation in the County on gipsy and traveller matters which can address the wider needs identified in the Gypsy and Traveller Accommodation Assessment and the subsequent locational and policy criteria work undertaken by Dr Simon Ruston. Working with one public estate and other landowner organisations should provide opportunities going forward. Dr Simon Ruston evidence on potential site incomes should assist those conversations.","The Council recommend using existing evidence. ORS provided mapping on key movement corridors and existing locations of those communities. Dr Simon Ruston has provided up to date policy criteria for assessing locations. This needs to be backed up with discussions with those communities and potential landowners exploring future development options. Clearly locations for the boat dweller/bargee community are more limited linked with need to use navigable waterways, with access to adequate services and meeting Canals & Rivers Trust / Port Authority licensing and safety requirements. ","SDC would like to see the SLP highlight its role as an employment provider for the wider catchment area of Gloucestershire and the region. \nSDC supports a strategy that accords with and helps to deliver the long-term vision of the emerging county-wide Gloucestershire Economic Strategy, referenced at para 5.34.\nSDC recognises the significant demand on the M5 junctions and welcomes the SLP acknowledging the existing and future pressures. Junction 12 is located within Stroud district and SDC would like to highlight ongoing work as part of our joint action plan with National Highways and Gloucestershire Highways to address and resolve capacity issues at J12; however, we also welcome the consideration of future development options within the SLP which would enable a shift in demand away from the M5 in general, towards rail. ",null,null,"Given the functional relationship between Stroud, Gloucester and Cheltenham in terms of the location of some of Stroud District’s communities to the SLP boundary and the sustainable travel routes linking the areas, SDC would like consideration to be given to the role and function that city and town centres, as well as smaller village, farm and neighbourhood shops within the SLP, perform for communities in the wider area. ",null,"The consultation document focuses primarily on infrastructure in the context of supporting new sites; but impact of development and growth may be felt further afield, beyond SLP area – for example impacts on the SRN (e.g. J12 within Stroud District).\nSDC would like to see consideration and reference given to any impacts on the SRN and LRN in Stroud and other districts. Early engagement with SDC and National Highways will be imperative. ","SDC would like early consideration given to strategic and local infrastructure that may impact services and facilities in the Stroud District. A lot of infrastructure demands and pressures don’t stop at district boundaries and strategic scale new settlements won’t necessarily be self-contained in terms of infrastructure usage. A detailed Infrastructure Delivery Plan will need to be produced to support new developments and consider cross boundary impacts.","SDC would like early consideration given to strategic and local infrastructure that may impact services and facilities in the Stroud District. A lot of infrastructure demands and pressures don’t stop at district boundaries and strategic scale new settlements won’t necessarily be self-contained in terms of infrastructure usage. A detailed Infrastructure Delivery Plan will need to be produced to support new developments and consider cross boundary impacts.","Yes",null,null,null,"We welcome that there is a clear narrative set out in Chapter 6, explaining how all options are being considered, moving towards an eventual preferred strategy. In general, the pros and cons are set out clearly and seem to be a fair assessment. \nWhilst the focus of the SLP is naturally to generate a strategy that will most sustainably and effectively deliver growth to meet the needs of the three local authority areas, SDC would like to make some comments about potential implications for our own district and communities. Cross-boundary implications (both pros and cons) vary from scenario to scenario. Some of the scenarios require delivery of sites outside the SLP area, including potentially within Stroud district, and there are various implications for the transport network, including additional pressures on M5 J12 within our area. \nSDC will of course be interested in potential cumulative and cross border impacts, and will maintain a constructive and open dialogue around these and the potential need for mitigation.\n\nScenario 1 – urban concentration\nAs hubs for employment, retail, services and leisure, Cheltenham and Gloucester act as significant focal points for Stroud District and for communities within a catchment that is much wider than the SLP area. An increased population and densification of resources within these urban areas may ease sustainable transport and active travel within these quite confined zones, but consideration should also be given to how this strategy might improve or inhibit access to strategic services from elsewhere in the county. \nThe quality of the built environment in Cheltenham and Gloucester (including their respective heritage assets) is also an asset to the wider Gloucestershire economy, helping to attract tourism and high quality knowledge-based and creative industries. Stroud district benefits directly and indirectly from access to our neighbouring urban hubs, and SDC would caution against a strategy that poses “likely harm to the setting and significance of important heritage assets and character of the urban area”. \nWe also note that amongst the ‘cons’ associated with this scenario, the consultation document mentions possible “increased journey lengths as housing and economic growth [may be] diverted to alternative locations outside of the SLP area”. Obviously SDC would welcome clarity about how that might impact Stroud district. \n\nScenario 2 – urban extensions \nConcentrated growth points, which take advantage of proximity to existing infrastructure and/or the ability to deliver new infrastructure on an efficient strategic scale, tend to perform well in sustainability terms. Whilst some loss of green belt land would be inevitable, this scenario offers an opportunity to introduce efficient, joined-up walking and cycling routes on relatively flat ground, for both leisure and active travel / commuting. \nAgain, we would like to emphasise the importance of supporting existing sustainable transport links and improving access to services between Stroud district’s communities and Gloucester / Cheltenham in particular. We would support a strategy that would enable connectivity from our district to future Mass Rapid Transport infrastructure.\nWe appreciate that the consultation document (para 6.9) states that the scenario maps are illustrative and diagrammatic, and that the placement of symbols does not mean that the land is suitable for development. However, whilst the consultation document does not explicitly mention the use of land within Stroud District, it appears to be alluded to through the placement of symbols on the maps for Development Scenarios 2, 3 and 6. As set out in response to Q13, the (in)ability of the SLP area to meet housing needs in full should be clearly identified as a key issue and SDC would welcome clarity on this matter. \n\nScenario 3 – urban extensions excluding green belt\nWe appreciate that the consultation document (para 6.9) states that the scenario maps are illustrative and diagrammatic, and that the placement of symbols does not mean that the land is suitable for development. Whilst the ‘cons’ identify that capacity to deliver sufficient jobs and homes is an issue, and that “alternative locations outside the SLP area” would be required, the use of land within Stroud District is not explicitly mentioned. However, this appears to be alluded to through the placement of symbols on the maps for Development Scenarios 2, 3 and 6. As set out in response to Q13, the (in)ability of the SLP area to meet housing needs in full should be clearly identified as a key issue (and potentially a ‘con’) and SDC would welcome clarity on this matter. \nConcentrated growth points, including urban extensions that take advantage of proximity to existing infrastructure and/or the ability to deliver new infrastructure on an efficient strategic scale, tend to perform well in sustainability terms. A strategy that excludes any of the green belt land between Cheltenham and Gloucester misses some opportunities to capitalise on connectivity between the two, as well as strategic links to the M5 / rail transport corridor. \n\nScenario 4 – new strategic settlements\nThe three potential locations identified are relatively remote from Stroud District and potential impacts are less immediately evident, compared to other scenarios. The consultation document identifies possible enhanced bus / rail services as a potential pro, subject to development location. \nWe welcome the consideration of future development options within the SLP which would enable a shift in demand away from the M5 in general, towards rail and active travel. \nPlanned new settlements offer the ability to deliver new infrastructure on an efficient strategic scale, which means they may perform well in sustainability terms. Should there be a need to investigate any additional locations, a new settlement sited somewhere within the greenbelt land between Cheltenham and Gloucester might offer even greater opportunities to capitalise on connectivity between the two existing urban hubs, as well as strategic links to the M5 / rail transport corridor. This location could benefit from several of the ‘pros’ identified for Scenario 6. \nWhilst the role of the green belt in avoiding coalescence is important, this scenario could also incorporate really significant strategic green infrastructure (something like a country park, as referenced in response to your Q.9), introducing more accessible natural green space for the benefit of wider Gloucestershire, as well as providing a high quality environment for those living and working within the new settlement. A new settlement between Gloucester and Cheltenham could help to support the vitality and viability of these two existing city/town centres and employment hubs by introducing efficient, joined-up walking and cycling routes on relatively flat ground, for both leisure and active travel / commuting – particularly if combined with complementary employment growth within the settlement itself.\n\nScenario 5 – rural dispersal\nStroud’s own spatial development strategy (as set out in the eSDLP 2021) is based primarily upon the principle of concentrated growth at a selection of urban extensions, new settlements and commercial market areas, but with some dispersal to ensure local needs can be met and our settlements can respond to wider economic and demographic challenges. The SLP area (particularly parts of Tewkesbury Borough) shares some similarities with Stroud District. Some aspect of dispersal may be an appropriate component within a ‘hybrid’ spatial development strategy, in order to provide the flexibility to meet the specific needs of smaller rural communities. \n\nScenario 6 – Sustainable transport scenario\nWe welcome the consideration of future development options within the SLP which would enable a shift in demand away from the M5 and car travel in general, relieving pressured infrastructure (referred to in response to Q.18 and Q.23) by moving towards rail, bus, active travel and potential integration with the Gloucestershire Mass Rapid Transport system in the future. We strongly support the intent behind this strategy scenario, to focus on reducing carbon emissions from transport, as per the Gloucestershire authorities’ Statement of Shared Intent. \nWhilst the role of the green belt in avoiding coalescence is important, this scenario could also incorporate really significant strategic green infrastructure (something like a country park, as referenced in response to your Q.9), introducing more accessible natural green space for the benefit of wider Gloucestershire, as well as providing a high quality environment for those living and working within the areas of new development.\nStroud district sees considerable out-commuting to the SLP area for employment. Again, we would like to emphasise the importance of supporting existing sustainable transport links and improving access to services between Stroud district’s communities and Gloucester / Cheltenham in particular. SDC would support a strategy that would enable connectivity from our district to future Mass Rapid Transport infrastructure. We would support the delivery of high quality employment development in accessible locations, and a strategy that accords with and helps to deliver the long-term vision of the emerging county-wide Gloucestershire Economic Strategy. \nSDC would like early consideration given to strategic and local infrastructure that may impact services and facilities in the Stroud District. A lot of infrastructure demands and pressures don’t stop at district boundaries and strategic scale development (including, potentially, at Whaddon) won’t necessarily be self-contained in terms of infrastructure usage. A detailed Infrastructure Delivery Plan will need to be produced to support new developments and consider cross boundary impacts.\nWe appreciate that the consultation document (para 6.9) states that the scenario maps are illustrative and diagrammatic, and that the placement of symbols does not mean that the land is suitable for development. The use of land within Stroud District is not explicitly mentioned in relation to Scenario 6, but land at Whaddon does appears to be alluded to through the placement of symbols on the map. As set out in response to Q13, the (in)ability of the SLP area to meet housing needs in full should be clearly identified as a key issue (and potentially a ‘con’) and SDC would welcome clarity on this matter. ",null,null,null,"[Q15.] The Council considers that it should on strategic sites in appropriate locations. It is reasonable to expect that accommodation should include meeting the specific needs of travellers, including local gypsies and travelling showpeople in the locality. New housing should be well designed to address a range of local housing needs, incorporating a range of different types, tenures and sizes of housing to create mixed inclusive and sustainable communities. Development proposals should contribute towards meeting the needs of all sections if the community and help to encourage social cohesion across social and ethnic groups. It is important to note here the scale of any provision. Dr Simon Ruston’s work indicates traveller sites with 5-10 plots or yards are easier to manage and do not often give rise to potential social tensions between the settled and traveller groups.\n\n[Q26.] SDC believes this is a sensible approach if longer term infrastructure is identified and also to future proof future development.\n\n[Q29.] At this stage, SDC does not wish to give a view on a specific preferred development scenario or combination. However, we agree that it likely the eventual strategy will encompass aspects of more than one of the scenarios presented in this consultation document – and we would consider that to be appropriate. A hybrid strategy is likely to offer the best scope to deliver both targeted and dispersed benefits to the SLP area. \nAs summarised above, our own experience (evidenced through sustainability appraisal and the testing of various sites and options) indicates that concentrated growth points, which take advantage of proximity to existing infrastructure and/or the ability to deliver new infrastructure on an efficient strategic scale, tend to perform best in sustainability terms. However, an element of dispersal may be required in order to meet specific needs of individual communities – particularly in the rural areas of Tewkesbury Borough. \nStroud’s own spatial development strategy (as set out in the eSDLP 2021) is based primarily upon the principle of concentrated growth at a selection of urban extensions, new settlements and commercial market areas, but with some dispersal to ensure local needs can be met and our settlements can respond to wider economic and demographic challenges.\n\n[Q31.] SDC recognises the hard work that has gone into producing the plan and the quality of the work, we wish to be kept up to date as it progresses and welcome any future discussions. "]
["","Friends of the Earth",25,"There is no explicit mention in 2.4 of energy usage in a net zero scenario, ie a design limit on energy usage and demand management of all resources. Unlimited demand is unsustainable. \n\nAlso to be considered is food security and farming. Whilst these are outside the scope of the NPPF a holistic approach should be taken for our area ensuring that we protect good agricultural land and limit building on green field sites. We should be planning towards reducing food imports especially of fruit and vegetables.","There will be policies relevant to Tewkesbury due to its mainly rural make-up. Currently the 5 year housing land supply is allocated by borough/district boundaries and whilst that is government policy the housing policies should be within those boundaries.","","At the vision level this is fine, however the amount of growth is crucial. Modelling for different\namounts of population growth should be done. The necessity for movement of people within the\narea if flooding becomes so severe that it isn’t affordable to protect houses that are flooded\nregularly.","","See above [Q4] re growth. \n\nThe strategic objectives should line up more closely with the Garden communities principles which are far stronger in aspiration for the highest quality in all developments","Set a net zero target date with accompanying annual carbon budgets.\n\nSet modal transport targets with clear and transparent assumptions about future transport\nchoices.\n\nSet the highest possible building standards to lower the amount of energy and water usage.","Zero carbon construction and operation","Retrofit for energy and water efficiency where that would be the lowest climate cost, whilst allowing some leeway for historic and socially important buildings.","","","All land could probably capture more carbon if it is kept green for as long as possible and the soil\nmicrobiome is allowed to flourish. Website: http://www.amazingcarbon.com/\n\nAll open air and the top floor of multi storey car parks , plus all suitable roofs should have solarcanopies, Roofs not suitable for panels should be of a light reflective colour.\n\nUrban centres should have trees to provide shading in the majority of streets.","Schools, food shops, health facility, community halls, playgrounds and other recreational\nfacilities. Public transport and cycle/walking routes to the adjacent neighbourhoods.","Yes","Yes for roofs, yes to solar farms on low quality agricultural land, also wind turbines, and agricultural and human waste bio gas generation and the households closest to such facilities gain some economic or other benefits","","There needs to be a national conversation about growth and development over the whole of the UK and each authority should have input into their own sustainable growth targets. Government resources should be allocated to encourage growth in areas with lower economic prospects. Levelling up should mean what it says on the tin.",""," See answer to 12","","Better provision for social rented accommodation. Housing for older people to downsize into where there is neighbourly supportand some shared facilities eg swimming pool and good storage areas.\n\nHigh quality high density housing for single people with excellent design meaning for light and storage meaning sizes can be reduced without and detriment to residents of such.\n\nCommunity land trust opportunities especially for young adults because “They ensure that their\nhomes are permanently and genuinely affordable. CLTs act as long-term stewards of land and the assets on it. They ensure that it is put to the benefit of the local community, not just for now but for every future occupier.”\n\nIndividual sites within the gardens of rural properties for small houses for single people to allow for extended families to live together but in independent dwellings.",""," See above [Q15] Better provision for social rented accommodation. Housing for older people to downsize into where there is neighbourly supportand some shared facilities eg swimming pool and good storage areas.\n\nHigh quality high density housing for single people with excellent design meaning for light and storage meaning sizes can be reduced without and detriment to residents of such.\n\nCommunity land trust opportunities especially for young adults because “They ensure that their\nhomes are permanently and genuinely affordable. CLTs act as long-term stewards of land and the assets on it. They ensure that it is put to the benefit of the local community, not just for now but for every future occupier.”\n\nIndividual sites within the gardens of rural properties for small houses for single people to allow for extended families to live together but in independent dwellings.","See above [Q15] Better provision for social rented accommodation. Housing for older people to downsize into where there is neighbourly supportand some shared facilities eg swimming pool and good storage areas.\n\nHigh quality high density housing for single people with excellent design meaning for light and storage meaning sizes can be reduced without and detriment to residents of such.\n\nCommunity land trust opportunities especially for young adults because “They ensure that their\nhomes are permanently and genuinely affordable. CLTs act as long-term stewards of land and the assets on it. They ensure that it is put to the benefit of the local community, not just for now but for every future occupier.”\n\nIndividual sites within the gardens of rural properties for small houses for single people to allow for extended families to live together but in independent dwellings.","The plan needs to positively encourage green businesses to service the zero carbon buildings and other developments. Optimise the digital economy (ultra fast broad band as standard) With low energy industries and using waste heat for useful purposes.","There could be more small workshop areas to attract artisans and build in planning permission for garden rooms and studios.","Make sure there is sufficient agricultural land with opportunities for diversification. Universal access to ultra fast broad band. Allow some individual self builds within grounds of existing dwellings but such developments would need to contribute their fair share to community infrastructure costs as larger developments do via S106 and CIL","Developing brown field sites in city and town centres to be mixed developments with spaces for small businesses and leisure activities and small scale learning centres eg apprenticeship training\ncentres. The facilities already in the centres may need some protection from competition from newer facilities. Tewkesbury High street and Barton St up to nelson Street to have wider pavements – one\nway system to allow this. ","Checking that S106 and CIL money from developments is used primarily to benefit the villages concerned eg library money supporting a mobile library service. ","Cycle routes linking to neighbouring areas and the local schools . Road capacity must be looked at in light of potentially more cars but equally looking at modal shifts. Some nudges to discourage car usage.\n\nLow maintenance and high Bio diversity green spaces producing shade and good drainage as adaptive measures. Social meeting facilities , community hall or café.\n\nAll energy infrastructure is sufficient for the demands of the development and digital access for all.\n\nMedical care could be accessed via the internet in many instances. ","Secondary school, medical centre, civic space, sports facilities, supermarket","Public transport giving good choices to lessen car journeys, a primary school with admissions policy taking into account distance needing to be travelled to the school. A cycleway linking to the wider\nnetwork. Making sure the settlement has sufficient energy infrastructure for an all-electric future.","Yes","","(b) A scenario with major, repetitive flooding meaning many people need to live elsewhere, probable development on hilly areas say in AONB areas.\n\n(c) A lowest carbon budget scenario. So, estimate the carbon budgets of the 6 given scenarios and look for alternatives that have a lower budget than any of the 6. Taking into account that\nonce the energy system is mainly renewable and electric food production and agriculture and other land use may become the area with the highest greenhouse gas emissions. ","Yes","Yes, they seem reasonable, although it is not clear whether the Garden communities area around Ashchurch is counted in just scenarios 2 and 3, whereas it is already really a new strategic settlement as in scenario 4.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","","Individual or small clusters of house plots, including “tiny homes” for people wishing to live in a sustainable way in the countryside and work on the land producing small market garden-types crops and other small rural enterprises.","[Q1 - 25 years to ensure that we think far enough in the future and also holistically especially re infrastructure. And the plan would need to be reviewed regularly, say every 5 years, to take into account the effects of climate change and associated migration and national and international policies.]\n\n[Q8 - It should state 20% net gain to allow for inevitable slippage and soil carbon capture should be factored in as well.]\n\n[Q15 - Without knowing the requirements and aspirations of traveller communities this is hard to answer.]\n\n[Q26 - Yes, particularly for local renewable energy production. Infrastructure for flood protection using modelling that looks at scenarios where there is an average temperature rise of > 2 degrees C]\n[Q.29] A mixture of 1, 2 and 6\n\nThe plan needs to allow for enough housing to fulfil the government’s plan for the number of houses required in this area so that we no longer have a shortfall in housing land supply and are\nnot able to insist on development within the planned area and to the net zero standards that are now a necessity to meet accelerated decarbonisation.\n\n[Q.31] It is very important to look at the whole plan with an eye to accelerated decarbonisation and to quantify the different scenarios with this in mind and to generate a narrative of what people’s lives would look like in a net zero Gloucestershire. There could be a picture of all the future jobs involved in , say, retrofitting houses, with happy residents enjoying low bills, people able to work from home 2 or 3 days a week, cycle routes to the local shops with space for cargo bikes, schools used in the evenings by the community, holiday pods on rewilded farms and many other images that are dreamt up by local people to show their ideal lives\n\n"]
["Planning agent or developer","Zesta Planning ","","","","","A key focus of the draft vision is on ‘green growth’ which achieves carbon reductions and addresses the causes and effects of climate change. The draft vision also envisages investment in training, skills and development, the attraction and retention of a younger workforce and provided new premises and flexible workspaces to support a flourishing circular economy in both urban and rural areas. It also envisages that inward investment, innovation and growth in key sectors including, amongst others, cyber and digital-tech, food/agri-tech, advanced engineering and tourism will have been fostered. It envisages that growth in sustainable locations will have enabled the provision of healthy, accessible and walkable neighbourhoods, the promotion of active travel and sustainable travel, and provision of new transport systems that work for local people. GAL support these facets of the draft vision and indeed consider that employment growth at the airport would make an important contribution towards realising this vision.","","Similarly, GAL give particular support to the following Draft Strategic Objectives: • Meeting the challenges of climate change by (inter alia) ensuring growth takes place in sustainable locations that minimise the need to travel and provide genuine sustainable transport and active travel options. • Building strong, competitive and sustainable urban and rural economies by (inter alia) providing the right conditions and sufficient land in the right locations to support existing and new businesses and deliver the ‘green growth’; improving the area’s economic resilience, supporting a highly skilled workforce, skills and educational development attainment. Providing the right environment for business start-ups, entrepreneurship, and the improvement and expansion of education and training facilities to develop the skills employers need. • Prioritising sustainable transport and active travel by (inter alia) promoting the use of sustainable travel modes by improving existing and providing new frequent public transport links and safe walking and cycling routes in all new developments; creating a genuine choice between different modes of transport by integrating new development with existing networks and enhancing these wherever possible.","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","","Scenario 6: Sustainable transport scenario","","","Zesta Planning has been instructed by Gloucestershire Airport Ltd (GAL) to make a formal representation to the Strategic & Local Plan Issues and Options Consultation: Spatial Options and Key Policy Areas. A brief representation is also made to the consultation on the draft site assessment methodology for the Housing and Economic Land Assessment (HELAA). \n2. Gloucestershire Airport and its surrounding business parks represent an important economic asset to the SLP area. The Airport currently handles approximately 70,000 flights per year, making it one of the UK’s busiest general aviation Airport. Indeed, the adopted JCS recognises the Airport as strategically and regionally important, serving a sub-regional catchment of 1.9 million people and 84,000 businesses. The Airport is also recognised in the Local Enterprise Partnership’s Strategic Economic Plan (SEP) for Gloucestershire as an important economic asset for Gloucestershire and having significant growth potential. Furthermore, one of the strategic priorities of Tewkesbury Borough Council’s latest Economic Development and Tourism Strategy is to support Gloucestershire Airport business expansion. \n3. There are currently over 50 businesses located at the Airport, many of which anticipate future expansion and job growth. The Airport is also experiencing demand from a range of aviation companies that wish to locate there.\n4. It is considered essential therefore that the growth aspirations of the airport are realised through the SLP in order to maintain and further promote its important role in the economic prosperity of the area. \n5. In this representation we offer comments on the following main themes: • The overall vision for the plan and its draft strategic objectives • The questions around jobs and the economy • The growth options/development scenarios for the plan • Other (non-specified) matters \n6. We would also like to take this opportunity to make the SLP authorities aware of the growth aspirations of the airport, and in this regard, we can confirm that land at the airport has been submitted to the Housing and Economic Needs Assessment (HELAA) call for sites under a separate cover, a copy of which is appended to this representation. Background \n7. Land within and around the airport has previously been subject to consideration as part of both the adopted JCS and the Tewkesbury Borough Plan (TBP). \n8. The employment land potential of the airport was considered as part of the JCS but ultimately the Councils decided to go with a more restrictive approach of expanding the extents of the ‘Non-Essential Operation Area’ rather than making new employment land allocations. Allocating employment land at the airport was instead deferred for consideration as part of the TBP. \n9. In the interim period, Tewkesbury Borough Council’s Economic Development and Tourism Strategy 2017-2021 was published. One of its strategic objectives is to support the Airport’s business expansion by identifying growth opportunities through the TBP. \n10. Accordingly, as part of the TBP the Council proposed to further expand the ‘Non-Essential Operation Area’ and make new employment land allocations involving the expansion of the Major Employment Site designations at Meteor Business Park, Bamfurlong Industrial Park and Ashville Business Park respectively. These allocations all involved the removal of land from the Green Belt. A policies map extract from the Pre-submission TBP showing the proposed employment land allocations at the airport (red outline/red hatched infill) is provided at Figure 1 below.\n11. Whilst the Council were clearly supportive of these removals/allocations, the examining Inspector ultimately concluded that exceptional circumstances had not been demonstrated to justify alterations to the Green Belt in this area. This was due to fact that the JCS provided no strategic direction for the TBP to remove land from the Green Belt, and providing employment land at the airport was not critical for meeting the JCS requirement for 192 ha of B-class employment land across the plan period. Moreover, the TBP Inspector considered Green Belt releases at the airport to be a strategic matter that was beyond the remit of the TBP, stating at paragraph 75 of his final report that: “With general agreement as to the importance of the airport to the local economy, its future is a strategic matter that should be considered through the JCS review and not prejudged by incremental decisions in the TBP.” \n12. This situation has clearly moved on and the Councils will now be required to identify land to meet employment land requirements across the new plan period of the SLP, which is expected to last up until 2041. Furthermore, it is clear from the TBP Inspector’s findings that the future of the airport is an important strategic matter that is best considered through the review of the JCS (which is now being progressed in the form of the SLP).  \n13. Tewkesbury Borough Council’s Employment Land and Economic Development Strategy Review 2016 (ELEDSR), which forms part of the evidence base for the TBP, identifies that some of the most important and deliverable employment sites in the Borough are adjacent to Gloucestershire Airport. This potential has been realised to some degree over recent years with planning permission being granted by the Council in 2021 for 5.9ha of B1, B2 and B8 development on land within the airport between Meteor and Anson Business Parks (20/00758/FUL) as shown by the plan at Figure 2 below. This does however represent just a proportion of the available and deliverable employment land at the airport and the remains to be untapped potential. Figure 2 – Recently permitted employment development at the airport \n14. Given the strategic location of the airport and its importance to the area’s economy it is considered to represent an ideal opportunity for meeting the employment land needs of the area. We make more detailed comments on the suitability of the airport later in this representation. \n\n[Q4&5.] 20. In these regards, we would emphasise the sustainable location of the airport on an existing high frequency bus route between Cheltenham and Gloucester, in addition to being located along the ‘Gloucestershire cycle spine’ (connecting Gloucester/Cheltenham/Bishops Cleeve) and on the potential route of the proposed Gloucestershire Mass Rapid Transport system. Furthermore, the airport is ideally located midway between Cheltenham and Gloucester and is sandwiched between the A40 and B4063 Gloucester Road which provide the road links between the two urban areas. \n21. Employment growth at the airport would therefore be in a highly accessible location that can capitalise on existing and proposed public transport and active travel infrastructure and would minimise the need to travel owing to its proximity to both Cheltenham and Gloucester. \n22. We make more detailed comments on the ‘economy’ aspects of the draft vision and strategic objectives in our responses to the questions around jobs and the economy, but consider that employment growth at the airport would help to achieve inward investment, innovation and growth in key sectors, and would also function as part of a wider innovation hub together with the nearby Golden Valley/Cyber Central development. \n23. We consider therefore that employment growth at the airport would be consistent with the vision and draft objectives for the SLP. \n\nJobs and the economy \n24. The SLP envisages growth in key sectors including, amongst others, cyber and digital tech, food/agri-tech, advanced engineering. It also recognises and promotes Cheltenham as an innovation hotspot and refers to the clustering together of firms in terms of sharing infrastructure and access to workers. \n25. A key proposition of the emerging SLP strategy is to secure inward Investment which builds on supporting Gloucestershire’s reputation as a welcoming and supportive environment for businesses from the UK and abroad to invest, fostering innovation, creating jobs, and promoting prosperity across the county. \n26. In this regard, we would comment that the airport already accommodates businesses in key growth sectors and is ideally located to take advantage of its proximity to the Golden Valley/Cyber Central development and could function as part of a wider innovation hub.\n27. Indeed, GFirst LEP’s Strategic Economic Plan for Gloucestershire 2.0 cites the rapid development of general aviation, drone, and autonomous air vehicle technology together with the ‘Grand challenge’ set by the Government in the 2017 Industrial Strategy “the UK becoming a world leader in shaping the future of mobility” means that in future years the close proximity of the airport to Gloucester and Cheltenham and the planned UK Cyber Business Park in Cheltenham ensure that it will be a strategically important asset for the county over the long term. \n28. The Airport aims to continue its relationship with the local authorities and the LEP in order to promote Gloucestershire as a destination for business and leisure. Growing the airport business is dependent upon having the appropriate on-site property development. Currently there are over 50 business at the Airport, many of which anticipate future expansion and job growth. The Airport is also experiencing demand from a range of aviation companies that wish to locate there. \n29. The Staverton Business Parks and the Airport have been established through the SEP and the ELEDSR as being some of the most prime employment land in the Borough. This is also because many businesses require an airport location to function. \n30. On the above basis, it is considered that enabling employment land growth at the airport would help to achieve the aspirations of the SLP relating to jobs and the economy. It is considered to be essential for the SLP to facilitate the growth aspirations of the airport in order to enable the expansion of the existing businesses located there, thus securing their retention, and attract inward investment from new businesses wishing to base themselves at the airport. \n\nDevelopment Scenarios \n31. The SLP sets out a number of development scenarios for consideration, one of which is a ‘Sustainable Transport Scenario’ which would mean delivering development in locations along existing and potential high frequency public transport, walking and cycling routes. \n32. GAL support this development scenario and emphasise the Airport’s advantageous location in this regard. \n33. As previously noted, we would emphasise the sustainable location of the airport on an existing high frequency bus route between Cheltenham and Gloucester, in addition to being located along the ‘Gloucestershire cycle spine’ (connecting Gloucester, Cheltenham and Bishops Cleeve and on the potential route of the proposed Gloucestershire Mass Rapid Transport system. Furthermore, the airport is ideally located midway between Cheltenham and Gloucester and is sandwiched between the A40 and B4063 Gloucester Road which provide the road links between the two urban areas. \n34. Employment growth at the airport would therefore be in a highly accessible location that can capitalise on existing and proposed public transport and active travel infrastructure and would minimise the need to travel owing to its proximity to both Cheltenham and Gloucester. \n\nOther matters \n35. GAL note and welcome the comment at paragraph 1.6 of the consultation document that evidence gathering is underway including a review of the Green Belt. GAL consider a Green Belt review to be an essential part of the evidence base for the SLP in the interests of achieving sustainable patterns of development and realising the employment growth potential of the airport and the benefits that it would deliver to the economy of the SLP area. \n36. The NPPF enables Councils to review and alter Green Belt boundaries through the plan making process where exceptional circumstances are fully evidenced and justified. \n37. A key consideration in this regard is the need to promote sustainable patterns of development, and where it is necessary to release Green Belt land for development, the NPPF advises that plans should give first consideration to land which has been previously developed and/or is well-served by public transport. It also advises that Councils should set out ways in which the impact of removing land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land. \n38. GAL consider that the careful removal of land at the airport from the Green Belt would help to achieve sustainable patterns of development owing to its location on key public transport/active travel routes (existing and proposed) and its proximity to both Cheltenham and Gloucester. Moreover, realising the employment growth potential of the airport and the significant benefits that it would deliver to the economy of the SLP area can only be achieved if suitable land is removed from the Green Belt. The airport has a strategically advantageous location over other parts of the SLP area. Furthermore, some of the most important and deliverable employment sites in the SLP area are within the immediate vicinity of the airport. The benefits of delivering further employment land growth in this location cannot therefore be achieved elsewhere on land outside of the Green Belt. \n39. GAL consider there to be exceptional circumstances for removing land at the airport from the Green Belt to enable its allocation for employment land purposes. GAL are committed to working with the SLP authorities as the plan progresses to assist with providing the evidence and justification for a Green Belt release in this location. \n40. GAL are also committed to working with the SLP authorities to identify opportunities for how the proposed removal of land from the Green Belt can be offset through compensatory improvements to the environmental quality and accessibility of remaining Green Belt land."]
[null,null,"","Can’t find 2.4!","Infrastructure, whether roads, drs and schools can cope with any extra demand, already stretched due to already built new houses in the villages. Sewage systems also can not cope","","Some of it but not all. Planning maps, although just guidelines at this stage have upset a good many of the local people. They are not accurate and should not have been published without consulting local parish councils, borough councillors and county councillors, who are elected for this very reason","","Some but not all","Solar panels on planning applications and other green energy that can be put in within the planning/building stage, without too much extra cost.\nGreat swaths of concrete causes more flooding, better mapping and concern for areas that flood should be considered as this will only get worse over the years. Writing this into the document will guide would be planners and developers.","More attention should be paid to infrastructure, although often not seen as planning reasons, this can affect the communities adversely. Ticking the box to acquire the planning numbers/ 5 year land supply, should not be done if detrimental to an area.","Planning should be easier and quicker to grant when converting existing building into accommodation.","Yes","","Don’t understand what is being asked here","Schools, so that children can walk to school, particularily primary age. This has been lost with too much development in our villages.","","Possibly yes","No","Planning of new houses should be needs based on the local areas. Some areas may need more social housing, some more starter homes and some more housing for elderly to downsize. A calculation produced in some office doesn’t reflect the needs of the community","Yes","As previous answer","Yes","More housing for elderly to down size, or be supported in, but stay within the community they have lived for most of their lives.\nAlso more starter homes for the younger generation to get onto the housing ladder","Yes","As above in the question. Make sights mandatory on new communities over a certain number. If accepted within the communities, there would not be such a divide in public opinion","You could ask them. They should have all the amenities, water on a water meter, sewage disposal, rubbish collections the same as everyone else, and be prepared to pay their council tax like everyone else. This would stop pop up sites without permission and hopefully keep them cleaner and tidier","?","Developments like the Golden valley cyber community to attract those with IT needs for employment","Stop building on all the green fields that are good quality arable land. Encourage planning for agricultural diversification","Providing housing and facilities within town centres will bring life back to these areas, encouraging high street shops to re open, pubs, restaurants etc. Out of town facilities requires people to get in their cars and drive! And takes the heart and money out of the town/city","A local shop/post office used to exist in most villages, but these closed in many areas, meaning people had to travel, usually by car as bus services are infrequent. Pubs have also gone in many villages. Whether buisness rates could be looked at in villages that still have these facilities, to try to help them remain viable? Village communities usually try to support local, but new estates added to villages tend to get in their cars to buy cheaper elsewhere.\nService villages, that were identified years ago need re looking at as there is no common features of these any more. Schools have closed, shops and pubs lost etc","Schools, adequate parking, mains sewage that is adequate, water supply that doesn’t affect existing residents, capacity at the Drs, road structure that can cope with the extra houses. Surveys done by developers are rarely accurate","If a garden community, all of the above should be in place before the houses are completed for habitation","Whether the land and surrounding areas flood? Accurate information, not lies some developer has paid some topographer to write.\nThe road infrastructure, accurately recorded before planning permission is granted, not a Quick Look at a Google map! By Highways.\nCapacity at the schools, Drs etc","No","Yes","Focusing development in area not at risk of flooding and along existing major road networks, with access to all the facilities required to live a good life, that doesn’t affect village communities. People choose to live in a village for a reason.","","Yes and no, a combination of the options should be considered.","Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","Yes","Land either side of the A40 between Gloucester and Cheltenham","I totally agree with the provision of social houses but the location needs considering. 40% of all new developments means placing people in the country often and they don’t want to be out on a limb. From lived experience I have had comment to say “the buses are not frequent enough if they need to get to the food bank in town”\n“The primary school places are not available to all in the village, as no capacity and we don’t have a car.”\n“There is nothing for the kids to do”\n“The school even said in passing they are not used to social workers at the school “ all these are very sad and make me think we shouldn’t put our own values on other people"]
["Other","Stagecoach West",21,"Stagecoach and Pulhams consider that the strategic policy topics set out are comprehensive and this is welcomed. ","Stagecoach and Pulhams consider that the strategic policy topics set out are applicable across the plan area.","No","Stagecoach and Pulhams consider that the draft Vision or the SLP is broadly comprehensive but fails to properly direct the plan strategy where the pressing need to secure a more sustainable balance of travel choices by sustainable modes is concerned, and public transport in particular.\n\nOn page 15,  g) fails to state clearly that high quality sustainable travel choices that are competitive with driving must consistently be delivered across the plan area to secure the Vision, and conformity with both the adopted GLTP4 and national transport policy, and planning policy expressed at paragraphs 108-110 of NPPF.\n\nPoint j) makes reference, as an example to “Mass Transit Corridors”. Notwithstanding the policies in GLTP4, these are yet to be defined. The plan must have a clear and unremitting focus on deliverable sustainable transport outcomes, without being spatially tied to a specific unfunded and undefined solution, which if it would to do so, would open the strategy up to material delivery risks, that could go to the heart of the soundness of the plan. The focus of the plan should accordingly be on “high quality public transport corridors”.\n\nTo address the above points, Stagecoach and Pulhams consider that the draft Vision or the SLP should be altered as follows:\n\nDraft Vision \nBy 2041, and beyond for larger scale developments, the Cheltenham, Gloucester and Tewkesbury area will have …\n\nInvestment in training, skills and development will have attracted and retained a younger workforce and provided new premises and flexible workspaces to support a flourishing circular economy in both urban and rural areas, and the delivery where necessary of facilities to support expanded public services. Inward investment, innovation and growth in key sectors including, amongst others, cyber and digital-tech, food/agri-tech, advanced engineering and tourism will have been fostered. \n\nPeople’s housing needs will have been met through the provision of sustainable, high-quality market, affordable and other specialist homes set in beautiful, safe places and conforming to sustainable standards of design and construction. The focus will have been on making best possible use of brownfield sites in built up areas and large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved. The vital role of the area’s city centre, town centres and high streets, as those places most accessible by sustainable modes will have been improved will increasingly be the focus of major trip generating land uses through careful management of development and land uses opportunities across the plan area. \n\nGrowth in sustainable locations will take advantage of and if necessary have enabled the provision of healthy, accessible and walkable neighbourhoods, the promotion of maximising the use of active travel and sustainable travel public transport, effectively rebalancing the and provision of new transport systems that work effectively to secure sustainable local mobility for local people existing and new neighbourhoods. \n\nGrowth will have been supported by the provision of a range of essential the digital, transport, community and other infrastructure necessary to secure the plan’s strategic objectives and in support of wider national policy. \nEqually, …”","No","Stagecoach and Pulhams consider that the draft Strategic Objectives of the SLP again, address the main areas identified in a broadly comprehensive way, but lack sufficient clarity of intent to properly direct the plan strategy and policy where the pressing need to secure a more sustainable balance of travel choices by sustainable modes is concerned, and public transport in particular.\n\nStagecoach and Pulhams consider that the draft Vision or the SLP should be altered as follows:\nDraft Strategic Objectives \nMeeting the challenges of climate change\n1. …\n2. Ensuring growth takes place in sustainable locations that minimise the need to travel and provide genuine sustainable transport and active travel options sufficient to be competitive with car use, and secure high levels of use. \n3. Making the most effective use of previously developed land, including higher density development both in city and town centres and other locations well served by public transport. \n4. Ensure development effectively provides excellent access to local services by active travel modes through integration  with existing adjoining development, and/or secures credibly high levels of self-containment at a suitably early stage.  is a self-contained development that provides shops, services, facilities through walking, cycling or public transport. Public transport should be the natural first choice for trips beyond the neighbourhood. \n\nPrioritising sustainable transport and active travel \n1.\tReducing the need to travel, and the need to travel long distances by motorised means, by pursuing a compact development strategy and compact forms of development creating real options that make active travel and public transport the natural first choice  for healthy, accessible and walkable neighbourhoods where to access key services are available without the need to use motorised transport; \n2.\tPromoting the use of sustainable travel modes by focusing development in locations that are sustainable by virtue of their active travel and public transport connectivity offer, taking necessary opportunities to further improveing existing safe walking and cycling routes and providing new frequent public transport links and in all new developments, where necessary securing new links to meet identified deficits; \n3.\tMaterially reducing reliance on the private vehicle by improving access to services in rural and urban areas through new development, improved integrated transport links and supporting local and community led transport initiatives in the Local Transport Plan;\n4.\tCreating a genuine choice between different modes of transport by integrating new development with existing networks and enhancing these wherever possible. ","If national legally binding targets for carbon mitigation are to be secured, then an unprecedented mode shift away from private car use is unavoidable in every scenario set out by Government. This is made very clear in the National Transport Decarbonisation Plan. \n\nThe role of development plans in facilitating this by aligning development strategies with the need to reduce the energy intensity and distance of travel should not be underestimated. This is made explicit in Section 5 of the NTDP. While this is still yet to be made explicit in NPPF, the direction of policy travel is very clear.\n\nThe language at 4.14 of the condoc fails to recognise this at all, which is disappointing. It focuses only on urban design and building specification, having no regard to the fact that extensive patterns of development that extend journey distances make car dependency inevitable. Active travel and public transport can never be competitive with the car in developments thus located. \nIn fact, active travel or public transport too often is not even a credible choice, much less the genuine choice that NPPF paragraph 108 expects plan strategies to facilitate.\n\nPublic transport is not even mentioned in the table at 4.15 under the “movement” theme, though it is in the supporting memorandum. The plan needs to have a clear and consistent vision, that is evidentially well-founded, for the role of public transport in securing sustainable mobility. For this to happen, this will require the plan evidence base to pay careful regard to those appropriate sites that can take advantage of existing of potential high quality public transport corridors, and the development strategy should be appropriately steered by this evidence. Furthermore, if the plan is to be soundly based, the deliverability and effectiveness of envisaged public transport interventions to support the plan ought to draw on operator experience, in this regard, especially where improved or new public transport links are necessary. \n\nThis new strategic plan needs therefore to pursue a spatial strategy that appropriately prioritises urban intensification, thereafter a relatively compact form of development building on existing neighbourhoods and existing high quality public transport corridors to the extent that this is possible and appropriate, before extending the search to new stand-alone neighbourhoods and settlements, which, again, should be located on demonstrably effective existing or potential high quality public transport corridors.  ","","","","","","Traffic counts expose the degree to which peak car-borne journeys reduce at school holiday periods. Thus, the provision of sustainable choices to reach primary and secondary education sites should be paramount. 1200-1400 dwellings are typically considered sufficient to support economic and effective 2-form entry primary school provision. \n\nThe ability to meet daily convenience shopping needs within a 5-minute each way walk (about 400-500m) ought to credibly be achievable even at net densities of 35 dwellings per hectare, given that this radius would put up to about 1700 dwellings within range. Factoring in of the land uses, a 1400-dwelling exclusive catchment is considered commercially capable of sustaining a sound convenience store offer. \n\nFor off-site trips, a bus service operating no less than every 20 minutes with a journey time to a major town of no more than 30 minutes, should be considered the minimum baseline offer to achieve even the current public transport mode share. A 15-minute frequency and 25 minute journey time is the minimum necessary to secure any prospect of higher bus mode shares than those typical in the urban areas within the plan. 30-minute frequency on evening and Sunday hours of operation is also necessary. Such services should typically be available within 500m of all dwellings on new developments, and ideally, closer.","","","No","The Standard Method is clearly stated in NPPF to be the “starting point” for calculating housing need, not the methodology in its entirety.\nThe Councils should seek to follow the guidance published by Government to establish how far other factors, including economic growth potential, affordability and the ability to deliver sufficient affordable housing tenures, should inform the potential to justify a higher requirement.\n\nThe failure of the JCS to fail to deliver against current housing needs is serious and compounds a situation that was already chronic especially in and around Cheltenham. This has directly impacted the ability of service providers including bus operators, to staff their operations. That this has disproportionately affected Cheltenham, of all the bus operating centres in Gloucestershire, manifestly reflects the particularly severe lack of housing availability at any price, much less so affordable costs.\n\nThere is an immediate need to bring housing land forward at policy compliant levels of affordable housing delivery. This justifies allocation of further land capable of early delivery in the plan period, immediately adjoining the existing main settlements and well placed with regard to local facilities, especially secondary school provision, and public transport corridors.  Given the extent of the statutory Gloucester and Cheltenham Green Belt, further limited tactical releases might be required. \n","No","","Yes","There is an argument that the plan should set out to provide a proportion of new homes as social rent, where viability permits. There seems little need for intermediate tenures given that the national First Homes policy already demands this as a matter of course. Affordable rent homes hypothecated to “key worker” housing are also justifiable to address severe local skills shortages in public services. \n\nMultiple above inflation pay awards have still not entirely addressed the ability of bus companies to recruit sufficient staff in and around Cheltenham in particular. Other service providers have similar problems. We urge the Councils to engage with providers, including the NHS, to establish the nature of these issues in more depth as art of the housing need evidence base.","","","","The plan needs to have much more regard to the underlying service economy that typically supports about half of all the jobs in a locality. Many of these are in the public sector,  but far from all of them. \n\nOperational sites for key transport infrastructure and service providers are essential to maintain and enhance their operational capabilities. There is no meaningful room to deliver significant additional increases in bus mileage during the core daytime hours in the plan area, because depot facilities are at or close to capacity in the plan area. As it is, Pulhams is running significant numbers of vehicles into the heart of the area from its operating centre a considerable distance away in Bourton on the Water at the start and end of the operating day. This is neither efficient nor especially sustainable having regard to the energy consumption involved in this “dead” operated mileage.\n\nIf the area is to see the electrification of the bus fleet, merely maintaining existing operating fleet resource will require more space. This is because the parking space needed to accommodate charging infrastructure generally reduces capacity by about 15-20% over the maximum diesel capacity. Much depends on the size and configuration of the depot site.\nEven assuming that only current bus mode share is achieved from committed new development, there is a clear requirement for more bus resource to be supported. Looking further ahead beyond 2031, the need to support this base level of organic growth cannot be supported by current depot capacity.\n\nIf even relatively unambitious mode shift targets I GLTP4 are to be achieved, this would involve a near doubling of bus passenger boardings by 2031, and a greater figure beyond that point. The implications of this for planning operational support infrastructure needs to be carefully considered by GCC and the Councils.\n\nBus depots do not fit into the statutory Use Classes Order. They are a sui generis use. There is high demand for general employment land across the plan area, and there is even more development pressure near main bus route corridors and town centres, both from commercial, employment, residential and other uses. Maximising urban capacity as the plan seeks to do, will also directly serve to remove land that might well be suitable for the necessary expansion of bus operations through redevelopment for other uses. \n\nOne only need look at the situation within 1 mile of Stagecoach’s existing Gloucester and Cheltenham premises to see that the few remaining areas of low-intensity commercial uses, for example near the railway, are already being allocated an proposed for residential redevelopment. Land adjacent to the Stagecoach Cheltenham depot site, that was occupied under a short-term lease, is now the subject of a residential redevelopment proposal – reducing the capacity of the depot as a direct result.\n\nThere is thus a direct requirement to examine how the plan might make specific provision to support the relocation and expansion of bus depots to support the County’s transport objectives set out in GLTP4 and the plans own transport strategy.\n","Employment growth needs to be properly provided for, not least to prevent further overheating in the commercial land and property market. \n\nThe tendency, already apparent, will otherwise be for important employment and service activities within the plan area to be suppressed. Where existing employment cannot sustain the rental or other land values that are being demanded, these smaller established local businesses which are a crucial part of the heathy social and economic functioning of the plan area, are less likely to move, and more likely to contract or to close altogether. This kind of economic “sanitisation”, while superficially attractive on an aesthetic level, has a profoundly corrosive effect on society.\n\nLooking beyond the existing employer ecosystem, the plan area is remarkable in the breadth and diversity of the economic base, and the range of UK and multinational businesses present, many of which engaged in strategically significant knowledge based and high value-added sectors. Many of these firms are sited on legacy sites that benefit from being on existing public transport routes, for example at Staverton, of south of Bishops Cleeve. It is important that these companies can expand and reconfigure their operations without the significant costs and risks of moving. One of these would be that a technically suitable site is remote from credible sustainable access opportunities.\n\nWhere inward investment is concerned, this must be directed to sites, whether specifically identified and allocated or not, that can support a high proportion of personal access requirements being met by walking, cycling and high quality public transport.","","For the last 20 years, national planning policy has sought to ensure that major trip-generating land uses are directed to town centres, and where comparison retail is concerned, a formal hierarchy was established that was based on a “town centres first” prioritisation. \n\nThis policy was justified by a need to ensure that the central location and exceptionally high accessibility of town centres by public transport would support the location of such uses such that over time, a reversal of car dependency and use would be achieved. \n\nLocally and nationally, this has been all but entirely resiled from in the development control arena, faced by the economic strength of retailers who source the bulk of their revenue from affluent households for whom almost every adult has exclusive use of their own car. The rise of retail parks in peripheral locations has been to a very great result, the failure of the planning system, and this cannot just be put down to market forces, strong though they undoubtedly are.\n\nThe role of town centres as places to meet and interact, across a full spectrum of backgrounds, is something the plan condoc does not recognise. It should do if it is serious about achieving the full range of Strategic Objectives it already is intending to place at the heart of plan making. There are already clear signs that town centres are becoming vacated as much by the affluent as they are by retailers, leaving town centres increasingly dependent on and occupied by the most socio-economically disadvantaged, helping feed a vicious spiral of decline.\n\nThe SLP area is fortunate that in Gloucester, after many years the regeneration of the Kings Quarter is taking place; and at least as important, the large and prominent Debenhams building has found an exciting and highly productive new role. These are adjacent to the County’s most accessible point by sustainable modes, especially public transport.  The consolidation of the University and many halls of residence into Gloucester’s central area is an extremely significant and welcome development, and further development of the post-16 Further and Higher Education into the main town centres can and should be facilitated as far as possible.  \nThis builds on the success of Gloucester Quays, which is now showing signs of positive consolidation as further investment has taken place at the northern end around the Customs House, and where the links with the historic city centre look likely to gradually strengthen as a result of the Castle redevelopment.\n\nSubstantial primary research was undertaken in 2012 which showed the value of bus passengers to town and city centres. This work was based on Cheltenham and Gloucester. It showed that bus passengers spend less per trip than car-borne visitors, but generally visited a good deal more often, and thus their actual spend per head exceeded that of car-borne shoppers. Bus passengers are more loyal to town centres, which in terms of underpinning a sustainable town centre economy, less geared to increasingly “zero-sum” competition between venues requiring long car-borne journeys, is clearly in every sense more sustainable.\n\nStrong town centres, able to develop and thrive as safe, animated venues, are crucial to a sustainable low-carbon future. \n\nThe absolute and relative attractiveness of car-borne retail parks is already waning, as the ongoing long-term vacancies at many across the plan area testifies. Many of these represent excellent opportunities for residential redevelopment, or for other edge-of centre uses, including, potentially, R+D and laboratory space.    \n\nIt is therefore vital that existing and future levels of bus services can be properly facilitated in the town and city centres. There is already little if any space capacity at bus stops and stands in Gloucester City Centre, including at the Transport interchange. In Cheltenham the convoluted circulation of buses through Cheltenham town centre, particularly from north to south, is something that is inefficient and makes no positive contribution to townscape or the visitor experience in the strongest town centre, which is relatively resilient. Notwithstanding this, Frasers plc has announced the closure of the Cavendish House department store on Upper Promenade.  The large and unremarkable building is in effect a legacy asset, which could easily be stranded. However we have long pointed out the merits of allowing buses to operate southbound only down this part of the Promenade, which would be likely to allow both more efficient bus access and circulation, and also allow other vibrant parts of the town centre, such as High Street west, to become fully pedestrianised. \n\nWe are also in deep discussions with Gloucestershire County Council about how better access for cycling across Gloucester and Cheltenham City Centres can be facilitated without prejudicing access by bus services and their reliable operation. ","The minimum turnover to sustain a convenience store is substantial, and in rural areas where car ownership and use is already very high, it is very hard to sustain any range of local shops and services, unless there is already a significant cluster of established businesses, where access to passing trade on a main through route also greatly assists.\n\nThere may be a case, in some local villages where a local service centre function is identifiable, to focus sufficient additional new development to securely anchor convenience retail provision, or, in some cases, re-establish it.\n\nHowever, it is at least as important to ensure that as many villages as possible retain access by public transport to higher-order centres. These services need to operate at least 6 days per week, at least hourly. Focusing appropriate levels of additional development in the few larger villages on existing regular bus services might be considered as a logical option to maintain rural accessibility across quite large extents of rural Tewkesbury Borough. ","As we have already stressed, the development strategy must ensure that further allocated development sites are located where existing high-quality public transport exists and/or where it can credibly be provided bus priority.\n\nBeyond that, where strategic allocations are concerned that are considered to require bus services to enter the development, it is vital that policy demands that both master-planning and phasing facilitates this in an efficient and rational manner at all points during the development life-cycle. In a very large number of cases, access by car is the only practical option, until the very last phases where primary streets are finally connected through and buses are able to enter. By this point high levels of car ownership and use are “baked in”. \n\nA clear policy expectation therefore needs to be set that phased deployment of high-quality bus services on large-scale development will take place, and that further development will not be permitted beyond established triggers set through development obligations in accordance with policy. Attempts to forestall and circumvent this by developers, formally or informally, needs to be met with robust enforcement action. \n\nBus circulation and access strategies, including indicative bus stop locations on or adjacent to development, need to form part of the application and consent of all large applications at the initial Outline Application stage, if the site is not brought forward as a full application.  There is neither justification nor need for this to be left to planning condition. There are several examples, including Gloucester Business Park within the plan area, where conditions to agreed permanent bus stop permissions have never been discharged, nor enforced.\n\nBeyond development sites, there is a clear need for urgent effective measures to protect bus services from chronic and increasingly unpredictable delay. We have been saying this for about 20 years. This is recognised in GLTP4 and the Gloucestershire Bus Service Improvement Plan (BSIP).  This needs the SLP to have due regard to and align with these strategies, and, furthermore, to identify where the development strategy might justify and/or help facilitate additional bus priority measures.\n\nThis should also extend beyond development sites to include alignment to parking policy across the county to ensure that bus journeys made from development sites remain attractive from both a financial and priority point of view. ","For new settlements there is an even greater need to ensure off-site trips can be conveniently performed using public transport as by definition, they are likely to be sited such that cycling will be a less attractive option. \n\nThus, it is essential that new settlement sites are located where existing high quality public transport corridors pass the site and/or where it can credibly be provided by augmentation or limited extension of existing services.","The settlement in its existing or expanded form needs to provide at the least for a 1 FE primary school, and a convenience store. A community hall and formal and informal public open space should also be available, or deliverable including playing pitches.\n\nThe settlement should have, or justify the augmentation of bus services running at least hourly 6 days a week to at least one town centre, and ideally two. ","Yes","No","","No",{"$cut":{"chars":17745,"head":"While the advantages and disadvantages are described in reasonably broad and fair terms there are some clearly unsupportable assumptions and statements made, that we need to challenge.\na.\tIf not, which one(s) and what are your reasons?\n\n1.\tUrban Intensification\nThis should made much clearer that development needs would not be met by a substantial margin, aggravating housing availability and affordability problems and suppressing economic potential. This is a serious disadvantage and would go the heart of the soundness of the plan.\n\n2.\tUrban extensions\nWe broadly agree that the summary of pros and cons is fair and reasonable.\nWe recognise that there are some good options, of a limited but still strategic scale  south of Hatherley Way, and East of Churchdown that avoid the vast majority of disbenefits and secure advantages, including the ability to take advantage of high-quality public transport from first occupations, and the availability of secondary education within walking and cycling distance. However, they are relatively few and far between, and could not accommodate the majority of the likely residual development requirement that needs to be identified.\n\n3.\tUrban extensions, avoiding the Green Belt\n6.23 makes the very helpful distinction between Green Belt policy and other protections to landscapes and habitats that have more objective and legally-based rationales:\n“Green Belt land is, as a matter of national policy, designated as a means of managing urban growth, rather than providing environmental protection. This scenario would include land which was previously removed from the Green Belt in the JCS and ‘safeguarded’ to meet longer term needs.” \n\nThe JCS removed and “safeguarded” some additional land from the green belt at Twigworth and at Hayden, adjoining existing strategic allocations A1 and A7, to help meet longer term development needs. These areas are included in this scenario. These areas are most likely to help consolidate demand for bus services already likely to be necessary at West of Cheltenham. At Twigworth, bringing forward the safeguarded land should seek to ensure that a bus route corridor from the eastern boundary of the current allocation is secured to the east towards Innsworth and/or Hatherley.  These are significant inherent advantages offered by these options.\n\nThe transport implications of these options are highly site-specific and not amenable to be broadly categorised. If options are on existing or potential high quality bus corridors – such as the A38 between Gloucester ad Tewkesbury or even north or west of Bishops Cleeve, they may offer some potentially good options, though mostly not as good as options that are closer to Gloucester and Cheltenham in particular, such as east of Churchdown.\n\nWe do recognise that credible options on these sites would probably not be sufficient to meet the development needs of the plan area in full. \n\nHowever, that said, there is clear evidence that credible and potentially very sustainable options exist adjoining the Gloucester Urban area in Stroud District, both at Whaddon and at Hardwicke Green. These have been tested through the Stroud District Local Plan Review EiP within the last year. It is somewhat surprising and inexplicable that there is no reference to these in the condoc, especially since they were highlighted by the previous EiP Inspector for the JCS as being worthy of a future collaborative approach with Stroud District Council, who then brought these both forward as proposed allocations in a Regulation 19 plan within the last 2 years.\nThe options south of Tewkesbury on the A38, as well as at Mitton that already have some planning status within the South Worcestershire Development Plan, are very well located on public transport corridors – though south of Tewkesbury needs very careful urban design to take advantage of the main Tewkesbury-Gloucester and Tewkesbury-Cheltenham bus corridors.\n\n4.\tNew strategic settlements\nParagraph 6.29 refers to this option in the following terms:\n“This option would mean seeking to deliver development through o"}},"Scenario 6: Sustainable Transport","","","[Q1] The Consultation proposes a baseline date of 2022 and a horizon of 2042. We consider the following points to be important to consider for extending to 2045:\n•\tSchemes and plans running in parallel having an impact in resources and delivery at County Council Level\n•\tAligning with the National Highway Road Periods linked to the investment needed for the A46 and M5\n•\tSites such as a Garden Town at Ashchurch are going to take a great deal longer to bring forward and deliver over a period longer than the plan horizon date.\n•\tThe plan must recognise that there is already a deficit from the delays in bringing strategic development forward from the last plan adopted in 2017.\n\nNPPF is clear that plans must run for a minimum of 15 years beyond the date of adoption.  Thus 2042 would be the earliest prudent horizon having regard to preparation and examination timescales. \n\nThe Councils ought already to be aware that, after over 30 months of confusion and stasis at national level while major reform of the planning system has been deliberated over, a very large number of local plans are now being reprised and taken forward in parallel. This is going to cause a substantial issue in resourcing what could be an unprecedented requirement for Local Plan Examinations in the Planning Inspection National Service (PINs).\n\nSection 2.9 in the Consultation Document (“condoc”) states that “Some sites are large enough to justify a longer period if they were to be chosen.”  This is plainly the case for “Garden Town” at Ashchurch (AGT), which was always going to involve a very extended delivery period, and one likely to both dependent and follow on from investment on the A46 and M5, which for part of the national SRN; as well as the railway. Both are subject to 5-year planning periods. As such it may be prudent to align the plan period with National Highway Road Periods (“RP”). 2042 lies at the start of RP5 (2040-2045).\n\nIt is also important to consider aligning the delivery of development with the need to secure major funding for highways infrastructure on the SRN, that may already be partly justified and to give the necessary certainty that these investments will align with the housing trajectory. \n\nThe development quantum is plainly of a scale that is likely to make at least one very large strategic allocation necessary, which would be likely to extend beyond the plan period as currently defined.\n\nIrrespective, the base date of the plan should be 2020 or 2021. There has been a deficit in housing delivery against assessed need to date. The plan should not seek to “write this deficit off”, in effect moving homes that are already allocated to meet existing needs, and re-hypothecate them in effect to meet future needs.    \n\nIt is also considered useful for the plan to set out some achievable timescales that will be followed in order to prioritise schemes  and allow for forward planning for service providers for the future.]\n\n[Q13] There are no apparent constraints that would justify the Councils not seeking to meet assessed housing and other development needs in full.]\n[Q.26] (Safeguarding sites or routes for longer term infrastrucutre) This will be a necessary measure to demonstrate the deliverability of the plan and the key infrastructure needed to support it.\n\nThis is likely to include transport measures already identified in GLTP4 and any successor Local Transport Plan. It should also include the committed infrastructure measures already progressing, in the plan area, but yet to commence or be completed.\n\nIt is recognised that key interventions are not fully defined and preferred routes are not yet identifiable. This may well be the case on the A46 between Teddington Hands and the M5. It may be that a broad wider corridor needs to be identified for this and other schemes when there is sufficient certainty that they feature in the delivery programmes of transport infrastructure providers.\n\nWe also invite the Councils to discuss with us the potential to identify suitable sites that might be necessary to accommodate future bus depot sites. \n[Q27] Stagecoach and Pulhams consider the six scenarios represent the full range of realistic alternatives that should be considered.]\n\n[Q31] We note and welcome that the previous JCS Review has been abandoned. Stagecoach had serious concerns about the effectiveness of emerging approaches to assessing sustainable transport connectivity and the potential for public transport.\n"]
["Statutory/Specific Consultee","Severn Trent Green Power limited",15,"STGP agrees with the broad strategic topics that are identified, and in particular supports recognition of the need for sufficient provision for sustainable waste management and renewable/green energy infrastructure, to help address climate change.","","","STGP agrees with the draft Vision for the Plan. In particular, the Company supports the vision for ‘green growth’ and growth which achieves carbon reductions and addresses climate change. STGP’s sustainable waste operations, which support a circular economy, contribute to decarbonisation of the energy grid and help to achieve local and national targets for carbon reduction, are in line with the Vision for the Cheltenham, Tewkesbury and Gloucester area.","","STGP broadly agrees with the draft Strategic Objectives put forward in the Plan. The Company particularly supports ‘growth that contributes to decarbonisation’ with a reduced reliance on fossil fuels, and the delivery of low and zero carbon development. STGP also strongly supports maximising the use of renewable energy opportunities. Whilst it is\nnoted the objectives include ‘ensuring development incorporates measures to reduce waste’ it is considered this could go further by specifying that waste minimisation, recycling and recovery of value from waste (in support of a circular economy) is a key priority.","STGP strongly supports the transition to a low carbon future, and the need to provide secure local supplies of renewable\nand low carbon energy. This is key to addressing the challenges of climate change and achieving the necessary reductions\nin greenhouse gas emissions. STGP welcomes and supportsthe proactive approach being taken by the councils to address\nthese issues, and further welcomes the Renewable Energy Study (RES) commissioned by the councils. The RES should\nfully recognise the contribution which can be made by AD treatment of organic waste (with associated recovery of green\nenergy).","","","","","","","","STGP would support the allocation of sites in the SLP for renewable energy generation and storage. The Company is actively seeking to develop more renewable energy facilities, including solar power sites, in the Gloucestershire area. STGP would support the allocation of suitable land which is part of the current Severn Trent portfolio (i.e. on or adjacent to Severn Trent Water sites), on which the Company may develop further renewable energy, including solar power, sites in future. In addition, storage will be very important in the future, to help maintain supply to the grid through peak times of the day and to help manage operational sites throughout the night time, and therefore STGP would advocate for the inclusion of storage at any/all identified renewable energy sites.","","","","","","","","","","STGP is very supportive of the vision for creating improved employment opportunities whilst achieving the transition to a low carbon economy. Furthermore, the key propositions of the emerging Gloucestershire Economic Strategy - including Sustainable Growth (ensuring proposals support carbon net zero targets), Inward Investment (fostering innovation and job creation across the County) and Business Support (enabling businesses to innovate, create jobs and positively contribute to the transition to a low carbon economy) - are very much supported. STGP considers the SLP should provide clear support to existing business to grow and expand, particularly where it can be demonstrated that those businesses support the transition to a low carbon economy and carbon net zero targets, in line with the Plan’s Vision for ‘green growth’","","","","","Alongside the critical infrastructure identified in the consultation document (e.g. roads, schools, public transport, healthcare services and recreation provision), STGP considers that provision for the sustainable management of waste from new development, and the provision of adequate sustainable waste management facilities, is of key importance. As such, STGP considers that strategic waste facilities which will play a significant role in the management of the County’s waste in a sustainable way for the foreseeable future - such as the Company’s AD facility at Bishops Cleeve - should be identified and safeguarded in the Plan for this purpose.","See above; if new settlements were to be developed as part of the SLP, there would be a need to consider the provision of existing and future sustainable waste management capacity to serve the needs of new settlement areas/populations. Expansions could be required to existing sustainable waste facilities, or new facilities could be required in order to manage the additional amount of waste arising. In addition, renewable energy infrastructure should be included as a key part of the development of new settlements, to ensure that new development is in line with the Vision and key Objectives of the\nSLP - for ‘green growth’ which achieves carbon reductions and addresses climate change.","","","","","","","","","","[Q1 - STGP agrees with the proposal that the SLP should cover a period of 15 years, with a review of the Plan every 5 years.]\n\n[Q8 - STGP considers that the Plan should reflect the national requirement for 10% Biodiversity Net Gain. As identified in the draft Plan, going beyond this will represent an additional cost to developers and potentially compromise the viability of development (this would be true of AD/waste developments). STGP would support a coordinated approach to the provision of off-site biodiversity enhancements, where this is necessary to deliver the required BNG. The Plan should be clear on which sites the BNG requirements apply to, and which sites are exempt (e.g. ‘Section 73’ applications where the original permission was granted before the BNG requirements came into force).]\n\nINTRODUCTION\n\nThis letter provides the representation on behalf of Severn Trent Green Power Limited (STGP) to the consultation on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (SLP) Issues and Options document, which was published jointly by the councils of Cheltenham, Gloucester and Tewkesbury on 16th January 2024. The consultation period runs until 12th March 2024, with views being sought by the councils on the draft Vision and Strategic Objectives, and the key issues and opportunities for development, to be included in the Plan.\n\nThe SLP covers the areas of Cheltenham Borough Council, Gloucester City Council and Tewkesbury Borough Council. It is intended that the Plan will provide strategic policies that will cover the entirety of the council areas. It will also include local policies, which will apply to a specific area only. As stated at paragraph 2.2 of the consultation document, it is intended that the Plan will:\n• “Set a clear vision, strategy and polices for how the area will grow, providing clarity for what development will and will not be acceptable.\n• Set out requirements for the delivery of new homes, jobs and infrastructure to meet the needs of the community and the local economy in a way that is sustainable and addresses our commitments to climate change.\n• Provide a framework for Neighbourhood Plans, which can be developed by communities”.\n\nThe current timetable is for the SLP to be submitted to the Secretary of State for Examination in 2026, with adoption by the councils sometime thereafter. The SLP will cover the period at least up to 2041.\n\nThe SLP consultation document poses a number of questions on key matters, on which views are sought in order to help develop the Plan. It is noted that, at this stage, the draft Plan does not include specific sites for development.\n\nThis representation provides STGP’s views on the SLP Issues and Options consultation document.\n\nABOUT SEVERN TRENT GREEN POWER (STGP)\n\nSTGP is a leading waste recovery and renewable energy provider operating across the UK. The company owns and operates an award-winning network of anaerobic digestion (AD) facilities, for the treatment and recovery of energy from food waste, as well as in-vessel composting (IVC) facilities treating a combination of food and green waste, and open windrow composting (OWC) sites treating green waste only, plus a number of wind turbines and solar farms.\n\nThe Company is fully committed to sustainable development and supporting a circular economy; our priority is to make a positive impact on the environment. Our facilities and infrastructure produce a total of 58MW of renewable energy, sufficient to power 115,000 homes each year. Additionally, STGP is the largest producer of renewable energy from food waste in the UK. Further details of STGP’s operations are available on our website: www.stgreenpower.co.uk.\n\nSTGP’s Operations in Gloucestershire\n\nAD is an important and proven sustainable waste treatment technology, which takes separately collected food waste from Local Authority and commercial sources and treats it using a safe and established biological process in order to produce a sustainable and consistent source of renewable energy (i.e. ‘green gas’) and a nutrient-rich biofertiliser (or ‘digestate’) for use in agriculture. All of STGP’s AD plants are PAS 110 accredited, meeting the highest and most stringent quality standards for the digestate produced, and operating just one of the Company’s AD plants has the net carbon benefit of taking 71,000 cars off the road. STGP currently operates one of its AD facilities just north of Cheltenham, at Wingmoor Farm East, Orchard Road, Bishops Cleeve:\n\nSTGP recently acquired the AD facility at Bishops Cleeve from Andigestion (the previous operator of the site). Established in 2015, the AD facility provides vitally important food waste recycling and renewable energy generation capacity for the Cheltenham, Tewkesbury and Gloucester area. The Bishops Cleeve plant predominantly processes household food waste collected from residents within Gloucestershire and has done so since it started operating in 2015.\n\nThe Company’s facilities make a significant contribution to the greening of the economy, in ensuring that organic waste is managed sustainably higher up the waste hierarchy, helping to decarbonise energy supply and improving the soil quality of agricultural land. Such facilities will become even more important in the coming years, with the passing of new legislation recently which mandates the separate collection of household food waste by March 2026. Added to this is increasing targets for waste recycling (the target for Gloucestershire in 2020 was 60%, with actual rates for 2020/21 around 51%) and the key aims of the ‘Greener Gloucestershire’ climate campaign (which includes minimising waste sent to landfill and increasing recycling rates, as well as a clear commitment to renewable energy and reducing the County’s carbon footprint). All of which serves to demonstrate the importance of facilities such as the one at Bishops Cleeve and ensuring their long-term future through the strategic planning process.\n\nIn addition to the AD facility at Bishops Cleeve, the Company owns and operates a number of solar power sites. STGP is actively seeking to develop further renewable energy facilities, including solar power sites, in the Gloucestershire area. [Also see separate PDF which contains an image].\n\nSTGP REPRESENTATION\n\nSTGP has the following comments to make in respect of the SLP Issues and Options consultation document, and in particular to some of the specific questions raised.\n\nSTGP wishes to reiterate the importance of strategic, sustainable waste management facilities (such as the AD facility at Bishops Cleeve) and the vital role of these sites, along with other renewable energy facilities, in contributing to a low and zero carbon future. As such, it is considered that these sites should be identified and safeguarded in the SLP to ensure they can continue to support the County’s ambitions.\n\nCLOSE\n\nThe above provides STGP’s views on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (SLP) Issues and Options document. We trust these views are helpful and will be taken into account as the Plan progresses.\n\nWe look forward to the opportunity to consult on any further proposals in due course"]
["","","","Tewkesbury Council revenue from Council tax should be shared with Cheltenham who are providing facilities. development only on low grade agricultural land. re-purposing old buildings should take priority. ","","","green growth only applies to plants. abolition of parking charges. unlike destruction of Lansdown Industrial estate. ","","tall street trees, but not green walls. solar panels on industrial building roofs. expand capacity of sewage works for foul sewage. space for recycling containers. green growth only applies to plants. increase minimal space standards. abolish parking charges. not necessarily family friendly. too many retirement homes in Cheltenham. locate night clubs, lap dancing etc. in one area. who is the judge? infrastructure first. what about disabled, young mothers, deliveries, tradesmen etc.? is the problem the vehicle or the fuel? incentivise re-use of exiting buildings and brownfield land. we should not drive to the Cotswolds, but have plenty of parks within short distance. tree lined streets with large long-lived trees. large flat grass areas required throughout developments for informal football, cricket etc. how? who pays for maintenance? better to provide larger gardens. larger gardens/ plots. larger plots with space to expand accommodation.","rats, pigeons and seagulls. don't build on floodplains and retain run-off on-site. financial incentives required to match new build. financial incentive required. penalising urban development to pay for habitats miles away, when users need to drive there is not sustainable. need large trees and gardens to provide shade for buildings. stop use of bedding displays in parks, hanging baskets, planters etc. local wind turbines providing power for local residents. internationally designated sites are not nearby, and more likely to be affected by the Javelin incinerator. huge inequality between disadvantaged and wealthy areas of town. There are plenty of opportunities to replace street trees and trees in housing areas. BNG does not need wardens, signposts etc.as it is just an informal park. insist on tree lined streets with long lived large trees.","new buildings to have 100+ year life expectancy.","","No","Yes","most council housing areas","outdoor play spaces with no equipment","","solar panels on all industrial building roofs wind turbines for local supply away from flight path","","these figures do not take account of people moving out of the area. not really relevant when so many permissions are not built. ","","conversion of office buildings and above shops into flats","","houses can be small, but must be on larger plots to accommodate extensions etc. patronising to think that older, or disabled people should have different housing. can do that anyway. all houses etc. should be accessible otherwise you are discriminating. why are we housing Bristol and Hartpury students in Cheltenham? where are refugees going to be housed?","No","no, their transitory and recycling activities need more space. there are currently sites, and if they are travellers they should move around. ","same as existing sites","is this really exciting?","","provide skills training centres on bus routes","out of date figures abolish parking charges so shops can compete with out of town shopping centres","","financial incentives required for developing brownfield sites sewage treatment capacity and measures to prevent flooding","","road and rail connections to towns and cities","No","","Council revenue from Council tax should be shared with Cheltenham who are providing facilities","","Need financial incentives. 20% cheaper to build new rather than convert existing buildings, and no reclamation cost on greenfield land. Scenario 1 most sustainable option. Scenario 2 urban sprawl least sustainable option. Scenario 3 floodzone development away from facilities and employment. Scenario 4 floodzone development away from facilities and employment. Scenario 4 sustainable way of integrating housing in existing communities whcih would support schools, shops and businesses, this type of development would provide more space for people to work from home and internet provision is good. Scenario 6 we can't even get a satisfactory mainline train service at the moment. Is the problem the car or the fuel? Physical elitism is discriminatory towards disabled, elderly and mothers with young children. Everyone is disabled in some way at some stage of their life and should not feel that they are excluded from living anywhere. Why is a link between Gloucester and Cheltenham so important? People live and work all over the south west and this is a very parochial assessment of  travel requirements.","Scenario 1: Urban concentration","","","[Q26] no, because cannot predict future requirements and causes blight"]
["Planning agent or developer","Newbridge Construction Ltd",20,"Green Belt policy is a strategic issue that goes beyond individual LPA boundaries and therefore should not be left to individual Local Plans or left to whether it happens to form part of the chosen SLP scenario(s).  Although the protection or loss of parts of the Green Belt is implicit in some of the various scenarios, its boundaries should be reviewed as a strategic topic of its own. Irrespective of which scenario (if any) is followed, it is important that the green belt is reviewed in order to aid delivery of enough homes in the right places whilst protecting land that deserves to be protected rather than simply continue protecting land just because it has always been so. For example, there is land around the edges of Cheltenham that could be removed from the Green Belt and would form a logical rounding off of the urban area without undermining the function of the Green Belt;  such as around The Reddings and at the junction of the A46 and Up Hatherley Road.","The allocation of local community facilities such as POS & play areas, the designation of conservation area boundaries (historic & the natural environment), local infrastructure needs, detailed design policies, local town/city centre policies & individual settlement policies.","","The vision focusses on delivering housing on brownfield sites or large scale sites but ignores the potential for smaller or green field sites that will round off settlements and help deliver much needed local/affordable/specialist housing in sustainable, safe locations within walkable neighbourhoods. Individually these sites may not deliver large numbers of houses but collectively can make the best use of land to contribute to the overall housing target and ensure that development integrates with existing development. A number of small sites rather than one large one will also deliver housing numbers more quickly. This would tie in with the strategic objective of ‘ensuring growth takes place in sustainable locations that minimise the need to travel and provide genuine sustainable transport and active travel options.’","No","The addition of a Strategic Objective to review Green Belt boundaries is needed to allow small scale housing development in sustainable locations where it would round off a settlement, integrate with it and help create a walkable neighbourhood.","","","","","","","","","","No","The Standard Method should merely be the starting point as it can be affected by factors that are related to housing affordability rather than housing need.  The Standard Method is aimed at creating a level playing field by trying to prevent LPAs from ducking their responsibilities to deliver enough housing but, in reality, it is too blunt a tool and can have the opposite effect. The median house price to work-place earnings ratio affects the minimum local housing needs figure when using the Government’s Standard Method. In theory this means that the affordability of housing nationally has improved. However, this is, in part, because the increased cost of living crisis means that households now have to spend a greater proportion of their income on basic necessities and therefore have less to spend on housing; which has, in turn, affected house prices. \n\nAccording to the Standard Method housing need has reduced in Gloucester, Tewkesbury and Cheltenham since 2021, whereas the reality is the opposite. In addition, whilst the affordability figure has reduced it is still over 8 times the median salary; which is considerably more than the maximum mortgage salary multiplier, meaning that housing remains unaffordable for many, especially for 1st time buyers. Other factors, such as the economic success of an area, means that areas such Gloucester, Tewkesbury and Cheltenham are more desirable to inward migration and these reasons mean that a ‘local’ multiplier should be applied to ensure that the right number of houses are delivered. Even if the Standard Method is used, the SLP needs to aim above the minimum target in order to even achieve it. Unforeseen events and delays always affect the delivery of individual sites which needs to be taken into account. An overprovision is necessary to ensure delivery of the required numbers. Finally, if the successful strategic scenario involves the allocation of a small number of large sites they will inevitably have problems with the delivery of large housing numbers earlier on in the plan period or complete delivery by the end of the plan period as they are inherently more susceptible to being delayed by problems than a number of smaller sites; which are collectively more resilient to problems on individual sites.","","A number of factors, such as the median house price to work-place earnings ratio affect the minimum local housing needs figure when using the Government’s Standard Method. These factors cannot be modified using the Standard Method alone. For example, in theory the current median house price to work-place earnings ratio means that the affordability of housing nationally has improved since 2021. However, this is, in part, because the increased cost of living crisis means that households now have to spend a larger proportion of their income on basic necessities and have less to spend on housing; which has, in turn, affected house prices.  According to the Standard Method housing need has reduced in Gloucester, Tewkesbury and Cheltenham since 2021, whereas the reality is the opposite. In addition, whilst the affordability figure has reduced it is still over 8 times the median salary; which is considerably more than the maximum mortgage salary multiplier, meaning that housing remains unaffordable for many, especially 1st time buyers. Other factors, such as the economic success of an area, means that areas such Gloucester, Tewkesbury and Cheltenham are more desirable to inward migration and these reasons mean that a ‘local’ multiplier should be applied to ensure that the right number of houses are delivered. Even if the Standard Method is used, the SLP needs to aim above the minimum target in order to even achieve that. Unforeseen events and delays always affect the delivery of individual sites which should be accounted for; an overprovision is necessary to ensure delivery of the required numbers. Finally, if the successful strategic scenario involves the allocation of a small number of large sites they will inevitably have problems with the delivery of large housing numbers earlier on in the plan period or complete delivery by the end of the plan period as they are inherently more susceptible to being delayed by problems than a number of smaller sites; which are collectively more resilient to problems on individual sites. Larger sites also deliver proportionally fewer houses per annum than a number of smaller sites delivering the same overall quantum.  ","","","","","","","","","","","","","","","Yes","Yes –  Para 6.8 acknowledges that none of the scenarios would deliver what is needed on their own but whilst the various scenarios focus on specific solutions (ie brownfield sites or large scale sites) they ignore the potential for smaller sites to make a valuable contribution. This has meant so far that some small sites on the edges of Cheltenham have not been brought forward because, so far, the numbers have been delivered by urban extensions in Tewkesbury and it would appear that the current scenarios will simply repeat that. There are small sites that are currently in the Green Belt, such at The Reddings and at the junction of the A46/Up Hatherley Road, which contribute little to Green Belt objectives but are still protected because it is easier to continue to do so. Freeing these sites up for development would simply round off development in parts of Cheltenham to help deliver much needed local/affordable/specialist housing in sustainable, safe locations within walkable neighbourhoods. Individually they may not deliver large numbers of houses but collectively can make the best use of land to contribute to the overall housing target and ensure that development integrates with existing development. This would tie in with the strategic objective of ‘ensuring growth takes place in sustainable locations that minimise the need to travel and provide genuine sustainable transport and active travel options.’ This additional scenario would complement the others and, with the addition of a Strategic Objective to review Green Belt boundaries, allow small scale housing development in sustainable locations where it would round off a settlement, integrate with it and help create a walkable neighbourhood.","","","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","[Q1] 15-20 years but with a mandatory review after every 5 years to determine if it is out of date. The macro environment is extremely volatile and the pace of change is increasing. Planning policy must be able to respond and adapt accordingly and therefore the strategic horizon should be able to be shortened in the event that the plan has become out of date. \n[Q28] The following combination: 1. Urban concentration. However, this should be linked a Green Belt review rather than retreat within current boundaries. In addition to maximising housing within the current urban areas, it would allow housing development in sustainable locations where it would round off a settlement, integrate with it and help create a walkable neighbourhood. 2. Urban extensions – of existing urban areas, including within (and outside) the Green Belt. 5. Rural dispersal  This should be linked to a Green Belt review to allow housing development in sustainable locations where it would round off a settlement, integrate with it and help create a walkable neighbourhood. There are redundant farms on the edge of the urban areas that lie in the Green Belt which could make valuable contributions to housing numbers. 6. Sustainable transport. "]
["Planning agent or developer","North Ashchurch Consortium ",null,null,null,"Yes","The Consortium support the principles of the draft Vision, and in particular reference to meeting people’s housing needs through delivery of large-scale, comprehensively planned new development.","Yes","The Consortium support the draft Strategic Objectives set out.",null,"The Future Homes Standard, which is set to be introduced by the Government in 2025, will support the move towards low carbon and energy efficient homes as a national requirement through Building Regulations. It is important to ensure that any additional policy requirements that are sought to be implemented through the SLP are proportionate and do not impact development viability.","The Future Homes Standard, which is set to be introduced by the Government in 2025, will support the move towards low carbon and energy efficient homes as a national requirement through Building Regulations. It is important to ensure that any additional policy requirements that are sought to be implemented through the SLP are proportionate and do not impact development viability.",null,null,null,null,null,null,null,"The NPPF is clear at Paragraph 61 that to determine the minimum number of homes needed, strategic policies should be informed by a Local Housing Need assessment derived from the Standard Method. Whilst Paragraph 61 of the NPPF recognises that the Local Housing Need assessment derived from the Standard Method is an advisory starting point, exceptional circumstances must be demonstrated to justify an alternative approach.\nThe Councils should prepare evidence to support the formulation of the Preferred Options which reviews current and future local demographic trends, and consider this in tandem with the Councils’ Vision and Objectives, to ensure a sufficient number of new homes is planned for in the SLP.",null,null,null,null,null,null,null,null,null,null,null,null,null,"Delivery of infrastructure to support strategic scale development should be proportionate, and considered on a case-by-case basis. This is to ensure that development can be delivered with appropriate infrastructure to meet the needs arising, and for mitigation measures to limit impacts on existing communities without undue impact on development viability.",null,null,null,"The Consortium consider that the six Development Scenarios are sufficient, recognising the likelihood that it will be a combination of those Development Scenarios which comprise the Development Strategy for the SLP.",null,"Generally the assessment of all 6 Development Scenarios is considered reasonable.\nWith regard to Development Scenario 1, although urban concentration is supported in principle, only providing housing within the urban areas of Cheltenham and Gloucester would not provide diverse housing across the region, meaning that needs across the SLP area will not be adequately met. As is recognised in the Spatial Options and Key Policy Areas consultation document, a Development Strategy based solely on Development Scenario 1 would not deliver sufficient new homes and jobs, and thus it cannot be solely relied upon.\nDevelopment Scenarios 2, 3 and 4 should also make reference to delivery being supportive of Tewkesbury Borough Council’s Garden Communities programme. Tewkesbury Garden Communities was awarded Garden Town status in 2019 with work being undertaken by Tewkesbury Borough Council to move the project forward, including the adoption of a Charter to shape development proposals in the Garden Communities in the time preceding the adoption the SLP.\n\nDevelopment Scenario 5 is not considered sustainable as development would be dispersed across the area and small scale development does not offer the opportunities to provide the infrastructure larger strategic sites can offer. In addition, Development Scenario 5 would support development in locations with limited services and facilities, and generally poor public transport accessibility, meaning a greater reliance on the private car. Indeed, the NPPF at Paragraph 82 recognised that planning policies in rural areas should be responsive to local circumstances and support housing developments that reflect local needs. It is noted that Development Scenario 5 is the worst performing option in the supporting Sustainability Appraisal (December 2023) which should guide the Councils’ decision-making for the emerging SLP.\nWhilst Development Scenario 6 would support development in locations with existing or planned access to sustainable transport, a reliance on delivery of the Gloucestershire Mass Rapid Transport system which is still in the early stages of being investigated is not considered sound at this stage. Indeed, Development Scenario 6 appears to be the second worst performing option in the supporting Sustainability Appraisal.The Consortium consider that the most appropriate Development Strategy is likely to be formed of a mixture of Development Scenarios that primarily support brownfield development and large-scale, comprehensively planned new development, supporting the Councils’ draft Vision and Strategic Objectives, including importantly the first phase of the Tewkesbury Garden Communities programme which includes Land at North Ashchurch.\n39. There are significant benefits associated with the delivery of strategic-scale development, including the provision of significant housing that can be comprehensively planned to meet needs in the most sustainable manner, supported by the delivery of significant infrastructure.",null,null,null,"[Q1] The National Planning Policy Framework (NPPF, December 2023) is clear at Paragraph 22 that “strategic policies should look ahead over a minimum 15 year period from adoption, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure” and that “where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery”. On that basis, the Consortium consider that the SLP Plan Period should run to at least 2042, and given the likelihood that the Development Strategy will incorporate larger scale developments, the SLP should be set in the context of a vision that looks ahead until at least 2057.\n\n[Q.8] The Environment Act allows Local Plans to seek a higher Biodiversity Net Gain requirement than the established 10% minimum, however any proposed requirement above 10% should be sufficiently evidenced and not impact development viability.\n\n[Q.29] The Consortium consider that the most appropriate Development Strategy is likely to be formed of a mixture of Development Scenarios that primarily support brownfield development and large-scale, comprehensively planned new development.\nIn particular, the Consortium consider that establishing the Tewkesbury Garden Communities programme through the SLP is important, and more specifically the northern Garden Communities as the first phase, recognising work already undertaken by Tewkesbury Borough Council supported by interested landowners and developers. The inclusion of strategic-scale development in the SLP Development Strategy is supportive of the Councils’ draft Vision and Strategic Objectives to create thriving, beautiful, energy efficient, resilient and healthy places. These strategic sites can provide sustainable housing that is set in beautiful, safe places and that conform to sustainable standards of design and construction. Due to the nature of strategic sites, they can be comprehensively planned to meet needs in the most sustainable manner.\nIn addition, delivery of strategic-scale sites are more readily able to deliver significant infrastructure, which options such as Development Scenarios 5 that encourage smaller scale development across the region do not support. Therefore, we think that the scenarios that support larger scale, strategic sites are more appropriate options to ensure that new developments are planned to meet needs. (site promotion for Land at North Ashchursh included with submission)\nBased on the Consortium’s assessment, Tewkesbury Garden Town and more specifically Land at North Ashchurch is the best performing Development Scenario, and the Councils should take this evidence into account when formulating the Development Strategy for the SLP.\n\nLand at North Ashchurch forms a significant part of the initial northern phase Tewkesbury Garden Communities. The Consortium consider that Land at North Ashchurch can provide significant delivery of the first phase of the Garden Communities, delivering a consistent supply of new homes throughout the SLP Plan Period and likely beyond.\n41. Land at North Ashchurch is adjacent to the only urban edge of Tewkesbury which isn’t significantly constrained by Flood Risk or the Battlefield land associated with Battle of Tewkesbury, and is bordered by development. It is also well located and accessible to the existing residential and commercial areas of Northway, Ashchurch, and Tewkesbury, including via existing pedestrian / cycle routes, and therefore capable of providing a genuine choice of transport modes for future residents. Indeed, it is the only location in the Plan area where significant development can be accommodated within walking distance of a mainline rail station with connections to Cheltenham, Gloucester and regional centres such as Bristol and Birmingham. A significant level of initial technical work which has been commissioned by the Consortium to inform the Framework Masterplan Document which has been prepared by the Consortium and incorporates all land within the northern phase of the Tewkesbury Garden Communities (including Land at North Ashchurch), demonstrating how the land can come forward in a comprehensive manner to deliver a significant level of housing growth supported by relevant infrastructure. A series of technical reports demonstrating the deliverable and suitability of the land are submitted in support of the allocation of the Site.\n43. The Consortium respectfully request that Land at North Ashchurch is proposed for allocation in the SLP Preferred Options, and welcome the opportunity to continuing to work positively with Council Officers and Members in bringing the initial northern phase of the Tewkesbury Garden Communities to fruition.\n"]
["Planning agent or developer","Vinci St Modwen and the Defence Infrastructure Organisation",20,"","","","","Yes","The draft strategic objectives are, in the main, supported. Indeed, we entirely agree with objectives such as  the needs to ensure growth takes place in sustainable locations that minimise the need to travel. We will  come back to this later in our commentary on the development scenarios.\nThe only other comment on the strategic objectives is the level of detail. In some cases the detail appears to be out of context for a strategic objective and, in places, even for a local plan. For example, objective eight \nunder the meeting the challenges of climate change heading states that: “Ensure people can make carbon friendly choices at home by providing easy to use cycle storage,  covered space to dry washing outside, space to grow food and compost.”\nThe matters covered in this objective are not 'strategic' in nature but are matters of detail which in many ways  extend beyond the remit of the SLP and would be better suited to SPD. This level of detail has led to a list of  draft strategic objectives which are too lengthy and not strategic in their application. We therefore recommend  that the authorities revisit the draft strategic objectives and to elevate the level of detail such that the \nobjectives can be applied more broadly to the development of the subsequent policy details.","Section 4 of the consultation document provides a detailed answer to its own question. In so doing, it outlines a number of policy tools and measures which can be incorporated into the SLP in order to address climate change and deliver nature recovery. We consider that the most important of these for the SLP and the most impactful is the allocation of land in the most accessible and sustainable locations. Doing so is clearly consistent with national planning policy and Section 39(2) requirement of the Planning and Compulsory Purchase Act 2004 which requires planmaking bodies to: “exercise the function with the objective of contributing to the achievement of sustainable development.”  It is the location and broad form of development with which the SLP should concern itself rather than building design and engineering which is more appropriately dealt with under the Building Regulations. For the reasons explained in our response to question 7(a), the SLP should focus exclusively on planning considerations and not matters which are covered by other regulatory regimes.","Whilst we recognise that there may be a desire to establish ambitious targets for future development, for the \nreasons explained below, we do not consider that such an approach would be consistent with national policy \nand therefore sound.\nOn 13 December 2023 there was a Written Ministerial Statement (WMS) by the Minister of State for Housing, \nLee Rowley, which relates to the construction and operation of new buildings and which is it therefore directly \nCheltenham, Gloucester and Tewkesbury SLP\nIssues and Options Consultation: Spatial Options and Key Policy Areas\nVSM and the DIO March 2024 5\nrelevant to this question. The WMS includes a number of statements which are pertinent to the soundness \nof a draft policy:\n“The improvement in standards already in force, alongside the ones which are due in 2025, \ndemonstrates the Government’s commitment to ensuring new properties have a much lower impact \non the environment in the future. In this context, the Government does not expect plan-makers to \nset local energy efficiency standards for buildings that go beyond current or planned buildings \nregulations.\nAny planning policies that propose local energy efficiency standards for buildings that go beyond \ncurrent or planned buildings regulation should be rejected at examination if they do not have a wellreasoned and robustly costed rationale that ensures:\nThat development remains viable, and the impact on housing supply and affordability is considered \nin accordance with the National Planning Policy Framework.\nThe additional requirement is expressed as a percentage uplift of a dwelling’s Target Emissions \nRate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP).\nWhere plan policies go beyond current or planned building regulations, those polices should be \napplied flexibly to decisions on planning applications and appeals where the applicant can \ndemonstrate that meeting the higher standards is not technically feasible, in relation to the \navailability of appropriate local energy infrastructure (for example adequate existing and planned \ngrid connections) and access to adequate supply chains.\nTo be sound, local plans must be consistent with national policy – enabling the delivery of \nsustainable development in accordance with the policies in the National Planning Policy Framework \nand other statements of national planning policy, including this one”. [emphasis added]\nIt is clear from the WMS that the Government considers the Building Regulations to be the preferred and \nprimary mechanism to deliver improvements in energy efficiency and reduce the carbon emissions from \ndevelopment. There are a number of reasons why such an approach is supported and considered to be \nappropriate and sound.\n First, there is a logical cut off point between the two statutory regimes which it is helpful to keep separate. \nPlanning is concerned with matters such as the location, form and design of new development, and Building \nRegulations controls matters of detailed design and construction such as building fabric, fire safety, access \netc. These two statutory regimes are both equally important but have necessarily separate application and \napproval processes which reflect the stage at which they are applied to development and the knowledge of \nbuilding form and fabric which is available at each stage. There is a good logic to maintaining a clear \nseparation between these two regimes.\nPlanning has an extremely important role to play in reducing carbon emissions and tackling the climate \nemergency but it should seek to achieve this through policies which direct and ‘plan’ for development in a \nsustainable manner; it should not seek to stray into territory which is better achieved through nationally \nprescribed Building Regulations.\n According to Government published statistics from 2021, the largest contributor to greenhouse gas emissions \nin the UK is transport. Indeed, the movement of people and goods accounts for approximately 26% of \nemissions, considerably more than residential emissions which account for 16%1\n. The plan-making process \ntherefore has an extremely important role to play in addressing the climate emergency without stepping into \nand duplicating policy areas which are better addressed at a later stage of the development process. \n4.10. Second, the Government has strategic (i.e. beyond local authority level) concerns over the capacity of the \ncurrent grid to accommodate additional local energy infrastructure and the availability of supply chains to \nmeet the need for new building technologies that are required to achieve tightening standards. Aligning the \ntimescales with Building Regulations will allow for investment in the grid to take place which would alleviate \nthis concern.\n Third, it is important to consider the policy in the context of the changing national requirements emerging \nthrough Buildings Regulations. Around the time the Local Plan Review is expected to be adopted in 2025, \nnew, more stringent, Building Regulations will be in place. This will require all new homes to achieve the \nFuture Homes Standard and be net zero ready. Then in 2030, the Government is committed to having  decarbonised the grid. Less than 3-4 years into the plan period, the new homes built to Building Regulations \nwould therefore be net neutral irrespective of the local plan policies. \n This draws into question whether there is any merit in including a policy in the SLP or instead relying upon \nBuilding Regulations. For the reasons set out above, our clients consider that the SLP should focus on \nensuring development is directed towards sustainable locations (a matter covered in more detail elsewhere \nin our representations) and leave the Building Regulations regime to control the detailed standards for \nbuilding fabric and energy generation. Such an approach would be entirely consistent with the Government’s \nexpectation for the plan-making process","Whether development should seek to retain and reuse existing buildings as opposed to demolish and \nredevelop can be a legitimate planning consideration. In circumstances where the reuse and redevelopment \nof an existing building is feasible, careful consideration is required by the applicant and local authority to \ndetermine whether retention would be desirable. There are a number of planning considerations which feed \ninto such a decision, including but not exclusively the feasibility of reuse, viability, desirability and any design \nor quality compromises which would be required. A further consideration which we assume to be the reason \nfor this question is the effect on carbon emissions. \nWhilst the carbon impact of alternative scenarios is important, it is only one of a number of relevant planning \nconsiderations to be considered in the balance when preparing and determining a planning application. \nWhere there is an existing building which may feasibly be reused as opposed to redeveloped then we can \nsee merit in providing an embodied carbon assessment to inform a balanced planning judgement. Such an \nassessment should however only be required where such an option is deemed to be feasible.","No","","","Approximately one quarter of carbon emissions in the UK are generated by transport movements. Reducing \nthe need to travel and encouraging sustainable and active modes over the private car is one of, if not the, \nmost important contributions that the planning system can make to addressing climate change. Allocating \nland for residential development which is either well located to existing frequently used infrastructure such \nas a convenience shop, primary school etc or which will deliver such facilities as part of a mixed-use \ndevelopment, is crucial to the achievement of sustainable development.\nIn other words, and in direct response to this question, it is the key services and facilities which are most \nfrequently used by households and which households are most likely to travel to by sustainable and active \ntravel modes which are the most important to be provided within easy reach of developments","","","No","The framework clearly requires at paragraph 61 the use of the standard method to establish the minimum \nhousing requirement for local plans. Whilst it also acknowledges that there may be circumstances where an \nalternative starting point is deemed appropriate, such circumstances must be \"exceptional\". Footnote 25 of \nthe Framework provides the only example of an exceptional circumstance – that of an island with an elderly\npopulation and no land bridge to the mainland UK - which would warrant deviation from the Standard Method. \nAs this example ably demonstrates, to pass the \"exceptional circumstances\" test, requires a set of conditions \nwhich are genuinely exceptional.\nNo such circumstances are present within the Gloucester, Cheltenham and Tewkesbury area and there is \ntherefore no Framework-compliant justification to depart from the Standard Method as the starting point for \nthe housing requirement. The starting point is sometimes referred to as the ‘policy off’ level of housing need \nas it represents the baseline before the effect of other local policies and priorities are taken into consideration","","As the staged presentation of the questions suggests, the next step in establishing the housing requirement \nis to establish whether any ‘policy on’ justification exists to either increase or decrease the ‘Policy-off’ \nStandard Method starting point.\nWhilst there are environmental and policy constraints which apply to land within the plan area (such as \nNational Landscapes and Green Belt respectively), these do not justify a reduction in the Standard Method \nrequirement for the SLP. Indeed, there is a significant amount of land available which is not constrained and \nwhich can collectively deliver the Standard Method output. It is for the authorities to establish whether an increase to the standard method is justified by policy objectives \nsuch as economic growth or the delivery of affordable housing. This is a matter which will need to be \nconsidered in detail in order to inform the next consultation stage of the SLP.\nNotwithstanding the strategic housing requirement, we urge the authorities to apply a degree of flexibility in \nthe supply of land through allocations within the SLP. All three authority areas have struggled to maintain a \nsufficient housing land supply since the adoption of the JCS. This has resulted in the submission of numerous \nplanning applications on land not allocated for development with many of these being subsequently approved \nat appeal. Rather than planning for the precise housing requirement and no more, in order to guard against \nsuch a circumstance happening again in the future, flexibility should be incorporated into the housing \nrequirement of the SLP to act as a buffer and ensure that delivery matches, as a minimum, the identified \nneeds.\nThere is no nationally prescribed buffer nor guidance on what may be appropriate. However, based upon the \nshortfalls that have accumulated within the three authority areas and the significance of the housing need, a \n15-20% buffer is in our view justified.","","The evidence which explains the housing needs mix is contained in the Strategic Housing Market \nAssessment (SHMA). In the formulation of policy, it is important however to acknowledge the difference \nbetween an assessment of housing need, such as that in the SHMA, and the demand for housing. \n There is no legitimate means of controlling the occupation rates of open market housing within the UK and \nwhilst many households may only 'need' a small number of bedrooms, they may nevertheless choose to \noccupy a larger home. A SHMA with a methodology that is predicated on an analysis of population and \ndemographic change might advise on the needs of the emerging demographic trends but it will not have \nregard to housing demand. As a consequence, the outputs from such an assessment must be treated with \nconsiderable caution and assumed to represent the minimum size breakdown of properties across the SLP \narea. \nFurthermore, in the absence of an assessment of housing demand, the authorities should avoid placing \nundue weight upon the output of the SHMA in the formulation of policy. Rather, the mix of housing within the \nopen market component of a development should reflect both need and demand alongside other \nconsiderations such as local character, density etc. We therefore advocate a flexible policy approach which \nallows for this matter to be determined by an applicant and justification provided as part of the planning \napplication submission.","No","It is sometimes seen as an easy option to include a component of traveller community accommodation within \nthe policy requirements for a strategic site, however, it is not necessarily the case that such locations are \neither suitable or desirable to the traveller community. As is the case for all policy requirements, there must \nbe clear evidence that the selected allocations are suited to the needs of the traveller community and \ntherefore deliverable. The authorities must therefore work with the traveller communities to understand their \nneeds and how best these can be an accommodated in the first instance","","","","","","","The question of the infrastructure required alongside new development is an important one but impossible to \nanswer in a generic sense across the SLP area as a whole. The individual circumstances of each selected \ndevelopment location need to be carefully considered alongside the impact that development will have on \nexisting local infrastructure and whether there is a localised deficit or surplus.\nTake for example open space provision. If there is a sufficient number of playing pitches within the locality of \na development to meet the needs arising from a new development then it would be incompatible with Clause \n122 of the Community Infrastructure Regulations and therefore unlawful to seek land or a financial contributions towards the provision of further pitches. The same principle is true of all community infrastructure designed to support the needs of a growing population.\n We therefore recommend that an infrastructure delivery plan for each of the selected strategic development \nlocations is prepared to inform the preferred spatial strategy and strategic site selection, and that this is \nconsulted upon as part of plan preparation.\nNotwithstanding the above, there is just one further topic specific comment we would like to make which \nrelates equally to all strategic development options. For most forms of infrastructure the planning system is \ndesigned to assess the needs of the development and to incorporate sufficient mitigation such that these \nneeds will be met without impacting negatively upon existing circumstances. The example provided above \nregarding playing pitches is such an example. A different approach however is required for transport. \nThe joint authorities have established challenging aspirations to address and mitigate the effects of climate \nchange. This will be impossible to achieve if, when considering development proposals, the authorities insist \nupon the construction of new roads and junction improvement works designed to alleviate the impact of \nadditional vehicles on the highway network. Rather than investing in new tarmac, we strongly recommend \nthat the authorities put in place a policy framework which instead directs investment to enhance sustainable \nand active travel opportunities. It is only by mitigating the impacts of development in this way that there will \nbe both a disincentive for people to drive and an incentive for people to use alternative modes of travel","","","","No","The six development scenarios outlined in Section 6 of the consultation document in our view provide a comprehensive range of broad alternative spatial strategy options. There are no further alternative development scenarios which it is therefore necessary to test.","","","Scenario 4: New strategic settlement;","","","[Q1.] The National Planning Policy Framework (the ‘Framework’) states at paragraph 22 that a local plan should look ahead for at least 15 years from the point of adoption. This represents the absolute minimum considered acceptable by Government and a plan period which would therefore be deemed consistent with national  planning policy in the Framework and therefore sound.  \nThere are however good planning reasons to look at a time horizon beyond 15 years. Meeting the housing and employment needs of the Gloucester, Cheltenham and Tewkesbury area will require significant \ninvestment in infrastructure. This scale and nature of the investment requires coordination across a variety of both public and private sector organisations and the alignment of funding regimes which can collectively \ndeliver the infrastructure. This inevitably takes a long period of time to resolve and, the longer the plan period, the more time there is available to plan for long-term growth needs. For this reason, we urge the joint  authorities to plan for growth over a 20 year period post adoption of the SLP.\"\n\n\n\nWe welcome the opportunity to comment upon the Issues and Options consultation: Spatial Options and Key \nPolicy Areas document published as part of the preparation for the Cheltenham, Gloucester and Tewkesbury \nStrategic and Local Plan (SLP).\n The consultation document is well written, accessible and contains the right level of detail for a first stage \nRegulation 18 document. Within our response we have addressed directly the questions which have been \nposed within the consultation document. Subsequent to the submission, we would welcome the opportunity \nto further engage with the joint authorities and to assist in informing the next stage in the preparation of the \nSLP.\n[Q8}  The Government’s intention behind the statutory requirement for a Biodiversity Net Gain (BNG) is to ensure \nthat development leaves the environment in a better state than it was before the development took place. \nThe 10% minimum within the Environment Act is an arbitrary figure but one which will provide a transparent \nbasis upon which to determine planning application proposals with a view to achieving the over-arching \nobjective. To set a higher level than this in the SLP would be to establish an alternative arbitrary threshold \nfor which there is no justification or evidential basis. Notwithstanding, there are further reasons why such \npolicy approach would be both unsound and undesirable.\n[Q29] VSM and the DIO only wish to comment upon one of the spatial scenarios - Scenario Four – New Strategic \nSettlement.\n Three potential new settlement opportunities have been identified within development scenario four – one of \nwhich is the Tewkesbury Garden Communities. VSM and the DIO are promoting the development of a \nrelatively small component part of the Garden Communities incorporating the redundant eastern extent of \nthe MOD Ashchurch base. This land falls within the Ashchurch settlement boundary and it’s redevelopment \nis therefore consistent with the adopted planning policy, nevertheless VSM and the DIO are working with \nTewkesbury Borough Council and other parties in the Garden Communities area to ensure a coherent and \ncoordinated approach to development within the area.\nNeedless to say, VSM and DIO support the principle of the Garden Community in the general location shown \non the plan accompanying Scenario Four of the SLP. The land under their control / ownership is available \nfor development now and capable of phased delivery during the SLP plan period. VSM and the DIO would \ntherefore endorse the Tewkesbury Garden Community forming part of the spatial strategy for the SLP.\nThe Government has recently updated the BNG section2 of the Planning Practice Guidance (PPG) to include \nthe following:\n“Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity \nnet gain, either on an area-wide basis or for specific allocations for development unless justified. \nTo justify such policies they will need to be evidenced including as to local need for a higher \npercentage, local opportunities for a higher percentage and any impacts on viability for \ndevelopment. Consideration will also need to be given to how the policy will be implemented.”\nThe intention of Government is quite clear and we are aware of no justification to deviate from this within the \nSLP.\nThere are also practical reasons why exceeding 10% BNG would be undesirable. As explained in the \nconsultation document and through our representations, one of, if not the most important roles of the SLP is \nto direct development to the most sustainable locations. A policy approach which required greater than 10% \nBNG would inevitably reduce the gross density of development and result in the inefficient and ineffective \nuse of the most sustainably located sites within the SLP area. If a higher BNG target was imposed, a greater \noverall area of land, potentially including less suitable and/or sustainable locations, would therefore need to \nbe allocated for development in order to meet the growth needs of the SLP. \nFor these reasons, we recommend that the authorities rely upon the BNG provisions within the Environment \nAct and not to go beyond these within the SLP. Furthermore, in order to avoid unnecessary duplication and \nthe potential for confusion it is recommended that the authorities avoid the temptation to include a policy on \nBNG within the SLP. We appreciate that authorities are committed to tackling the nature emergency but \npolicy which duplicates the statutory requirements of the Environment Act will have no practical effect but \nwould cause an unnecessary duplication of procedural requirements.\n2 Paragraph: 006 Reference ID: 74-006-20240214"]
["Planning agent or developer","Vinci St. Modwen and the Defence Infrastructure Organisation ",20,"","","","","","The draft strategic objectives are, in the main, supported. Indeed, we entirely agree with objectives such as the needs to ensure growth takes place in sustainable locations that minimise the need to travel. We will come back to this later in our commentary on the development scenarios. The only other comment on the strategic objectives is the level of detail. In some cases the detail appears to be out of context for a strategic objective and, in places, even for a local plan. For example, objective eight under the meeting the challenges of climate change heading states that:\n“Ensure people can make carbon friendly choices at home by providing easy to use cycle storage, covered space to dry washing outside, space to grow food and compost.”\nThe matters covered in this objective are not 'strategic' in nature but are matters of detail which in many ways extend beyond the remit of the SLP and would be better suited to SPD. This level of detail has led to a list of draft strategic objectives which are too lengthy and not strategic in their application. We therefore recommend that the authorities revisit the draft strategic objectives and to elevate the level of detail such that the objectives can be applied more broadly to the development of the subsequent policy details.","We consider that the most important of these for the SLP and the most impactful is the allocation of land in the most accessible and sustainable locations. Doing so is clearly consistent with national planning policy and Section 39(2) requirement of the Planning and Compulsory Purchase Act 2004 which requires plan-making bodies to:\n“exercise the function with the objective of contributing to the achievement of sustainable development.”\nIt is the location and broad form of development with which the SLP should concern itself rather than building design and engineering which is more appropriately dealt with under the Building Regulations. For the reasons explained in our response to question 7(a), the SLP should focus exclusively on planning considerations and not matters which are covered by other regulatory regimes.","Whilst we recognise that there may be a desire to establish ambitious targets for future development, for the reasons explained below, we do not consider that such an approach would be consistent with national policy and therefore sound.\nOn 13 December 2023 there was a Written Ministerial Statement (WMS) by the Minister of State for Housing, Lee Rowley, which relates to the construction and operation of new buildings and which is it therefore directly relevant to this question. The WMS includes a number of statements which are pertinent to the soundness of a draft policy:\n“The improvement in standards already in force, alongside the ones which are due in 2025, demonstrates the Government’s commitment to ensuring new properties have a much lower impact on the environment in the future. In this context, the Government does not expect plan-makers to set local energy efficiency standards for buildings that go beyond current or planned buildings regulations.\nAny planning policies that propose local energy efficiency standards for buildings that go beyond current or planned buildings regulation should be rejected at examination if they do not have a well-reasoned and robustly costed rationale that ensures:\nThat development remains viable, and the impact on housing supply and affordability is considered in accordance with the National Planning Policy Framework.\nThe additional requirement is expressed as a percentage uplift of a dwelling’s Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP).\nWhere plan policies go beyond current or planned building regulations, those polices should be applied flexibly to decisions on planning applications and appeals where the applicant can demonstrate that meeting the higher standards is not technically feasible, in relation to the availability of appropriate local energy infrastructure (for example adequate existing and planned grid connections) and access to adequate supply chains.\nTo be sound, local plans must be consistent with national policy – enabling the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework and other statements of national planning policy, including this one”. [emphasis added]\nIt is clear from the WMS that the Government considers the Building Regulations to be the preferred and primary mechanism to deliver improvements in energy efficiency and reduce the carbon emissions from development. There are a number of reasons why such an approach is supported and considered to be appropriate and sound.First, there is a logical cut off point between the two statutory regimes which it is helpful to keep separate. Planning is concerned with matters such as the location, form and design of new development, and Building Regulations controls matters of detailed design and construction such as building fabric, fire safety, access etc. These two statutory regimes are both equally important but have necessarily separate application and approval processes which reflect the stage at which they are applied to development and the knowledge of building form and fabric which is available at each stage. There is a good logic to maintaining a clear separation between these two regimes.\nPlanning has an extremely important role to play in reducing carbon emissions and tackling the climate emergency but it should seek to achieve this through policies which direct and ‘plan’ for development in a sustainable manner; it should not seek to stray into territory which is better achieved through nationally prescribed Building Regulations.\nAccording to Government published statistics from 2021, the largest contributor to greenhouse gas emissions in the UK is transport. Indeed, the movement of people and goods accounts for approximately 26% of emissions, considerably more than residential emissions which account for 16%2. The plan-making process therefore has an extremely important role to play in addressing the climate emergency without stepping into and duplicating policy areas which are better addressed at a later stage of the development process.\nSecond, the Government has strategic (i.e. beyond local authority level) concerns over the capacity of the current grid to accommodate additional local energy infrastructure and the availability of supply chains to meet the need for new building technologies that are required to achieve tightening standards. Aligning the timescales with Building Regulations will allow for investment in the grid to take place which would alleviate this concern.\nThird, it is important to consider the policy in the context of the changing national requirements emerging through Buildings Regulations. Around the time the Local Plan Review is expected to be adopted in 2025, new, more stringent, Building Regulations will be in place. This will require all new homes to achieve the Future Homes Standard and be net zero ready. Then in 2030, the Government is committed to having decarbonised the grid. Less than 3-4 years into the plan period, the new homes built to Building Regulations would therefore be net neutral irrespective of the local plan policies.\nThis draws into question whether there is any merit in including a policy in the SLP or instead relying upon Building Regulations. For the reasons set out above, our clients consider that the SLP should focus on ensuring development is directed towards sustainable locations (a matter covered in more detail elsewhere in our representations) and leave the Building Regulations regime to control the detailed standards for building fabric and energy generation. Such an approach would be entirely consistent with the Government’s expectation for the plan-making process.","Whether development should seek to retain and reuse existing buildings as opposed to demolish and redevelop can be a legitimate planning consideration. In circumstances where the reuse and redevelopment of an existing building is feasible, careful consideration is required by the applicant and local authority to determine whether retention would be desirable. There are a number of planning considerations which feed into such a decision, including but not exclusively the feasibility of reuse, viability, desirability and any design or quality compromises which would be required. A further consideration which we assume to be the reason for this question is the effect on carbon emissions.\nWhilst the carbon impact of alternative scenarios is important, it is only one of a number of relevant planning considerations to be considered in the balance when preparing and determining a planning application. Where there is an existing building which may feasibly be reused as opposed to redeveloped then we can see merit in providing an embodied carbon assessment to inform a balanced planning judgement. Such an assessment should however only be required where such an option is deemed to be feasible.","No","","","Approximately one quarter of carbon emissions in the UK are generated by transport movements. Reducing the need to travel and encouraging sustainable and active modes over the private car is one of, if not the, most important contributions that the planning system can make to addressing climate change. Allocating land for residential development which is either well located to existing frequently used infrastructure such as a convenience shop, primary school etc or which will deliver such facilities as part of a mixed-use development, is crucial to the achievement of sustainable development.\nIn other words, and in direct response to this question, it is the key services and facilities which are most frequently used by households and which households are most likely to travel to by sustainable and active travel modes which are the most important to be provided within easy reach of developments.","","","","The framework clearly requires at paragraph 61 the use of the standard method to establish the minimum housing requirement for local plans. Whilst it also acknowledges that there may be circumstances where an alternative starting point is deemed appropriate, such circumstances must be \"exceptional\". Footnote 25 of the Framework provides the only example of an exceptional circumstance – that of an island with an elderly population and no land bridge to the mainland UK - which would warrant deviation from the Standard Method. As this example ably demonstrates, to pass the \"exceptional circumstances\" test, requires a set of conditions which are genuinely exceptional.\nNo such circumstances are present within the Gloucester, Cheltenham and Tewkesbury area and there is therefore no Framework-compliant justification to depart from the Standard Method as the starting point for the housing requirement. The starting point is sometimes referred to as the ‘policy off’ level of housing need as it represents the baseline before the effect of other local policies and priorities are taken into consideration.","","As the staged presentation of the questions suggests, the next step in establishing the housing requirement is to establish whether any ‘policy on’ justification exists to either increase or decrease the ‘Policy off’, Standard Method starting point.\n5.4. Whilst there are environmental and policy constraints which apply to land within the plan area (such as National Landscapes and Green Belt respectively), these do not justify a reduction in the Standard Method requirement for the SLP. Indeed, there is a significant amount of land available which is not constrained and which can collectively deliver the Standard Method output. is for the authorities to establish whether an increase to the standard method is justified by policy objectives such as economic growth or the delivery of affordable housing. This is a matter which will need to be considered in detail in order to inform the next consultation stage of the SLP.\n5.6. Notwithstanding the strategic housing requirement, we urge the authorities to apply a degree of flexibility in the supply of land through allocations within the SLP. All three authority areas have struggled to maintain a sufficient housing land supply since the adoption of the JCS. This has resulted in the submission of numerous planning applications on land not allocated for development with many of these being subsequently approved at appeal. Rather than planning for the precise housing requirement and no more, in order to guard against such a circumstance happening again in the future, flexibility should be incorporated into the housing requirement of the SLP to act as a buffer and ensure that delivery matches, as a minimum, the identified needs.\n5.7. There is no nationally prescribed buffer nor guidance on what may be appropriate. However, based upon the shortfalls that have accumulated within the three authority areas and the significance of the housing need, a 15-20% buffer is in our view justified.","","The evidence which explains the housing needs mix is contained in the Strategic Housing Market Assessment (SHMA). In the formulation of policy, it is important however to acknowledge the difference between an assessment of housing need, such as that in the SHMA, and the demand for housing.\n5.9. There is no legitimate means of controlling the occupation rates of open market housing within the UK and whilst many households may only 'need' a small number of bedrooms, they may nevertheless choose to occupy a larger home. A SHMA with a methodology that is predicated on an analysis of population and demographic change might advise on the needs of the emerging demographic trends but it will not have regard to housing demand. As a consequence, the outputs from such an assessment must be treated with considerable caution and assumed to represent the minimum size breakdown of properties across the SLP area.Furthermore, in the absence of an assessment of housing demand, the authorities should avoid placing undue weight upon the output of the SHMA in the formulation of policy. Rather, the mix of housing within the open market component of a development should reflect both need and demand alongside other considerations such as local character, density etc. We therefore advocate a flexible policy approach which allows for this matter to be determined by an applicant and justification provided as part of the planning application submission.","","It is sometimes seen as an easy option to include a component of traveller community accommodation within the policy requirements for a strategic site, however, it is not necessarily the case that such locations are either suitable or desirable to the traveller community. As is the case for all policy requirements, there must be clear evidence that the selected allocations are suited to the needs of the traveller community and therefore deliverable. The authorities must therefore work with the traveller communities to understand their needs and how best these can be an accommodated in the first instance.","","","","","","","The question of the infrastructure required alongside new development is an important one but impossible to answer in a generic sense across the SLP area as a whole. The individual circumstances of each selected development location need to be carefully considered alongside the impact that development will have on existing local infrastructure and whether there is a localised deficit or surplus.\nTake for example open space provision. If there is a sufficient number of playing pitches within the locality of a development to meet the needs arising from a new development then it would be incompatible with Clause 122 of the Community Infrastructure Regulations and therefore unlawful to seek land or a financial contributions towards the provision of further pitches. The same principle is true of all community infrastructure designed to support the needs of a growing population.\nWe therefore recommend that an infrastructure delivery plan for each of the selected strategic development locations is prepared to inform the preferred spatial strategy and strategic site selection, and that this is consulted upon as part of plan preparation.\nNotwithstanding the above, there is just one further topic specific comment we would like to make which relates equally to all strategic development options. For most forms of infrastructure the planning system is designed to assess the needs of the development and to incorporate sufficient mitigation such that these needs will be met without impacting negatively upon existing circumstances. The example provided above regarding playing pitches is such an example. A different approach however is required for transport.\nThe joint authorities have established challenging aspirations to address and mitigate the effects of climate change. This will be impossible to achieve if, when considering development proposals, the authorities insist upon the construction of new roads and junction improvement works designed to alleviate the impact of additional vehicles on the highway network. Rather than investing in new tarmac, we strongly recommend that the authorities put in place a policy framework which instead directs investment to enhance sustainable and active travel opportunities. It is only by mitigating the impacts of development in this way that there will be both a disincentive for people to drive and an incentive for people to use alternative modes of travel.","","","","","The six development scenarios outlined in Section 6 of the consultation document in our view provide a comprehensive range of broad alternative spatial strategy options. There are no further alternative development scenarios which it is therefore necessary to test. As explained in relation to each of these within the consultation document, there are pros and cons associated with each scenario and it is inevitable that the ultimate preferred spatial strategy will be a hybrid which, to a greater or lesser degree, combines aspects of each of the alternatives tested. It is with this context in mind that we have commented upon the development scenarios in response to Question 29.","","The pros and cons presented in relation to each of the development scenario provide a helpful starting point and context for those wishing to comment upon the consultation document. As we will explain in our response to Question 29 however, the weight that we consider should be attributed to the pros and cons varies.\nThis is true not only in so far as the testing of the alternative scenarios is concerned but also in the locations that have been tested within each of the six scenarios. In other words, some of the broad locations where development is proposed will contribute to the pros and cons to a greater or lesser extent. We expand upon this at the end of our response to the next question.","Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","","",{"$cut":{"chars":26946,"head":"The only further comment to make by way of introduction is in relation to the timescales for the plan–preparation process. The Gloucester, Cheltenham and Tewkesbury Joint Core Strategy was adopted in 2017. Following her examination of the submission draft, the Inspector concluded that the JCS was sound but urged the authorities to nevertheless progress an early review in order to address the circumstances which had arisen during the examination process. The primary purpose of the review is to ensure a sufficient housing land supply is available to meet housing needs across the three authority areas. Whilst the JCS established a number of strategic allocations and therefore increased the supply of available land, it has not delivered the quantum of new homes needed at the pace anticipated. As a consequence, there has, over the past few years, been a housing land supply shortfall within each of the three authority areas. This has had a significant bearing upon the affordability of housing - a cause for concern acknowledged in the first bullet point on page 2 of the consultation document.\nThere is therefore an urgent need to address this shortfall and the sooner the planned level of supply can be increased, the sooner the land supply shortfall will be eliminated.\nWe therefore urge the authorities to accelerate the SLP process and press ahead of the timescales currently envisaged in the adopted local development scheme. We appreciate that this would not be straightforward and that there is a considerable amount of work required but the progression of the SLP is of paramount importance to the sustainable growth of the authority areas and if swifter progress can be made there are huge benefits to doing so.\n\n[Q8] The Government’s intention behind the statutory requirement for a Biodiversity Net Gain (BNG) is to ensure that development leaves the environment in a better state than it was before the development took place. The 10% minimum within the Environment Act is an arbitrary figure but one which will provide a transparent basis upon which to determine planning application proposals with a view to achieving the over-arching objective. To set a higher level than this in the SLP would be to establish an alternative arbitrary threshold for which there is no justification or evidential basis. Notwithstanding, there are further reasons why such policy approach would be both unsound and undesirable.\nThe Government has recently updated the BNG section3 of the Planning Practice Guidance (PPG) to include the following:\n“Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.”\nThe intention of Government is quite clear and we are aware of no justification to deviate from this within the SLP.\nThere are also practical reasons why exceeding 10% BNG would be undesirable. As explained in the consultation document and through our representations, one of, if not the most important roles of the SLP is to direct development to the most sustainable locations. A policy approach which required greater than 10% BNG would inevitably reduce the gross density of development and result in the inefficient and ineffective use of the most sustainably located sites within the SLP area. If a higher BNG target was imposed, a greater overall area of land, potentially including less suitable and/or sustainable locations, would therefore need to be allocated for development in order to meet the growth needs of the SLP.\nFor these reasons, we recommend that the authorities rely upon the BNG provisions within the Environment Act and not go beyond these within the SLP. Furthermore, in order to avoid unnecessary duplication and the potential for confusi"}}]
["","M Planning ","","","","No","The Draft Vision set out within the SLP sets out at its third paragraph that:\n“People’s housing needs will have been met through the provision of\nsustainable, high-quality market, affordable and other specialist homes set in\nbeautiful, safe places and conforming to sustainable standards of design and\nconstruction. The focus will have been on making best possible use of\nbrownfield sites in built up areas and large-scale, comprehensively planned\nnew development to ensure our valuable green spaces and highest quality\nfarmland are preserved”.\nThe following paragraph goes on to state that “Growth in sustainable locations will\nhave enabled the provision of healthy, accessible and walkable neighbourhoods”.\nWhilst we fully agree with the thrust of the above, we are concerned that the Draft\nVision, while highlighting the benefits of brownfield development, does not refer to the\nneed to consider the well managed release of parts of the Green Belt to deliver requisite\nhousing and jobs.\nIt is made entirely clear in Section 6 of the Draft SLP (Planning for Sustainable\nDevelopment – see our comments at Section 6 of this Report) that the identified\ndevelopment scenarios which do not necessitate development on Green Belt land (i.e.\nScenarios 1, 3 and 5) would fail to provide for the full amount of new homes and jobs\nneeded, “resulting in worsening housing affordability, and constrained economic\ngrowth”.\nIn light of this, we consider that there is a critical failure of the Draft Vision to\nacknowledge that well planned Green Belt release is necessary to be remiss. This is\nparticularly emphasised by the fact that the JCS Development Startegy is dependent\non Green Belt release. We would therefore recommend that additional wording is\nincluded within the fourth paragraph of the Draft Vision to link growth in sustainable\nlocations to the release of Green Belt land, where further assessment work deems this\nto be appropriate.","","The Draft Strategic Objectives identified within the draft JCS include the following\nunder the objective of meeting the challenges of climate change:\n“Ensuring growth takes place in sustainable locations that minimise the need\nto travel and provide genuinely sustainable transport and active travel options.\nMaking the most effective use of previously developed land, including higher\ndensity development in city and town centres and other locations well served\nby public transport.\nEnsure development effectively integrates with existing development, and / or\nis a self-contained development that provides shops, services, facilities through\nwalking, cycling or public transport”.\nThe locational Strategic Objectives set out above clearly place an emphasis on\naccessibility when making decisions about locations for housing development. Our\nanalysis leads to the conclusion that this is not just a question about existing\ninfrastructure but also new infrastructure and how development can better integrate\nthe existing urban area together.\nThis leads to our recommendation that reference is made within the Draft Startegic\nObjectives under the banner of meeting the challenges of climate change to the\ncarefully considered release of Green Belt land, given that some element of this\napproach is likely to be required.\nUnder the objective of delivering a wide choice of homes that meet the needs of our\ncommunities, the points identified include:\n“Delivering sufficient new homes in the right places to meet the needs of our\ncommunities, including market and affordable, specialist homes (e.g. older\npersons), Gypsys, Travellers and Travelling Showpeople and those wishing to\nbuild their own homes (self and custom build homes).\nWe wholly agree with the above and consider this a fundamental objective for the SLP.\nIt is clear from later assessment of the potential development scenarios (Section 6)\nthat in order to deliver on this objective, some form of development on existing Green\nBelt land is likely to be required.\n\nWe have addressed this question in our commentary above, but fundamentally our\nposition is that the Draft Vision and Draft Strategic Objectives must, in order to be\nrealistic and indicative of the likely shape of the development plan as a whole, refer to\nthe need for well managed release of appropriate parts of the Green Belt which offer\nopportunities for sustainable development, tackling previous unsustainable\ndevelopment patterns across the three districts. To this point, we would note that previous development which has taken place with the effect of expanding Bishop’s\nCleeve northwards has been ultimately unsustainable. This is recognised as long ago\nas the SW RPG EiP Panel’s Report. We recommend that the new SLP now takes the\nopportunity to examine opportunities for sustainable development in alternative\nlocations, including on the Hyde Farm site.","","","","No","","","","","","","National policy and guidance are clear that the standard method can be used to\ncalculate a minimum annual local housing need figure, which is an advisory starting\npoint. NPPG states that the standard method identifies a minimum annual housing\nneed figure; it does not produce a housing requirement figure2. It is clearly stated\nwithin the NPPG that there will be circumstances where it is appropriate to consider\nwhether actual housing need is higher than the standard method indicates.\nFurthermore, the Standard Method does not take into account any unmet need from\nneighbouring authorities. It is also the case that the housing need figure generated by\nway of the standard method may change as inputs are variable. Therefore, whilst the\nSLP should use the standard method to calculate local housing need, this should not\nbe simply translated into the housing requirement figure. The final housing\nrequirement figure will evolve over the plan preparation process and should be\ninformed by evidence, including evidence of any unmet need from neighbouring\nauthorities and analysis of affordable housing need. The LHNA then seeks to justify a reduction in this figure by applying affordability criteria\nto identify an effective demand from those able to afford the various products that will\nbe available, despite neither the NPPF nor the NPPG identifying any such affordability\ncriteria to be applied to those households who aspire to own their own home. This\nreduction results in a figure of 19,037 over the 20 year period, equivalent to 30% of\nthe LHN.\nPara 61 of the of the NPPF states “In addition to the local housing need figure, any\nneeds that cannot be met within neighbouring areas should also be taken into account\nin establishing the amount of housing to be planned for”. The Statement of Common\nGround February 2022 is made by SLP Councils and the other Gloucester Councils of\nStroud, Forest of Dean and Cotswolds, as well as GFirst LEP. Agreement 7 states that:\n“The Parties agree that making provision to meet the full range of housing\nneeds in the right places at the right time is a vital role for the Gloucestershire\nauthorities. The parties acknowledge this may result in one local authority\naccommodating the identified needs of another local authority, particularly\nwhere a local authority is unable to accommodate all of the identified need\nand where accommodating need in a neighbouring authority represents the\nmost sustainable form of development.”\nThe housing requirement may therefore need to increase to accommodate unmet need\nfrom neighbouring areas, the extent of which is to be determined through the Duty to\nCooperate.\nThe latest Gloucestershire Local Housing Needs Assessment (“LHNA”) was published\nin 2020 and includes analysis for all Gloucestershire authorities, including Forest of\nDean, Stroud and Cotswold. The LHNA reiterates the above, noting at paragraph 10\nthat “The LHN provides the starting point for establishing the final housing requirement\nwhich will be planned for through strategic policies. In determining the local plan\nhousing target, it will be necessary for the local authorities to consider whether or not\nthe LHN could be met within their area, taking account of any constraints on land\navailability. In particular, it will be important to balance the need for housing against\npolicies intended to restrict development in Areas of Outstanding Natural Beauty and\nany other areas with similar constraints”.\nBoth the Cotswold and Stroud areas are heavily constrained by the Cotswold AONB\nand large areas of Flood Zone 3. It is therefore likely that that there will be significant\nunmet need from these neighbouring areas, which should be planned for as part of the\nSLP.\nThe LHNA goes on to set out an analysis of affordable housing need (“AHN”), noting\nat paragraph 8.65 that “the overall need for affordable housing would comprise a total\nof 44,205 dwellings over the 20-year period 2021-2041, equivalent to an average of\n2,210 dwellings per annum”. This equates to 67% of the LHN.Data published on an annual basis by the Department for Levelling Up, Housing and\nCommunities (“DLUHC”) indicates that average annual affordable housing delivery in\nCheltenham over the past eight years has amounted to only 73 units per year, far\nbelow the estimated need in the SHMA 2015 (231 affordable units per annum)3.\nFurthermore, the number of households on the Council’s waiting list stood at 2,782 in\n2023, the highest figure since 2014 and a higher figure than in 28 of the preceeding\n36 years4.\nAs such it is clear that there are pressing affordability issues and a need to increase\nthe delivery of both market and affordable housing. We therefore strongly recommend\nthat the Councils increase the local housing requirement over that of the LHN\nsufficiently to arrest the trend of worsening affordability and affordable housing need.","Yes","National policy and guidance are clear that the standard method can be used to\ncalculate a minimum annual local housing need figure, which is an advisory starting\npoint. NPPG states that the standard method identifies a minimum annual housing\nneed figure; it does not produce a housing requirement figure2. It is clearly stated\nwithin the NPPG that there will be circumstances where it is appropriate to consider\nwhether actual housing need is higher than the standard method indicates.\nFurthermore, the Standard Method does not take into account any unmet need from\nneighbouring authorities. It is also the case that the housing need figure generated by\nway of the standard method may change as inputs are variable. Therefore, whilst the\nSLP should use the standard method to calculate local housing need, this should not\nbe simply translated into the housing requirement figure. The final housing\nrequirement figure will evolve over the plan preparation process and should be\ninformed by evidence, including evidence of any unmet need from neighbouring\nauthorities and analysis of affordable housing need. The LHNA then seeks to justify a reduction in this figure by applying affordability criteria\nto identify an effective demand from those able to afford the various products that will\nbe available, despite neither the NPPF nor the NPPG identifying any such affordability\ncriteria to be applied to those households who aspire to own their own home. This\nreduction results in a figure of 19,037 over the 20 year period, equivalent to 30% of\nthe LHN.\nPara 61 of the of the NPPF states “In addition to the local housing need figure, any\nneeds that cannot be met within neighbouring areas should also be taken into account\nin establishing the amount of housing to be planned for”. The Statement of Common\nGround February 2022 is made by SLP Councils and the other Gloucester Councils of\nStroud, Forest of Dean and Cotswolds, as well as GFirst LEP. Agreement 7 states that:\n“The Parties agree that making provision to meet the full range of housing\nneeds in the right places at the right time is a vital role for the Gloucestershire\nauthorities. The parties acknowledge this may result in one local authority\naccommodating the identified needs of another local authority, particularly\nwhere a local authority is unable to accommodate all of the identified need\nand where accommodating need in a neighbouring authority represents the\nmost sustainable form of development.”\nThe housing requirement may therefore need to increase to accommodate unmet need\nfrom neighbouring areas, the extent of which is to be determined through the Duty to\nCooperate.\nThe latest Gloucestershire Local Housing Needs Assessment (“LHNA”) was published\nin 2020 and includes analysis for all Gloucestershire authorities, including Forest of\nDean, Stroud and Cotswold. The LHNA reiterates the above, noting at paragraph 10\nthat “The LHN provides the starting point for establishing the final housing requirement\nwhich will be planned for through strategic policies. In determining the local plan\nhousing target, it will be necessary for the local authorities to consider whether or not\nthe LHN could be met within their area, taking account of any constraints on land\navailability. In particular, it will be important to balance the need for housing against\npolicies intended to restrict development in Areas of Outstanding Natural Beauty and\nany other areas with similar constraints”.\nBoth the Cotswold and Stroud areas are heavily constrained by the Cotswold AONB\nand large areas of Flood Zone 3. It is therefore likely that that there will be significant\nunmet need from these neighbouring areas, which should be planned for as part of the\nSLP.\nThe LHNA goes on to set out an analysis of affordable housing need (“AHN”), noting\nat paragraph 8.65 that “the overall need for affordable housing would comprise a total\nof 44,205 dwellings over the 20-year period 2021-2041, equivalent to an average of\n2,210 dwellings per annum”. This equates to 67% of the LHN.Data published on an annual basis by the Department for Levelling Up, Housing and\nCommunities (“DLUHC”) indicates that average annual affordable housing delivery in\nCheltenham over the past eight years has amounted to only 73 units per year, far\nbelow the estimated need in the SHMA 2015 (231 affordable units per annum)3.\nFurthermore, the number of households on the Council’s waiting list stood at 2,782 in\n2023, the highest figure since 2014 and a higher figure than in 28 of the preceeding\n36 years4.\nAs such it is clear that there are pressing affordability issues and a need to increase\nthe delivery of both market and affordable housing. We therefore strongly recommend\nthat the Councils increase the local housing requirement over that of the LHN\nsufficiently to arrest the trend of worsening affordability and affordable housing need. Our only comment in respect of the above is that any use of a figure below that arising\nfrom the standard method would be wholly inappropriate and counterinturitve given\nthe range of policy objectives the LPAs are looking to achieve. As above, we consider\nthat the allocation of Hyde Farm as a development site offers the opportunity to make\nsignificant ccontributions to housing delivery.","","","","","","","In respect of the above, we note that the Hyde Farm site, given its location, offers an\nopportunity for the co-location of residential and industrial accommodation.","","","","Paragraph 5.51 of the draft SLP sets out that “The use of greenfield sites may raise\nviability issues due to the need for new infrastructure, or environmental constraints\nsuch as flood risk which will need to be mitigated. However, brownfield (sometimes\ndescribed as Previously Developed Land) often pose their own viability challenges”.\nWe agree with the broad principles of the above, but note that there is a distinction to\nbe drawn between greenfield sites located some distance from existing urban areas\nand those located adjacent or more proximate – such as Hyde Farm, which, as above,\ncan be considered to benefit from nearby facilities and infrastructure, as discussed\nfurther below.","","","","","","","Scenario 1 – Urban Concentration\nIt is noted that this scenario would not deliver sufficient new homes and jobs, would\nonly provide a limited range of housing types and would likey result in harm to the\nsetting and significance of important heritage assets. Furthermore, as acknowledged\nin para 5.51 of the Consultation Document, brownfield sites present viability challenges,\nwhich in turn would result in a lower rate of affordable housing delivery.\nOn the basis of the above, we do not consider that the above option presents a viable\nscenario for development in the SLP area that will meet LHN or AHN. The existing\ndevelopment strategy as per the adopted JCS relies on the identification of sites for\nurban extensions – i.e. it has also been found and evidenced that there is insufficient\nland within the existing urban areas to meet development demands.\n\nScenario 3 – Urban Extensions, avoiding the Green Belt\nIt is noted that this scenario alone would not deliver sufficient new homes and jobs\nand would only provide for a limited range of housing types, sizes and tenures. Such\nan approach would be wholly inconsistent with NPPF objectives of boosting the supply\nof housing as well as the Draft SLP Vision. Whilst we note the qualification within the\ndraft SLP that none of the scenarios are intended to be brought forward in isolation,\nwe would caution against an approach that places undue weight on the blanket\nprotection of Green Belt land, without careful assessment of the specific context of\npracels of land which may offer appropriate development options enabling a short to\nmedium term response to development needs.\n\nScenario 4 – New Strategic Settlement\nThis option looks at the delivery of development through one or more comprehensive,\nmaster-planned new settlements of a minimum of 4,000 new homes, with supporting\ninfrastructure. It is noted that three potential locations have been identified to date,\nas follows:\n- around Boddington on land to the south of the A4109 between the A38 and M5\ncorridors;\n- straddling the boundary of Tewkesbury Borough and the Forest of Dean between\nChurcham and Highnam in the south west of the SLP area;\n- to the east of the M5 at Ashchurch on the edge of the built-up area of Tewkesbury.\nThe third of these options is known as the Tewkesbury Garden Town, having been\nawarded Garden Town status in 2019. On this basis, work is currently being\nundertaken to develop plans for the site, including proposals for major improvements\nto Junction 9 of the M5.\nIt is noted that while this scenario could reduce the need to build on Green Belt land\n(except at Boddington) and would enable the provision of a wide choice of housing\nsizes, types and tenures, it would also be unlikely to provide for all of the new homes\nand jobs required, “resulting in worsening housing unaffordability and constrained\neconomic growth”. It is also acknowledged that this option would require longer lead\nin times to the delivery of homes and jobs, given the need for a significant amount of\nmasterplanning work and the co-ordination of transport and community infrastructure.\nFor these reasons, we do not support this development option, or this being a leading development option. \nIn our view, the implementation of Scenario 2 would better\ndeliver the objectives of enabling the provision of a high number and wide range of\nhousing, without the costly – both in financial and temporal terms – implications of\nmassive transport and commununity infrastructure.\n\nScenario 4 – New Strategic Settlement\nThis option looks at the delivery of development through one or more comprehensive,\nmaster-planned new settlements of a minimum of 4,000 new homes, with supporting\ninfrastructure. It is noted that three potential locations have been identified to date,\nas follows:\n- around Boddington on land to the south of the A4109 between the A38 and M5\ncorridors;\n- straddling the boundary of Tewkesbury Borough and the Forest of Dean between\nChurcham and Highnam in the south west of the SLP area;\n- to the east of the M5 at Ashchurch on the edge of the built-up area of Tewkesbury.\nThe third of these options is known as the Tewkesbury Garden Town, having been\nawarded Garden Town status in 2019. On this basis, work is currently being\nundertaken to develop plans for the site, including proposals for major improvements\nto Junction 9 of the M5.\nIt is noted that while this scenario could reduce the need to build on Green Belt land\n(except at Boddington) and would enable the provision of a wide choice of housing development option. In our view, the implementation of Scenario 2 would better\ndeliver the objectives of enabling the provision of a high number and wide range of\nhousing, without the costly – both in financial and temporal terms – implications of\nmassive transport and commununity infrastructure.\n\nScenario 5 – Rural Dispersal\nThis scenario looks at the distribution of growth widely across the rural area. It is\nnoted that while this scenario would be likely to safeguard the Green Belt, it would\nlikely harm the character and setting of existing settlements and surrounding\ncountryside and would be unlikely to provide for the full amount of new homes and\njobs needed. We cannot support this as a sole or primary scenario given the already\nidentified negative implications for existing settlements and their inhabitants.","Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","","","[Q1] How far into the future should the Strategic and Local Plan cover? Paragraph 2.8 of the draft SLP states that “the Government requires a plan to cover a period of at least 15 years from the point of adoption. Where the plan includes larger\nsites that will take longer to develop, the vision and policies can look further ahead to at least 30 years”. This is reflective of paragraph 22 of the NPPF.\nWhilst the draft SLP sets out at paragraph 2.10 that “The current timetable for the SLP is for submission to the Secretary of State in April 2026…On this basis, the SLP would\nneed to plan up to at least 2041”, it does not identify a plan period start date. This is an important consideration given the significant period of time across which the area\nwill be without up-to-date strategic policies.\nThe Inspector’s Report relating to the adoption of the JCS notes at paragraph 76 that “Whilst the JCS authorities have sought to meet the full housing requirement for the\nPlan period, it is apparent from the HIS that insufficient sites can be identified at present for Gloucester and Tewkesbury. Overall, against the requirement of 35,175,\nthere is currently a supply of 31,824 dwellings, leaving a shortfall of 3,351. However, there appear to be a number of possibilities for locating additional land and, therefore,\nfocused reviews of Gloucester’s and Tewkesbury’s supply are proposed”.\nParagraph 106 further states that “The unmet needs of Gloucester and Cheltenham, beyond their administrative boundaries, are only to be delivered on identified strategic\nallocations and any other sites with an agreed sharing mechanism through a Memorandum of Agreement. In order to allocate any additional SUEs, a review of the\nPlan would be necessary”.\nIn conclusion, paragraph 112 sets out that “Although the JCS is unable to provide sufficient, deliverable housing at the current time, it appears that there are credible\noptions for identifying additional supply within the Plan period. Accordingly, by giving a policy commitment to undertake early focused reviews of Gloucester’s and\nTewkesbury’s supplies, this part of the Plan is made sound”. Consequently, JCS Policy REV1 states that “A partial review of the housing supply for Gloucester and Tewkesbury\nwill commence immediately upon adoption of the JCS.” An immediate review of the JCS did not and will not occur, given that it is to be replaced by the SLP.\n\nThe draft SLP does not mention the requirement for an immediate review of the JCS within the Introduction and Context chapter, which is a significant omission. The SLP\nmust take into account and plan for the period of time that the area is without an upto-date strategic plan and any shortfall in housing that arises in the interim. Our\nsuggestion is that the plan period should at the latest start in 2022.\nTurning back to the original question of how far in the future the SLP should cover, para 22 of the NPPF states “Where larger scale developments such as new settlements\nor significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years),\nto take into account the likely timescale for delivery.” Therefore to some extent the answer to the question is dependent on the development strategy that is considered\nto be the most appropriate for delivering growth. However, we consider it likely that a development strategy that is able to meet the housing and economic needs of the area\nwill involve a component of larger scale development. We therefore suggest that the SLP should plan for a minimum of 30 years with the precise plan period to be informed\nby the likely timescales for delivery of any strategic allocations.\n\n[Q8]Planning Practice Guidance states:\n“Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for\ndevelopment unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher\npercentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.”\nNo evidence has been provided as part of the consultation that justifies a higher percentage than 10% and we are not aware of any local circumstances that would\njustify such a policy.\n\n[Q29] Scenario 2 – Urban Extensions\nIt is noted that this option would mean “seeking to deliver development as urban extensions to the key urban areas of Cheltenham, Gloucester and Tewkesbury Town,\nand could include sites which fall within the designated Green Belt”. The draft SLP further sets out that “Urban extensions may be one of the most effective ways of\nsupporting high quality public transport infrastructure such as the Mass Rapid Transit scheme proposed in Gloucestershire County Council’s Local Transport Plan”.\nIt is acknowledged that this scenario is likely to result in the loss of some Green Belt land and potentially reducing the gap between Gloucester, Cheltenham and Bishop’s\nCleeve, but also noted that this scenario and the likely range of available sites may enable housing and economic needs to be met in full.\nWe note that the diagram associated with this scenario identifies a larger scale development to the north of Cheltenham, reflecting the location of Hyde Farm.\nMactaggart and Mickel wholly support this development scenario, noting the wide range of potential advantages it affords. Principally, this option allows the delivery of\nsites of a sufficient scale to provide the quantum and range of housing required to tackle housing need and affordability challenges across the SLP area.\nFurthermore, the Gloucestershire SLP Authorities Sustainable Transport Strategy Broad Site Assessment Report, published in December 2023, comprises an assessment of\ndraft HELAA sites for the SLP area againt the range of development scenarios, aligning each to the development scenario with which it is deemed to best fit. The purpose of\nthis assessment is to guage initial disadvatanges and advantages, from a transport perspective, taking four objectives and eight sub-objectives. For the purposes of the\nReport, we understand Hyde Farm to have been aligned with Scenario 2, as per Figure 2-3 (extracted below):\nWhilst we do not intend to set out here full commentary of the Broad Site Assessment insofar as it relates to Hyde Farm, it is clear that the Site performs strongly against\nmany objectives and sub-objectives, including ‘high’ against ‘access to key services, including schools, employment, healthcare and retail within 20-min walk’ and ‘very high’\nagainst ‘access to key services within 20-min cycle’. Critically, development within this location offers a unique opportunity to provide new homes which are already in close\nproximity to jobs, community facilities and retail and leisure services irrespective of where individual homes are located on the site. This is in stark contrast to locations at\nnorth west Cheltenham, where peripheral locations are blighted for poor accessibility to such features.\nIt is noted at Section 4.6.1 of the Report that “A thread of commonality across the assessed HELAA sites and their associated development scenarios is that sites which\nare located either within or adjacent to areas that benefit from from good access to existing sustainable transport networks and services emerge more positively from the\nBroad Site Assessment. Broadly speaking, Urban Concentration and Urban Extensions perform best due to the existing urban areas of Gloucester, Cheltenham and\nTewkesbury which also have a significantly higher frequency and wider offering of health, education, leisure, employment, open space and retail services. They therefore\nprovide the opportunity for these assets to be accessed by sustainable modes”. We fully agree with this, noting that the urban extension option therefore has the abiity to\n[Q29] Scenario 6 – Sustainable Transport Scenario This scenario looks at delivering development in locations along existing and potential\nhigh frequency public transport, walking and cycling routes, specifically high frequency bus routes, Gloucestershire’s cycle spine and the proposed Gloucestershire Mass Rapid\nTransport system. This scenario identifies the delivery of a Sustainable Transport Corridor extending to\nthe north of Cheltenham, with an associated development option. It is noted that this scenario would enable a significant proportion of, or all, housing and employment\nneeds to be met close to where they arise, but that it would also result in the loss of designated Green Belt between Cheltenham, Gloucester and Bishop’s Cleeve, and\npotentially the coalensence of Cheltenham and Gloucester. We note that this scenario identifies a potential development to the north of Cheltenham in the Hyde Farm area.\nIn general terms, Mactaggart and Mickel are supportive of Scenario 6, noting the significant ‘pros’ identified within the draft SLP document. both deliver the range and quantum of housing required, as well as presenting a\nsustainable option in transport and access terms. In our view, the above echoes paragraph 3.2.10 of the JCS, which sets out that “urban extensions are considered to be the most sustainable locations for new development\n(following existing urban areas) as they can share transport, social and service infrastructure with existing urban areas and are located close to essential services”. "]
["Statutory/Specific Consultee","G Frist LEP ",15,"","","No","The draft vision at present is too lengthy and should be designed to be more concise. The vision text should therefore be reduced and the explanation of how the SLP intends to meet the vision contained below the ‘vision statement’.","","The draft strategic objectives should focus primarily on how the districts believe they will get to carbon neutrality with subsequent development design to meet these objectives whilst supporting a strong and vibrant economy.","Climate change objectives should be met with a positive strategy to reduce emissions within the locality. Transport produced 26% of the UK’s total emissions in 2021 and remains the largest emitting sector in the UK. The majority of the emission (91%) from transport came from road vehicles (100MtCO2e) and the biggest contributors to this were cars and taxis. The plan should therefore facilitate a reduction in the need to travel by private car and focused on locations that are or can be made sustainable. Walking, wheeling, cycling and public transport must therefore be the first choice for all who can make it and strategic allocations should be designed to facilitate these modes of transport first. Where developments are located and how they are designed and how well delivery of public transport services are integrated will have a huge impact on people’s mode of travel for short journeys and consequently improve the sustainability of the County.","New buildings should meet carbon neutral targets in operation, with high ambition for the reduction of embodied carbon.","With regard to new and existing building development, the first consideration should be the retention and viable adaptation of existing buildings, and where this is not \nviable, then the construction of sustainable new buildings should be considered.","No","","","It will be important to ensure that all new developments facilitate the reduction in the need to travel by private car and therefore new development should be focused in the  right locations and are served by the right sustainable infrastructure delivered ahead of occupancy of the development. Walking, wheeling and public transport must be the first choice for all who can take it and the appropriate infrastructure to facilitate these forms of transport must be provided at an early stage. The location of new development should focus around existing transport infrastructure where possible.","Yes","The SLP should encourage and remain open to applications for all forms of renewable energy generation and storage. The plan should encourage such initiatives though positively worded policies within the plan but it is not considered that specific allocations would be the appropriate method in which to secure more renewable energy allocations within the County.","Yes","","Yes","The primary constraint that should apply to the SLP area will be the Cotswold National Landscape and the capacity of the motorway junctions on the M5. However, it is considered that there are sufficient areas that are outside of the Cotswold National Landscape to overcome this constraint. Consideration should for future growth to help avoid the erosion of the Cotswold National Landscape should be given to sustainable locations within the Green Belt. National Highways should also be engaged at an early stage to ensure that the M5 motorway junctions have sufficient capacity for any predicted growth and to avoid any delays in the delivery of new growth. ","Yes","The SLP should ensure that they provide inclusive mixed-use development that supports the delivery of more affordable housing.","","","","We believe that the SLP should aim to deliver up to 200ha of new employment land over the plan period to support the economic growth and prosperity of the area, based on past trends and current demand in the region. We support a growth option that helps deliver sufficient land to support continued employment growth in this area as well as provide a variety and choice of sites available to businesses. We therefore believe the plan should take a ‘policy on’ approach to employment land, recognising that strategic business park will take some time in gestation before businesses are actually able to occupy such sites. The proposed 200ha should be spread across use class E(g), B2 General industrial and B8 Storage or distribution. 100-120ha of this land should be used to provide anchor business parks within the SLP area with the residual being provided for other indigenous needs. New business parks should be accompanied with up to 20% ancillary uses to make them more attractive to end users and to provide a more dynamic employment environment. The 200ha should form positive allocations and not represent a notional or aspirational target for the three authorities to achieve. This will provide certainty and economic prosperity for the area.","We believe that the SLP should aim to deliver up to 200ha of new employment land over the plan period to support the economic growth and prosperity of the area, based on past trends and current demand in the region. We support a growth option that helps deliver sufficient land to support continued employment growth in this area as well as provide a variety and choice of sites available to businesses. We therefore believe the plan should take a ‘policy on’ approach to employment land, recognising that strategic business park will take some time in gestation before businesses are actually able to occupy such sites. The proposed 200ha should be spread across use class E(g), B2 General industrial and B8 Storage or distribution. 100-120ha of this land should be used to provide anchor business parks within the SLP area with the residual being provided for other indigenous needs. New business parks should be accompanied with up to 20% ancillary uses to make them more attractive to end users and to provide a more dynamic employment environment. The 200ha should form positive allocations and not represent a notional or aspirational target for the three authorities to achieve. This will provide certainty and economic prosperity for the area.","The SLP should ensure that there are flexible and deliverable planning policies that support the growth of existing rural business parks and sites as well as the re-use of disused and redundant buildings within rural areas for employment, commercial and leisure uses.","The SLP should ensure that there are flexible planning policies that facilitate and encourage the change and adaptation of building and premises within our cities and town centres to ensure that active frontages can be secured on the ground floor of such premises where this is viable and alternative uses are provided elsewhere and on other floors within the buildings. Where a viable use cannot be found for the ground floor, alternative uses including residential should be considered in preference to leaving such buildings empty.","Within villages and rural areas where there are a basic level of shops, services and facilities that already exist, the SLP should encourage limited and sustainable growth within these settlements in order to improve the vitality and viability of these facilities. Planning policies should be devised to help facilitate the growth of these smaller settlements where this is in scale and proportion of the host settlement.","With regard to the climate emergency, it will be important that essential transport infrastructure is made available alongside all new development. New transport infrastructure should ensure that wheeling, cycling and public transport will be the natural first choice for all who can take it to facilitate a reduction in the need to travel by private car. The location and design of new development will help the delivery an integrated multi modal transport system that gives people a choice in the way they travel. New developments should therefore be located where they can maximise existing public transport networks with a particular focus on the rail network within the County. Strategic allocations should then facilitate active travel routes that provide mobility hubs that are anchored around a rail service."," Where new settlements are considered the primary focus for their locations should  be as above (question 23) centred around the County’s rail network with complimentary mobility hubs and active travel routes to facilitate a reduction in the need to travel by car.","Rural settlements of all sizes should be considered for some sustainable and incremental growth where they are able to enhance or maintain the viability of rural communities. Policies should therefore identify opportunities for villages to grow and thrive, especially where this will support local services. Where there are groups of smaller villages, where one village provides services to the others, incremental development in one may help support these shops, services and facilities. Planning policies should reflect and support this. A good example of this, is Policy DS3 of the Cotswold District Local Plan 2011-2031 (August 2018):\nPolicy DS3 - Small Scale Residential Development in Non-Principal Settlements. \n1. In non-Principal Settlements, small-scale residential development will be permitted \nprovided it:\na. demonstrably supports or enhances the vitality of the local community and the \ncontinued availability of services and facilities locally;\nb. is of a proportionate scale and maintains and enhances sustainable patterns of \ndevelopment;\nc. complements the form and character of the settlement; and\nd. does not have an adverse cumulative impact on the settlement having regard to other \ndevelopments permitted during the Local Plan period.\n2. Applicants proposing two or more residential units on sites in non-Principal Settlements should complete a rural housing pro-forma and submit this with the planning application.","","Yes","We do not consider any of the options set out in the consultation document are appropriate individually and we believe that a hybrid approach that embraces elements from all options and is centred around the most sustainable locations should be the preferred option.\nThe primary considerations that the SLP needs to address are the climate emergency and the current housing crisis that is making living in the County less affordable especially to those on lower incomes who need new housing the most. In conjunction with this, the plan needs to positively provide for the areas need for housing, economic and other growth in the most sustainable manner.\nSequentially, strategic growth options should first be focused on the County’s primary transport corridors, with the larger strategic growth options anchored around a new or existing rail service. Such locations have the greatest ability to be designed to reduce the need to travel by private car and through design, will have the ability to create an integrated transport network based around walking, wheeling and cycling as the first priority, with public transport networks complimenting these active travel routes. The majority of the SLPs growth should be centred around this option and this is likely to include the development of new settlement/s in appropriate locations.\nFurther exploiting the existing rail network, it is considered that a sympathetic new neighbourhood could be accommodated between Cheltenham and Gloucester, that has the ability to provide strategic new services for both settlements such as a parkway railway station and a new hospital. This location would also help provide for the most sustainable and accessible employment locations for the area. Whilst the location sits within the Green Belt between the two settlements, it is considered thaton balance, the harm created by the loss of Green Belt is outweighed by the benefits in achieving sustainable new development for the area that has the ability to reduce our carbon emissions and create improved and accessible facilities for bothsettlements whilst allowing the regeneration of existing sites. With appropriate design, the coalescence of the two settlements can be prevented.\nBelow this, the growth strategy should also provide sympathetic new growth around the existing larger towns (Cheltenham, Gloucester, Tewkesbury, Bishops Cleeve, Winchcombe), where the infrastructure has the ability to accommodate this and where this is sympathetic to form and structure of each settlement.\nAll other settlements should be considered for smaller levels of growth, where this has the collective ability to support shops, services and facilities within the immediate area.\nAll of the above should be reviewed in conjunction with a countywide plan led approach. Such a strategic plan could be an evolving template for positive growth and prosperity, sustainable living and working, whilst protecting and enhancing the natural landscape of our county. ","","","","","","[Q1] The National Planning Policy Framework is clear that strategic policies should be  prepared over a minimum 15 year period. The Plan should therefore aim to provide strategic policies and a vision up to 2040, with appropriate reviews every five years to keep the plan up to date.\n\n[Q8] The Plan should have policies that require the minium 10% Biodiversity net gain on all new developments. We do not believe that this should be raised above the Government's target to ensure that new delveopments remain vibale whilst providing biodiversity gains within the County.\n\n[Q12] Housing need is an unconstrained assessment of the number of homes needed in an  area. Assessing housing need is the first step in the process of deciding how many \nhomes need to be planned for. It should be undertaken separately from assessing land  availability, establishing a housing requirement figure first and then preparing policies \nand site allocations. The National Planning Policy Framework expects strategic policymaking authorities to follow the standard. The standard method uses a formula to  identify the minimum number of homes expected to be planned for, in a way which addresses projected household growth and historic under-supply. The standard  method utilises the most recent projections and calculates the projected average annual household growth over a 10 year period. The growth is then adjusted based on  the affordability of the area. This is a national method that will provide consistency in the delivery of housing across the County. Only if there are exceptional circumstances should the SLP deviate from this methodology.\n\n[Q.26] The SLP should ensure that there is sufficient infrastructure to support all new allocations. Of primary importance will be the transport infrastructure as well as ensuring there is sufficient power to each allocation."]
["Other","Gloucester, Cheltenham & Tewkesbury Affordable Housing Partnership",17,"","","No"," The draft vision is largely agreeable, with a few amendments required to reflect the importance of meeting the needs of more vulnerable residents including those with disabilities, or residents who are otherwise disadvantaged by the housing market, building net-zero carbon developments and creating net-zero carbon places and meeting housing needs. From a housing perspective, meeting identified housing needs and addressing  affordability issues, especially for rented homes for households in the greatest need of accommodation, should always be a priority. The draft vision should make \nexplicit reference to meeting ‘identified needs’ for both market & affordable homes across the SLP area. Equally, the vision should reflect that new market homes should meet ‘identified needs’, to reduce the affordability gap between affordable and market housing (which, in turn, places additional pressures on the overburdened private rented sector). The provision of specialist homes should be driven by need, and be reflective of local affordability, rather than being driven by speculative proposals. On this basis, the Draft Vision should reflect that the provision and specification of specialist housing should be agreed in consultation with commissioners. The draft SLP vision should also acknowledge the increasingly important role of the private rented sector in meeting housing needs, with the vision emphasising the \nimportance of expanding the PRS to alleviate pressure on the sector, whilst creating highquality, fit-for-purpose PRS units (which could include Build to Rent or another sub-market rent product that bridges a gap between affordable housing and PRS, but not an expense of affordable housing delivery). Whilst it may ultimately not prove feasible in practice to deliver net-zero carbon places/buildings (of all types) by 2041, the current emphasis on building new \nSLP Reg 18 Consultation- Gloucester, Cheltenham and Tewkesbury AHP Response 3 ‘energy efficient’ homes is wholly insufficient in addressing the Climate Emergency that the SLP authorities are facing, with Tewkesbury and Cheltenham aiming to be net-zero carbon Boroughs and authorities by 2030, compared to Gloucester, which is aiming to be carbon neutral by 2045. Accordingly, this phrasing should be upgraded to reflect the importance of delivering and raising the bar to achieve ‘net-zero carbon’ places, infrastructure and developments to reflect the three SLP authorities respective ‘Housing Emergency’ targets. Where net-zero carbon buildings and developments cannot be achieved by 2041, The SLP should establish a mechanism for ensuring that any shortfall against this requirement is provided through an offsetting fund. This fund should only be used in exceptional circumstances, with the principle and contribution to such a fund being tested through viability. From the perspective of creating sustainable communities, emphasis should be \nplaced upon the objective of creating ‘welcoming’ communities and ‘sustainable neighbourhoods’ that provide easy access to other key population centres through low or zero emission public transport options, including safe and convenient walking and cycling routes. Finally, the ‘highest possibly quality of life for all’ can only be equitably and \nrealistically achieved if housing, infrastructure, transport and public services are designed to meet the needs of our ageing population, with an increasing incidence of households requiring wheelchair accessible and level access homes respectively. The 2020 Local Housing Needs Assessment indicates that an additional 22,388 over 65s will live in the \nSLP area by 2041, representing a 38% increase over the 2021 population demographics. Equally, the number of 85+ residents living in the SLP area is projected to increase by 9,894 individuals by 2041, representing a 102% increase against 2021 population demographics","No","The draft strategic objectives should include specific reference to building accessible and adaptable level access and wheelchair accessible homes covering both market and affordable tenures in accordance with identified needs. The strategic objectives should also include reference to the importance of creating resilient, cohesive communities through seamless, thorough integration of market and affordable tenures on new developments.Emphasis should be placed upon the importance of delivering net-zero developments to align with the three SLP authorities’ respective Climate Emergency Targets. Whilst lowcarbon development may be acceptable and necessary for a duration of the plan period, the SLP authorities should be ambitious and focus on enabling & delivering net-zero \ndevelopments wherever possible, with a view to this becoming the standard approach by the end of the proposed plan period (2041) if not before. Moreover, the framing and phrasing of the strategic objectives with regards to the delivery of ‘zero and low carbon development’ that is ‘resilient and adaptable to climate change’ should be adjusted to recognise the importance that new developments (yet alone existing homes) should be able to withstand extreme weather and climatic conditions, as projected within the latest scientific modelling produced by the UK’s climate change committee (or replacement equivalent expert authority). Finally, the integration of new communities into established areas should consider the ability of existing community resources and amenities to effectively meet the needs of new communities, to prevent the creation of disjointed communities and unnecessary journeys to access shops and community centres. ","All 3 SLP authorities have set out ambitious targets in response to the Climate Emergency, and improving planning policy to support this aim will undoubtedly be a key policy foundation upon which these objectives may be realised. From a housing perspective, introducing specific energy efficiency standards (that exceed the Government’s 2025 Future Homes and Building Standard), with a view to delivering net-zero developments across the SLP plan area, and requiring that on-site energy generation should meet or exceed the consumption requirements for new development represents a critical consideration when planning to mitigate the impact of climate change arising from new housing stock. If it is deemed that securing on-site energy generation is not appropriate through policy, the SLP authorities should aim to secure compliance through conditions. New homes should mitigate the significant anticipated impact arising from flooding and overheating, with increased emphasis on optimising building orientation, ventilation, materials and shading opportunities to alleviate the impact of rising temperatures and extremes in weather and climatic conditions. Whilst accounting for the ‘4 tests’ set out within the National Planning Policy Framework (Paragraphs 35a-d), the SLP should also leverage the planning process to assist with the decarbonization of existing social, market and private rented stock across the SLP area. The case supporting the need to decarbonise existing homes of all tenures across the SLP area is pressing: according to the latest statistics released by the Department for Levelling  Up, Housing and Communities (DLUHC), of the 129,004 properties possessing current EPC certificates across the SLP area, only 38% of these properties met or exceeded EPC C \nstandards (equating to 48,386 properties). Nationally, National Housing Federation research undertaken in October 2021 (predating the War in Ukraine and cost-of-living crisis) indicates that, as a minimum, an additional £36 billion of investment would be required, (in addition \nto existing Government commitments) to ensure that all housing association stock alone meets EPC C standards by 2030. Finally, research undertaken by the Committee for Climate Change has identified that the UK’s buildings are responsible for approximately 17% of the UK’s greenhouse gas emissions. Put simply, achieving net-zero locally or nationally will be unfeasible unless far-reaching, ambitious action is taken to support the decarbonisation of existing stock. In practice, homes falling below EPC C standards are typically more expensive to heat, less \nenergy efficient and more energy intensive, increasingly prone to overheating, damp, condensation and mould and, finally, have disproportionately negative impact on limiting carbon emissions. Nationally, the Government has outlined its aspiration for all housing to meet EPC C standards by 2035, representing a key milestone on its pathway to meeting the Government’s legally binding 2050 net-zero carbon target. In view of the local and national context, it is critical that the SLP also explores policy mechanisms to support the decarbonisation of existing housing stock of all tenures, (primarily focusing on social rented stock, where tenants can least afford to improve their properties). A potential mechanism for achieving this would be to establish a process by which developments make a per-home contribution to support decarbonisation efforts within the relevant SLP area. Alternatively, where new homes fall below net-zero requirements, the SLP could require that these units must make a contribution to the SLP authorities’ Climate Emergency Fund- of which a significant proportion can be ring-fenced to support the decarbonisation of existing stock across all tenures, focusing on the worst-performing stock types and tenures, and those least able to afford to pay for retrofitting. Whilst this should be balanced against overall development viability, it is nevertheless essential that the SLP \nincludes ambitious, fit-for-purpose and future-proofed policies in this area to help tackle the climate emergency, reduce fuel poverty and lower energy bills for SLP residents. The SLP offers a golden opportunity to introduce heat networks on large scale developments, providing low (or no) carbon heating to potentially hundreds or thousands of homes through residual heat usage. Finally, the SLP should raise the bar in terms of the requirements placed upon applicants to monitor, report and reduce their emissions arising from embodied carbon, in line with \nnationally recognised embodied carbon metrics. The Golden Thread running through the SLP should relate to how the SLP will address the \nongoing climate & ecological emergencies. Robust policy and monitoring mechanisms should be established within the SLP to drive forwards progress towards net-zero developments across the SLP area. With regard to new development, this should align new development with net-zero carbon standards in terms of energy efficiency, as well as increasing the stringency of monitoring through embodied carbon requirements, which should be explained in detail by applicants. ","With regard to the development of new residential homes, The SLP should introduce a policy which drives forwards the delivery of net-zero (or, as an absolute minimum at the start of the plan period, then being phased out over time) low carbon homes in line with the SLP authorities climate emergency declarations. In specific terms, any new policy should be underpinned by an energy hierarchy: first ensuring that buildings have a fabric-first energy efficient envelope, followed by the installation of low/net-zero energy generation (Solar PV, Air Source Heat Pumps), and finally, in exceptional circumstances, providing a route to offset any residual emissions up to net-zero (through a ring-fenced Climate Emergency Fund), with a tapered approach being taken to gradually increase the minimum expectations \n(in terms of the level of off-setting allowed via the Climate Emergency Fund) until new development meets net-zero carbon standards. New applications should be required, through policy wording, to meet specific heating demand (less than 15kWh/m2/yr) and heating use (less than 35kWh/m2/yr) targets. Additionally, the SLP should set out requirements for applicants to ensure that energy generated through on-site renewable energy sources (on major developments) exceeds 120kWh/m2. In exceptional circumstances, schemes falling below the aforementioned requirement must be required to contribute to the Council’s Climate Emergency Fund. \nTo support the SLP’s progress towards net-zero carbon development for both market and affordable homes, the construction process of new homes (including the demolition of existing buildings and removal or reuse of materials) should be accompanied by a separate Embodied Carbon statement, applying the RICS Whole Life Carbon Assessment (or latest replacement) to demonstrate the whole-life emissions of new development. This statement should identify the carbon emissions arising from the sustainable sourcing of materials, production process, demolition and disposal of residual material. Ultimately, embodied carbon emissions produced by major applications should not exceed 500kgC02/m2 per year, with an aim to achieve net-zero carbon developments in use. Equally important, the Government’s recent December 2023 Written Ministerial Statement must be given due consideration when constructing new policies concerning energy efficiency of new developments. In practice, whilst this statement makes delivering net-zero homes ahead of the Government’s Building Regulations increasingly difficult- it is not inconceivable to do so. The Government’s WMS is clear that- “the additional requirement is expressed as a percentage uplift of a dwellings Target Emissions Rate (TER) calculated using a specified version of the Standard Assessment Procedure (SAP)”. In this context, the SLP should introduce ambitious standards that align with the SLP authorities’ respective climate commitments, whilst being mindful of potential changes to Government policy. Turning to the operation of new buildings, the SLP should facilitate an ongoing monitoring scheme, in conjunction with developers and key stakeholders, which monitors the yearly emissions produced by new residential developments. Ideally, this should be monitored by developers using a self-assessment checklist, with figures being provided to the local authority to check on a yearly basis for a 5 year period. To sense-check that emissions targets are being met, local authority planning enforcement officers should (on a yearly basis) gather a 10% sample (or other representative sample size) of data relating to emissions produced over the last year. Where developers are found to be non-compliant, the SLP authorities reserve the right to pursue legal enforcement action, if appropriate and proportionate. These figures can then be cross-referenced against the explicit energy \nperformance requirements outlined within the SLP to monitor compliance throughout the plan period.","","","","","","","","Yes","","Yes","Notwithstanding the previous response, it may be appropriate to explore the possibility of seeking a housing requirement above and beyond the result of the Standard Method to maximise the delivery of affordable housing across the SLP area, which should incorporate the impact of turnover of existing affordable housing on the ability of households to secure affordable housing, which, in turn, will impact calculated housing needs. Crucially, this approach can be justified by cross-referencing affordable housing delivery against identified needs over the JCS period. In Cheltenham, for example, 540 affordable \nhomes have been delivered since 2017/18 against an identified need of 1,506 affordable homes over this period. In other words, for every 10 affordable homes required, only 4 have been delivered (rounded). \nDuring the previous JCS examination, the Inspector added an additional 5% to the housing requirement numbers established by the Standard Method, and, given the significant shortfalls in affordable housing delivery via the planning system, it would seem logical to explore the inclusion of a similar calculation within the Strategic & Local Plan, to ensure that affordable housing delivery is maximised.","Yes","The SLP should aim to maximise the delivery of affordable housing delivery, in light of \nhistoric and current chronic shortfalls in affordable housing supply across the SLP area\nagainst a backdrop of accelerating demand and affordability pressures. To illustrate this \npoint, Cheltenham’s identified affordable housing need between 2018/19- 2022/23 stood at \n1,074 dwellings. By comparison, only 374 gross affordable homes were delivered over this \nperiod (35% of overall need)- leaving a shortfall of 707 affordable homes under the existing \nJCS policies. Gloucester City has seen a consistent and significant shortfall of affordable \nhousing delivery against demand, this is especially problematic for 4, 5 and 6 bedroom \nhomes where the delivery of larger rented homes in Gloucester City has been minimal.\nReviewing affordability pressures, the latest data provided by the Office for National \nStatistics indicates that the average income to house price ratio for existing properties in \nCheltenham, Gloucester and Tewkesbury stood at 7.78 (CBC), 7.70 (GCC) and 9.38 (TBC)-\nindicating significant affordability pressures prevailing across the three SLP authorities, even \ndespite short-term turbulence (high inflation, slowing demand) across the residential \nconstruction sector. The picture painted by the Office for National Statistics on average newbuild house prices across the SLP area equally reflects worsening housing affordability for \nresidents on average incomes: with the average income to house price ratio currently \nstanding at 7.78 in Cheltenham, 8.75 in Gloucester and 11.08 in Tewkesbury. \nOf particular importance, the stark lack of affordable housing supply to meet the needs of \nlarger rented affordable households (4 bedroom and larger) has led to an acute shortage of \nnew larger affordable homes. Case in point, cross-referencing affordable housing delivery \nagainst identified needs reflects that, between 2013/14- 2023/24, only 9% of four bedroom \n+ rented affordable housing need has been met in Cheltenham Borough- equating to 24 \nunits, or, put another way, equivalent to a shortfall of 256 larger affordable units over a 10 \nyear period. \nThe turnover of existing social housing stock has been similarly ineffective at addressing \nrising rented needs, with 77 (70 four bedroom, 7 five bedroom) four bedroom or larger \nproperties being re-let through Homeseeker Plus since 2016/17, of which 34 have been relet since 2019/20. For comparison’s sake, as of February 2024, CBC’s Housing Register \nrecorded 122 households in 4-7 bedroom need requiring rented affordable housing. Thus, at \nthe current rate of new supply and turnover, it would take over 10 years to accommodate \nthe aforementioned 122 households on Cheltenham’s Housing Register. This picture is \nequally reflected across Tewkesbury and Gloucester, face significant problems in securing a \nsufficient supply of new larger rented affordable housing homes. In practice, therefore, the SLP should include a policy that delivers a set percentage of \nlarger affordable homes on major development, without compromising the overarching \naffordable housing thresholds for the SLP area. Additionally, the SLP should aim to enable good-quality, affordable private rented homes, without prejudicing the delivery of muchneeded affordable housing supply. \nFor those residents seeking to purchase their first home, the Housing Registry UK House \nPrice Index reflects that average property prices for first time buyers reached £272,000 in \nCheltenham, £211,000 in Gloucester and £271,000 in Tewkesbury as of December 2023. In \nthis context, the most efficient way of significantly boosting the delivery of affordable\nhousing through the SLP would be to increase the minimum affordable housing thresholds \non Strategic Allocations (or subsequent replacement) from the current 35% to 40%, subject \nto maintaining viability across the plan. \nThe SLP should also aim to provide specific numerical targets to enable specific provision of \ndementia-friendly homes and schemes (where the delivery of older-persons accommodation \nis proposed). More specifically, the SLP should clearly stipulate that older persons \naccommodation (covering both C2 and C3 use classes) should deliver policy compliant \naffordable housing, unless robust, independently assessed viability evidence demonstrates \nthat this is unachievable. \nEqually, ensuring that a sufficient supply of fit-for-purpose housing is delivered to \naccommodate those with Autistic Spectrum Conditions (ASC), and broader mental health \nneeds will help to ensure that the SLP authorities meet our obligations under the Equality \nAct 2010. The SLP process offers a critical opportunity to include specific policies and targets \nthat effectively address and meet the needs of these groups, thereby alleviating strain on \nprimary and secondary NHS services and adult & young children’s services. In practice, \ncreating a clear, robust policy framework will offer residents with these specific needs with \nan invaluable foundation upon which to live healthy, happy and fulfilling lives in their local \ncommunities. \nThe SLP must include a robust specific, target-driven policy for both delivering new-build \naccessible housing and wheelchair accessible homes respectively, for both market and \naffordable tenures. This policy should cover a range of groups including older persons \naccommodation to ensure that sufficient supply is delivered to meet current and future \nneeds. Reviewing the delivery of these crucial house types following the adoption of the JCS, \nthe current policy framework, which does not include quantifiable, robust policy \nrequirements and targets covering level access and wheelchair accessible homes- has been \nplainly ineffective in meeting the housing needs of disabled residents. For instance, in \nCheltenham, only 8 wheelchair affordable accessible homes have been delivered over the \nlast 10 years, with only 2 of these affordable homes being delivered over the ongoing JCS \nperiod. By comparison, the 2020 Gloucestershire LHNA identifies that, between 2021-2041, \n11 affordable wheelchair homes should be delivered per annum to meet need in addition to \n29 wheelchair accessible market homes per annum.\nDiscussions with the Children’s Services and Adult Social Care Teams at Gloucestershire \nCounty Council has indicated that the SLP area (and Gloucestershire more widely) has a \nsignificant deficit of children’s care homes (and accommodation to meet the needs of care \nleavers). Of particular note, Children’s care homes have disproportionately been located and sought in Gloucester City, leaving insufficient provision across the wider SLP area and \nCounty. In practice, this has led to children being placed in care settings outside of \nGloucestershire, away from their social and support networks- a far from ideal situation. \nIn view of the benefits of community housing investment and ownership, it would also be \nlogical and beneficial to designate small areas of land, in consultation with community \ngroups, where the delivery of community-led housing should be encouraged through\nplanning policy, thereby diversifying the available housing options open to our residents. ","No","","","","","","","","","Where strategic settlements are included as part of the SLP, these should include, as standard, a range of infrastructure and community facilities to aid with the formation of a \ncohesive, resilient and welcoming community where residents can thrive. Specifically, strategic scale new settlements should be accompanied by easily accessible, affordable and \nregular public transport links (to enable residents to travel to major population centres/work etc)- this is a critical consideration for lower-income residents, who may be unable to afford \nprivate cars. Additionally, the importance of providing temporary and permanent community facilities on strategic scale new settlements cannot be understated: developers should be \nheld to account to ensure that these services are delivered to local residents, through planning obligations, planning policies and appropriate conditions. Providing these facilities \n(e.g. a community hall, shops and other gathering spaces) is a crucial component of bringing people together and creating strong, cohesive, mixed and balanced communities. \nAn SLP infrastructure delivery plan could theoretically provide a mechanism to achieve this objective. Strategic scale new settlements should also provide sufficient provision for public green and blue spaces, as well as appropriately located and sized play areas, providing affordable and market tenants with equitable access to these resources, thereby benefiting all residents. The UK Government’s Electric Vehicle Strategy outlines the Government’s ambition to scale up the provision of EV chargers across the country in conjunction with private sector funding to power the transition away from petrol and diesel vehicles in pursuit of the Government’s net-zero targets. In this context, the incorporation of built-in EV infrastructure and charging points on strategic scale allocations will be an important mechanism for enabling a equitable and rapid transition towards net-zero carbon emissions. Clearly, therefore, both market and affordable tenants should benefit from equivalent infrastructure, both in terms of numerical distribution and overall quality of infrastructure provided, although careful consideration will need to be given to the takeup of EV’s amongst affordable housing tenants when designing schemes. ","","","Yes","","","","","","","[Q1] The SLP should cover until, at the very earliest, 2041. If possible, the SLP duration and affordable housing evidence bases should be aligned to aid in the monitoring and delivery of  affordable housing over the plan period. Notwithstanding this, in view of the significant affordability and housing supply issues that are likely to be increasingly prominent over the next 5 years, greater focus within strategic planning policies should be placed upon ensuring that the SLP’s policy and overarching vision addresses needs over a 5 year period following  the plan’s adoption date.\n\n\n[Q.5] The proposed strategic objectives are largely agreeable, with a few minor alterations aside. Of particular note, the inclusion of a phrasing within the Draft Vision stating that: ‘all \nhomes have usable functional amenity space that allows residents the opportunity to live, work and relax outside’ is welcomed. \n\n[Q.12] Whilst it is acknowledged that the Government’s latest standard method draws upon outdated population projections (using the 2016 demographic projections, instead of the updated 2018 demographic projections), it is felt that (notwithstanding any future updates to the Standard Method) the current local annual housing need calculation found within the Standard Method is the most appropriate mechanism for determining the number of new homes required over the SLP period. \n\n[Q15] In principle, the provision of pitches or plots on large developments for mixed use or residential development is acceptable. As public bodies, local authorities have a public sector \nequality duty to the Gypsy & Traveller community through the 2010 Equality Act. All three SLP authorities have varying degrees of housing need arising in relation to accommodating \ntraveller communities, with Tewkesbury being the primary District where accommodation is required, followed by Gloucester, and then, nominally, Cheltenham. Given this outstanding \nhousing need, and the onus upon the SLP authorities, (working with applicants and other stakeholders) to create cohesive mixed and balanced communities, the delivery of accommodation for traveller communities on large scale development sites should be carefully considered, and subject to careful negotiation, be encouraged on strategic \nallocations following extensive engagement with all relevant parties. Crucially, however, any provision of traveller plots or pitches should be undertaken in close \nconsultation with the traveller communities themselves, recognising their specific requirements and needs. Equally, whilst consideration should be given to accommodating traveller communities on large-scale residential developments, it is logical to consider whether, (dependent on the circumstances of the allocation and needs and desires of the traveller communities) the allocation of individual plots and pitches on smaller sites in more ancillary areas of the SLP area would be more appropriate (for example, designating plots or \npitches on local authority/county council land), or a combination of both approaches. When determining whether accommodation is provided for traveller communities on larger \ndevelopments, it is important to consider the physical siting of pitches and plots, as well as ensuring that any plots provided are adequately linked to the required amenities.] \n\n[Q. 31] Given the fundamental importance of Tewkesbury supporting Cheltenham and Gloucester respectively to meet their respective housing needs (and allocating affordable homes to \nmeet needs), it is critical that a shared policy approach is incorporated within the SLP to meet Cheltenham and Gloucester’s housing needs (encompassing both affordable and \nmarket tenures) in full. The Government’s recent decision to discontinue the ‘duty to cooperate’ via the Levelling Up and Regeneration Act 2023 (although yet to be enacted \nthrough the NPPF) further underlines the importance of securing policy alignment on this key cross-boundary issue. Wherever possible, achieving consistent, shared and robust affordable housing policies across the SLP area is desirable to provide developers, local authorities, housing associations and residents with clarity regarding the SLP’s expectations surrounding affordable housing provision. When delivering affordable housing, there is a general consensus amongst local RP’s and the SLP authorities that the delivery of social rented homes should be prioritised, with the delivery affordable rented homes comprising a limited role in meeting affordable housing need. Finally, when determining appropriate locations for new development, the accessibility and availability of supporting infrastructure should be a key consideration."]
[null,null,30,"In recognition of the general trend towards reduced biodiversity, the government has legislated to require development to include a biodiversity nett gain. Where possible, this should be provided on site and offset arguments not accepted unless strictly necessary.\n\nThe strategy should also address improvements in public health. \nFor example, there is concern relating to increased incidence of asthma and other respiratory illnesses. This can be partly mitigated by the use of adequate household ventilation. Mould growth within the home can be prevented by reducing humidity, and filtered ventilation can prevent the ingress of foreign particulate; such as combustion products and pollen. ",null,null,null,null,"The objectives are commendable, but a little vague. Currently, developers are simply offering to extend suburban sprawl, with increased reliance on motor vehicles.\nTo be effective, a vision is needed which is more specific and clear on how this will change.  For example, sustainable transport is a meaningless term.\nA key aspect of moves to a carbon-neutral future is the increased adoption of public transport.\nIt is not reasonable to expect the public to wait at a bus stop at the side of a road in all weathers, and to expose themselves to the risk of harassment while they are waiting. The transport hub in Gloucester is an example of adequate provision, but there appears to be a need for by-laws and/or enforcement to prevent harassment of travellers by people demanding money. Public transport will only be used if it is perceived to be safe. Can I propose that:\n\nA sustainable public transport system will include multiple transport hubs where it is possible to wait in comfort, where refreshment is available, and where harassment can be prevented.\n\nTypically, these hubs should be integrated into office buildings, shopping centres and other key destinations. This should be a key part of permission for new development, but also a policy objective where a back-fit can be negotiated.\n\n\n","The single most effective policy change would be to mandate that wherever possible, housing is optimally aligned to the sun (Glazing on buildings should be aligned to provide maximum winter solar gain, but to limit summer solar gain; by the provision of suitable over shading - using balconies and other jettied structures). ","Ensure that properties make the maximum use of embedded thermal mass for the storage of heat energy. In particular, where bulk concrete is used in the construction of flooring, this should be used effectively to help regulate the building temperature. Often, this is just about where the insulation is placed, but sometimes needs a change in thinking: In the summer, the thermal mass can be used in combination with night ventilation to limit daytime temperatures.\nWhere large buildings are constructed, they can include an atrium which acts as a solar collector and controls the building environment; including automatic night ventilation in summer. This usually also acts as a stair/lift well and includes much of the thermal mass. In many current designs, this opportunity is lost.","Ensure that properties make the maximum use of embedded thermal mass for the storage of heat energy. In particular, where bulk concrete is used in the construction of flooring, this should be used effectively to help regulate the building temperature. Often, this is just about where the insulation is placed, but sometimes needs a change in thinking: In the summer, the thermal mass can be used in combination with night ventilation to limit daytime temperatures.\nWhere large buildings are constructed, they can include an atrium which acts as a solar collector and controls the building environment; including automatic night ventilation in summer. This usually also acts as a stair/lift well and includes much of the thermal mass. In many current designs, this opportunity is lost.",null,null,null,"Priority needs to be given to the provision of integrated systems for public transport, pedestrians and cyclists in a way that it is not at present. Public transport is currently a dismal experience.  \n\nEven new cycle provision is poorly implemented; exposing cyclists to high levels of risk. In particular, cycling routes are often intersected frequently by junctions and vehicle access to properties. These intersections often do not provide adequate visibility and may include hedges or high fences. Cyclists should be able to commute safely at an average speed of 20 miles per hour. This should be the design objective of any cycle provision.\n\nSome recent housing developments of significant size have been constructed without the provision of any cycle lanes across the site. This should not be acceptable",null,"The most effective change would be to use building thermal mass to reduce the rate at which its temperature changes; so that it can be heated or cooled at the most appropriate time in terms of the availability of energy and optimal ambient temperatures.\nOtherwise, the incorporation of photovoltaic generation into new buildings should be considered. This is fast approaching a maturity where it can reasonably be incorporated into new roofs (rather than added on top).",null,"The standard calculation is a starting point, but the government figures are based on a number of questionable assumptions and contingency planning should be included to ensure that we can accommodate a much higher number, possibly by a factor of ten.\nThe first key assumptions are; firstly, that nett migration can be controlled, and secondly, that world population will stabilise at 10 billion.  Both look questionable and are dependent on meeting climate change targets.\nIn particular, population stability is dependent on increased prosperity in India and sub-Saharan Africa and women controlling fertility.",null,null,null,"Developments such as those in Churchdown are suburban sprawl. They come with no facilities and are too far from the centre of town and other facilities to make walking feasible. They are very isolating; particular for the elderly. The result is increased reliance on motor vehicles and the use of out-of-town shopping developments (city-centre parking having priced itself out oof the market). The starter homes provided are cramped, small boxes; just meeting minium requirements. In essence, they are the slums of the future. For students, we should build at higher density and higher quality; around strategic transport hubs. Experience show that, provided there is adequate quality, high density provision can support more amenities and is very sought after. Central Bath, Oxford and London are examples (as is Pittville in Cheltenham). To make this work, very local standards of architecture need to be prescribed, exceeding the current minimum, and setting a local style. ",null,null,null,null,null,null,"The loss of business in the town centre has been driven by the increasing difficulty in accessing it. Parking charges make visiting the town centre by car uneconomic compared to out-of-town shopping, and the reduction in the reliability of bus services has also not helped. If town centres are to recover, they either need to be served by more competitive transport links, or they need to accommodate a higher density of people either living or working within easy reach.\n\nIn Gloucester, there is also a perception from visitors that the town centre is unsafe and that the shops are in a poor state of repair.  Partly, this relates to high rates of homelessness apparent in the city centre. These are issues that need to be addressed before it can be thought of as a leisure destination or a candidate for inward investment.\n\nA representative of a major Holywood film company was given a tour of the city and advised that they would not be using Gloucester as a film location for this reason.","The comment on food shops in Cheltenham is, I guess, very old. We now have a large Waitrose store and many other supermarkets and specialist foot retailers. However, Waitrose appears to be an ideal site for a transport hub, with its own provision and a number of large offices in the immediate area providing a need. Consideration should also be given to better integrating John Lewis into the transport system.","As part of a sustainable public transport system, developments should include a transport hub; where it is possible to wait in comfort, where refreshment is available, and where harassment can be prevented.\nTypically, these hubs should be integrated into office buildings, shopping centres, or other key destinations. This should be a key part of permission for new development, but also a policy objective where a back-fit can be negotiated.","On a strategic scale, transport will be key. This should include streamlining travel between a network of transport hubs; as you might see in major cities, with provision for segregated public transport and (in the medium term) driverless public transport vehicles. This may be a medium -term aspiration, but we need to start planning for it now.",null,null,null,null,"No","The pros and cons are not well-founded. In particular, The comments against high-density urban development are contradicted by experience. Increasing housing density prevents urban sprawl, which would otherwise increase distances travelled: The larger the suburban area, the longer the journeys. High density also makes the use of public transport more practical, so that ownership of a private car becomes unnecessary. This is evidenced by the low car ownership in central London.\n\n High density of housing does not mean poor housing, and would not drive people out of these areas; as seems to be implied in the assertion. The evidence suggests the opposite; property prices more often increase as housing density increases. This is true in the centre of cities such as Oxford, Bath and London. Large buildings can provide spacious accommodation at a more affordable cost than small buildings, and they are much more thermally efficient. \nContinental Europe typically uses a higher density. Quality can be achieved by specific policies for particular areas. The Cotswolds area demonstrates this. \nStandards can be maintained by mandating certain architectural features in particular areas. These might include minimum room sizes, and policies on the look of buildings to ensure a coherent architectural style. Much can be learned from, for example, the Royal Crescent in Bath. \n\nThe Georgian style is well regarded by the public and can easily be reproduced with modern steel frame buildings. Cheltenham already has a number of examples of this.\nCan we please build something of quality?",null,null,null,"[Q1] Significant structural changes will occur as development resources become available, and a realistic timescale for this is thirty years. \nThis does not mean that key aspect of the plan can be postponed. \n\n[Q.8] It is possibly more important to set expectations as to how this should look in a particular area. Especially urban environments. Where possible, this should be provided on site and offset arguments not accepted unless strictly necessary. Where space is limited, this should not take the form of discrete gardens with separating fences, but maintained shared spaces for residents; similar to those seen in Kensington and Bloomsbury in central London.\n\n[Q.29] There is not one type of development that fits all. Young people and old people benefit from living in a high-density urban area, while families with children may prefer more space ."]
["Planning agent or developer","Robert Hitchins Ltd","","Paragraph 2.4 of the consultation reflects the NPPF paragraph 20 in terms of what strategic \npolicies should address in the plan. \n“Strategic policies should set out an overall strategy for the pattern, scale and design quality \nof places (to ensure outcomes support beauty and placemaking), and make sufficient \nprovision11 for:\na) housing (including affordable housing), employment, retail, leisure and other commercial \ndevelopment;\nb) infrastructure for transport, telecommunications, security, waste management, water \nsupply, wastewater, flood risk and coastal change management, and the provision of minerals \nand energy (including heat);\nc) community facilities (such as health, education and cultural infrastructure); and\nd) conservation and enhancement of the natural, built and historic environment, including \nlandscapes and green infrastructure, and planning measures to address climate change \nmitigation and adaptation.”\nSection 19(1B) - (1E) of the Planning and Compulsory Purchase Act 2004 sets out that each \nlocal planning authority must identify their strategic priorities and have policies to address \nthese in their development plan documents (taken as a whole).\nIt is essential that cross boundary matters are considered as strategic policies. Cross \nboundary matters should include the review of the Green Belt, provision of housing and \nemployment needs (as previously in the adopted JCS) and infrastructure.\nIt is noted that the intention is for the SLP to include separate sections that will cover each \nlocal authority area only providing “locality policies” that address issues and opportunities \nspecific to that area. \nThrough the SLP it should be clear which policies are strategic and which are non-strategic as \nset out in the NPPF paragraph 21. The PPG states:\n“…Where a local plan contains both strategic and non-strategic policies, the non-strategic \npolicies should be clearly distinguished from the strategic policies…”. Paragraph: 002 \nReference ID: 61-002-20190315","Non-strategic policies provide more detailed policies for a specific area(s), neighbourhoods or \ntypes of development. Paragraph 28 provides guidance on what matters can be covered by \nnon- strategic policies.","","In general, the Vision is supported. Through the objectives the Vision should be capable of \nbeing monitored.\nThe first paragraph of the Vision seems only to apply to larger scale developments, surely \nharnessing the opportunities for “green growth” etc should apply throughout the plan area.\n“Green Growth” should be defined in the glossary. The OECD definition of green growth and \nsustainable development is:\n“Green Growth means fostering economic growth and development, while ensuring that \nnatural assets continue to provide the resources and environmental services on which our \nwell-being relies.”\nFurthermore, it is not clear who will deliver “green growth” or how it will be delivered. Maybe it \nshould say “Working with our partners…”\nThis point also applies to the second paragraph of the Vision.\nThe third paragraph of the Vision is supported as whilst it acknowledges that there is a focus \non making the best possible use of brownfield sites etc, it also acknowledges that there is a \nneed for comprehensive planned new development to ensure housing and employment needs \nare met in sustainable locations. The point is that this will involve building on greenfield sites. \nThere is a need to provide a range and choice of sites and clearly not all needs can be met in \nthe urban areas on brownfield sites.\nThe fourth paragraph is supported i.e. “Growth in sustainable locations will have enabled the \nprovision of healthy, accessible and walkable neighbourhoods, the promotion of active travel \nand sustainable travel, and provision of new transport systems that work for local people.”\nThe fifth paragraph should be split into separate points:\nI.e. “Growth will have been supported by the provision of a range of essential digital, transport, \ncommunity and other infrastructure.”\nAnd then “Equally, alongside conserving the area’s special landscapes and its attractiveness \nas a place to visit, a network of interconnected green spaces and waterways will have secured \na high-quality environment for people and nature. Together with necessary retention and \nmanagement of existing sports and leisure facilities, this will have unlocked opportunities for \nhealthy lifestyles, inclusive access to sport and recreation, active flood risk management and \nimprovements to biodiversity.”","No","The objectives are set out under 8 themes. The objectives should be capable of monitoring in \norder to assess whether the plan is delivering in accordance with the NPPF. \n“Meeting the challenges of climate change”\nObjective 1 should be redrafted, as currently drafted it duplicates part of Objective 5 as it \nrefers to the delivery of zero and low carbon development. The achievement of BNG is a \nseparate issue and should reflect current policy guidance. E.g. “Maintain and improve the \nnatural and built environment including biodiversity, landscape, green Infrastructure and \nwaterways by ensuring new development achieves high-quality design standards and \nconserves and enhances the natural, historic, cultural and landscape assets”.\n“Delivering a wide choice of homes that meet the needs of our communities.”\nAdded to this should be \"which supports economic growth\"\nObjective 1 “Delivering sufficient new homes in the right places to meet the needs…”\nThis should read meeting housing needs in full. It is not clear what “sufficient” means it should \nbe sufficient to meet needs. For clarity the objective should be redrafted to read to meet \nneeds in full. \nIn order to ensure sustainable growth in Cheltenham, Gloucester and Tewkesbury, especially to \naddress the issue of an ageing population, younger people and people of working age need to \nbe retained and attracted to the area. One way of doing this is to provide a sufficient supply of \nhousing. \nBuilding strong, competitive and sustainable urban and rural economics\nThe objective should also include to support the growth in total employment across the SLP \narea. (Tewkesbury has one of the strongest performances in the south west being in the top 10 \nwhereas Cheltenham is one of the lowest).","The most effective way that SLP should address climate change is to plan for sustainable \ndevelopment, i.e. development in those locations that have the greatest opportunity to deliver \nand support development. Policies should not seek to go beyond national policy, instead they \nshould be consistent with the NPPF and government guidance. (see response below to \nQuestion 7).","Any measures and standards should be consistent with the Government’s policy. A Written \nMinisterial Statement was issued by Lee Rowley on 13th December 2023 which states that: \n“For a number of years, the plans of some local authorities have sought to go further than \nnational standards in terms of such efficiency for new-build properties. Equally, there is a \nlegitimate consideration for the Government to want to strike the best balance between \nmaking progress on improving the efficiency and performance of homes whilst still wanting to \nensure housing is built in sufficient numbers to support those who wish to own or rent their \nown home.\nIn 2015, in reference to an uncommenced provision in the Deregulation Act 2015 which \namended the Planning and Energy Act 2008, a written ministerial statement (WMS) (HC Deb, \n25 March 2015, vol 584, cols 131-138WS) stated that until that amendment was commenced, \nlocal plan policies exceeding minimum energy efficiency standards should not go beyond level \n4 of the Code for Sustainable Homes. Since then, the introduction of the 2021 Part L uplift to \nthe Building Regulations set national minimum energy efficiency standards that are higher than \nthose referenced in the 2015 WMS rendering it effectively moot. A further change to energy \nefficiency building regulations is planned for 2025 meaning that homes built to that standard \nwill be net zero ready and should need no significant work to ensure that they have zero \ncarbon emissions as the grid continue to decarbonise. Compared to varied local standards, \nthese nationally applied standards provide much-needed clarity and consistency for \nbusinesses, large and small, to invest and prepare to build net-zero ready homes.\nThe improvement in standards already in force, alongside the ones which are due in 2025, \ndemonstrates the Government’s commitment to ensuring new properties have a much lower \nimpact on the environment in the future. In this context, the Government does not expect \nplan-makers to set local energy efficiency standards for buildings that go beyond current \nor planned buildings regulations. The proliferation of multiple, local standards by local \nauthority area can add further costs to building new homes by adding complexity and \nundermining economies of scale. Any planning policies that propose local energy efficiency \nstandards for buildings that go beyond current or planned buildings regulation should be \nrejected at examination if they do not have a well-reasoned and robustly costed rationale that \nensures:\nThat development remains viable, and the impact on housing supply and affordability is \nconsidered in accordance with the National Planning Policy Framework.\n8\nThe additional requirement is expressed as a percentage uplift of a dwelling’s Target \nEmissions Rate (TER) calculated using a specified version of the Standard Assessment \nProcedure (SAP).\nWhere plan policies go beyond current or planned building regulations, those polices should \nbe applied flexibly to decisions on planning applications and appeals where the applicant can \ndemonstrate that meeting the higher standards is not technically feasible, in relation to the \navailability of appropriate local energy infrastructure (for example adequate existing and \nplanned grid connections) and access to adequate supply chains.\nTo be sound, local plans must be consistent with national policy – enabling the delivery of \nsustainable development in accordance with the policies in the National Planning Policy \nFramework and other statements of national planning policy, including this one.” (my\nemphasis)\nIf the Councils were to set their own standards there is a real risk of adding to the complexity \nof the approach of policy, regulations and standards that housebuilders are already expected \nto comply with. There is also a risk to the viability and consequently the delivery of sites.\nThe key to success is standardisation and avoidance of individual Councils specifying their \nown policy approach, which undermines economies of scale for product manufacturers, \nsuppliers and developers.","","No","","","The provision of key services and facilities within easy reach of development, depends on the \nprovision of existing services, capacity in schools etc and whether it can be justified and \nwhether it is viable depending on the level of development to support such facilities. ","","","No","It is noted that the Councils have not yet prepared an update of the Local Housing Needs \nAssessment (2020). This document reflected the standard method applicable at the time. \nThe consultation document acknowledges that since then, the figures have changed, (every \nyear the figures are updated due to the affordability ratio which is published in March).\nThe Standard Method figure changes annually until the Local Plan is submitted for Examination. \n(PPG Paragraph: 008 Reference ID: 2a-008-20190220.) The Government have reaffirmed the \nuse of the standard method in the NPPF Dec 2023, the standard method is the starting point. \nHowever, the standard method does not generate a housing requirement, other factors \nneed to be considered, as set out in the PPG.\n“Assessing housing need is the first step in the process of deciding how many homes need to \nbe planned for. It should be undertaken separately from assessing land availability, \nestablishing a housing requirement figure and preparing policies to address this such as site \nallocations”. PPG Paragraph: 001 Reference ID: 2a-001-20190220\nAn insufficient number of homes have been delivered nationally to meet the need for 300,000 \nhomes per annum, with only 232,816 built in 2021/22. The necessary consequence of this is \nthat the need for housing will have increased regardless of the results of the Government’s \nstandard method.\nIn this context, it remains the case that local authorities need to be aiming above the minimum \nlocal housing need to address housing needs in full and to deliver the 300,000 homes per \nannum sought by the Government. With the standard method still providing a minimum target \nbelow 300,000, it is inevitable that we will continue to see a shortfall in national housing \ndelivery without this.\nAs stated above, the Standard Method identifies a minimum housing need figure, it does not \nproduce a housing requirement (PPG Housing and Economic Needs Assessments paragraph\n002 Reference ID: 2a-002-20190220).\nThe PPG outlines the circumstances when it might be appropriate to plan for a higher housing \nneed figure than the standard method indicates:\n“The standard method for assessing local housing need provides a minimum starting point in \ndetermining the number of homes needed in an area. It does not attempt to predict the \nimpact that future government policies, changing economic circumstances or other factors \nmight have on demographic behaviour. Therefore, there will be circumstances where it is \nappropriate to consider whether actual housing need is higher than the standard method \nindicates.\nThis will need to be assessed prior to, and separate from, considering how much of the overall \nneed can be accommodated (and then translated into a housing requirement figure for the \nstrategic policies in the plan). Circumstances where this may be appropriate include, but are \nnot limited to situations where increases in housing need are likely to exceed past trends \nbecause of:\n• growth strategies for the area that are likely to be deliverable, for example where \nfunding is in place to promote and facilitate additional growth (e.g. Housing Deals);\n• strategic infrastructure improvements that are likely to drive an increase in the homes \nneeded locally; or\n• an authority agreeing to take on unmet need from neighbouring authorities, as set out \nin a statement of common ground;”\nPara 010 Reference ID:2a 010-20201216\nThe current standard method for each of the LPAs is shown in the Table on page 23 of the \nconsultation document and is based on the March 2023 affordability ratio.\nWhen compared with the adopted JCS (2017) which has a housing requirement of 35,175 \ndwellings over a 20-year period, which is 1,759 dwellings per annum, the SLP is now proposing \nonly a slight increase in the number of dwellings to 1,785 dwellings per annum, i.e. an increase \nof only 26 dwellings per annum. This is not consistent with the NPPF (Dec 2023) paragraphs\n60 and 61 as set out below.\nParagraph 60 states that in order to support the Government’s objective of significantly \nboosting housing supply, it is important that sufficient amount and variety of land can come \nforward where it is needed.\n“The overall aim should be to meet as much of an area’s identified housing need as possible, \nincluding with an appropriate mix of housing types for the local community.”\nThe outcome of the standard method is advisory as stated in para 61 of the NPPF (Dec 2023) \nstates:\n“The outcome of the standard method is an advisory starting-point for establishing a housing \nrequirement for the area (see paragraph 67 below). There may be exceptional circumstances, \nincluding relating to the particular demographic characteristics of an area25 which justify an \nalternative approach to assessing housing need; in which case the alternative approach \nshould also reflect current and future demographic trends and market signals. In addition to \nthe local housing need figure, any needs that cannot be met within neighbouring areas should \nalso be taken into account in establishing the amount of housing to be planned for.”\nNPPF para 67 states:\n“Strategic policy-making authorities should establish a housing requirement figure for their \nwhole area, which shows the extent to which their identified housing need (and any needs that \ncannot be met within neighbouring areas) can be met over the plan period. The requirement \nmay be higher than the identified housing need if, for example, it includes provision for \nneighbouring areas, or reflects growth ambitions linked to economic development or \ninfrastructure investment. Within this overall requirement, strategic policies should also set \nout a housing requirement for designated neighbourhood areas which reflects the overall \nstrategy for the pattern and scale of development and any relevant allocations33 “\n(my emphasis)\nThe consultation document acknowledges that the standard method is the minimum housing \nneed figure and that this figure provided by the government is the starting point. In paragraph \n5.17 and 5.18 the consultation document reports the NPPF advice referred to above, but then \nconcludes “our current evidence exploring economic growth forecasts and their relationship \nto the need for new homes have concluded there is currently no justification for amending the \nneeds figures, this evidence is required to be kept under review.”\nHowever, the evidence that the consultation relies upon is out of date, as there is no uptodate \nLocal Housing Need Assessment or Economic Assessment (LHNA) available to support the \nconsultation, both are dated 2020. It is noted that a new LHNA is being undertaken.\nIt is noted in the Gloucestershire Statement of Common Ground that it has been agreed \n(February 2022),\n\"Housing Agreement  \nThe Parties agree that making provision to meet the full range of housing needs in the right \nplaces at the right time is a vital role for the Gloucestershire authorities. The parties \nacknowledge this may result in one local authority accommodating the identified needs of \nanother local authority, particularly where a local authority is unable to accommodate all of the \nidentified need and where accommodating need in a neighbouring authority represents the \nmost sustainable form of development.”\n8 That the district councils \"agree to deliver housing where it promotes sustainable patterns of \ngrowth in Gloucestershire and is designed to respect the local character and address \npotential impacts on existing communities.”\nIt is considered that there is a justification for increasing the housing requirement above the \nminimum need provided by the standard method. In particular addressing the current housing \ncrisis, meeting housing need, providing a range and choice of sites, providing affordable \nhousing and providing homes to support economic growth.\nCheltenham, Gloucester and Tewkesbury have seen significant growth in the number of people \naged 65+ over the last decade. While past change in Cheltenham and Gloucester has been \ndriven largely by natural change, in Tewkesbury internal migration has played a big role in \ngrowing the population. \nWith all three areas projected to continue experiencing significant growth in its older \npopulation, younger people and people of working age need to be attracted to the local \nauthority. One way of doing this is through providing attractive and suitable housing options.\nOver the last seven years (from 2015-2022), Tewkesbury’s labour market has performed \nextremely well. In relative terms, it has seen the second highest employment growth of all \nSouth West local authorities. \nIf the positive trend of strong jobs growth continues in Tewkesbury, more people are likely to \nbe attracted to the area and this will make it even more important to ensure the housing offer \ncan meet the likely increase in demand for properties. For Cheltenham and Gloucester, jobs \ngrowth is equally as important in moving both areas closer to regional and national trends. If \nthey are successful in improving the performance of their respective labour markets, it is not \nunreasonable to expect more people to want to move to the area, which would increase \nhousing demand. Indeed, significant growth is anticipated as Cheltenham’s reputation as the \ncyber capital of the UK is established. As set out in Cheltenham’s Corporate Plan, Key Priority 1 \nCyber Cheltenham.\n“With a significant development site next to GCHQ, in a highly accessible location with great \nconnectivity, the opportunity exists to create a destination of global significance.”\nThere will be “spin offs” in terms of employment and other opportunities arising.\nBetween 2012 and 2022, the affordability ratios in Cheltenham (8.94), Gloucester (7.70) and \nTewkesbury (8.68) increased. The affordability ratios in the LPAs are currently below the ratio \nin the South West (9.41) but above the ratio in England (8.28), with the exception of Gloucester. \nMortgage providers will typically only lend 4-4.5 times a persons’ salary showing that housing \nin all areas is becoming increasingly unaffordable for many households. To put the affordability \nissue into perspective, as of 2022 the median house price in Tewkesbury is £300,000 and the \nmedian workplace-based wage is £34,544.\nHousing delivery has been strong in Tewkesbury, which has coincided with an increase in net \ninternal migration. For this to continue, a good supply of housing sites needs to be provided. \nCheltenham and Gloucester have both been consistently below target, which makes it vital for \nhousing delivery to increase in the long-term. \nHousing affordability in Cheltenham, Gloucester and Tewkesbury is a serious issue, for people \nearning median salaries and those in the lowest 25% of earners. This situation is unlikely to \nimprove unless more homes can be delivered. Simply basing housing need on the Standard \nMethod (including the projections which reflect past under delivery) will not significantly boost \nsupply.\nBoth Cheltenham and Gloucester have performed poorly in terms of past housing delivery, \nwhich makes it even more important to set ambitious housing targets. To address the trend of \nan ageing population which is projected in all three areas up to 2041 and also to improve \nlabour market performance, consideration needs to be given to increasing the standard \nmethod figure. The Issues and Options Consultation document states that the most recent \n2020 Housing Needs Assessment will be updated later in the SLP process. Once this new \nevidence is published and has been reviewed, a suggested housing target will be provided. The \nsame comment applies to the employment land requirements, which should also be updated \nlater in the SLP process. \nFrom our analysis it is considered that simply going with the standard method for housing \nneed in Cheltenham, Gloucester and Tewkesbury is not enough, the Standard method does not \nproduce a housing requirement. There is justification for a higher figure for housing i.e. above \nthe minimum figure generated by the standard method.\nThis is set out in Appendix 1: Economic Overview and Housing Need and should be kept \nunder review until the Local Plan is submitted for examination.","No","It is considered that when the opportunities and constraints are reviewed that there are sites \nin highly sustainable locations that are available, and which can assist the Council’s in meeting \na higher housing figure in the plan period. There is no reason why the housing requirement \nshould be constrained.","Yes","NPPF paragraph 63 states that, “the size, type and tenure of housing needed for different \ngroups in the community should be assessed and reflected in planning policies. These groups \nshould include (but are not limited to) those who require affordable housing; families with \nchildren; older people (including those who require retirement housing, housing-with-care and \ncare homes); students; people with disabilities; service families; travellers28; people who rent \ntheir homes and people wishing to commission or build their own homes29\n.”\nClearly the plan needs to provide a range and choice of sites, in terms of house types, sizes \nand tenure.\nIt can be seen from the analysis in Appendix 1 the proportion of homes that were owned with a \nmortgage or loan decreased in every area between 2011 and 2021, with Gloucester \nexperiencing a decline from 38% to 32.3%. Additionally, the proportion of homes that were \nprivately rented increased at similar rates in every area.\nThere is a significantly higher proportion of homes that are owned outright in all areas by those \naged 65 and over compared to the younger population (those aged 64 and under).\nAffordability is also an issue – for example, in 2012, the affordability ratio in Cheltenham was \n5.81. By 2022, the affordability ratio in the local authority had increased to 8.94. As of 2022, the \nmedian affordability ratio in Cheltenham was higher than the ratios seen in Gloucester (7.70), \nTewkesbury (8.68) and England (8.28) but was below the ratio in the South West (9.41). \n15\nTo put the affordability ratios into perspective, as of 2022 the median house price in \nTewkesbury is £300,000 and the median workplace-based wage is £34,544. Mortgage \nproviders will typically only lend 4-4.5 times a persons’ salary. Therefore, the affordability ratio \nin all areas presented in Figure 4.1 is significantly above the 4-4.5 times salary to house price \nratio.\nAs of 2022, the typical lower quartile house price in Tewkesbury is £230,000 and the lower \nquartile workplace-based earnings are £25,886, highlighting how difficult it is for the lowest \n25% of earners to get a foot on the property ladder.\nAll of which points to need to increase the supply of housing for all.","","The GTAA Report provides advice to the local authorities.","The GTAA Report provides the advice.","The Gloucestershire Statement of Common Ground (February 2022) states at paragraph 10 \n\"10. The Parties agree it is important to take advantage of the location and characteristics of \nGloucestershire and its economic strengths. The parties will take a pro-active role in creating \nthe conditions within which existing and potential new employers can flourish, with a particular \nemphasis on spatial planning. Action will be taken to identify the appropriate scale and \ndistribution of employment allocations, with the potential value of strategic sites to serve a \nlarger area fully considered.\n11. Parties agree that collaboration is essential to deliver a purposeful Gloucestershire \napproach to inward investment and business retention.”\nThe Gloucestershire Economic Needs Assessment (August 2020) needs to be updated – this \nwas prepared at the time of the COVID 19 pandemic and considered the potential impact on \nGloucestershire’s economy. Paragraph 5.32 of the consultation document acknowledges the \nneed to update the assessment – this will be critical in terms of providing the growth needed \nover the plan period.\nAny evidence will need to take account of ‘market signals’, which includes what changes in \nskills are likely to be needed; how many people will there be to take up jobs; and whether \nexisting employment land meets the needs of existing businesses or people looking to set up \nbusinesses in the area.\nThe SLP needs to recognise and support the delivery of the Gloucestershire Economic \nStrategy produced by Gloucestershire County Council and the GFirst LEP – due for approval in \nearly 2024. This strategy supports the county’s economic priorities for the next 5 years but \nimportantly for the SLP provides a long-term view to 2050.\nThe introduction to the Economic Strategy states:\n“To meet the needs of the economy, the county requires a robust long-term vision for \neconomic growth and prosperity supported by a countywide spatial strategy. This will provide \nconfidence to businesses and communities about how the county will grow. It will sustain a \nquality employment offer within the county and improve ease of access to the opportunities \nprovided across the region. Over the next 30 years, the county will need to balance the need \nfor additional infrastructure, affordable housing, the need to combat climate change, increase \nits working age population while sustainably managing its natural and historic environment. To \nachieve this, it is important think strategically and on a countywide basis.”\nGloucestershire has an ageing population and high housing costs which have implications for \nthe workforce with the number of jobs expected to exceed the number of working age people \nby 2035. (Gloucestershire Economic Strategy Draft – July 2023)\nThe intended outcomes of the Gloucestershire Economic Strategy focus around “Place\" and \n“People.” E.g. the county growth strategy delivers vibrant delivers vibrant and sustainable \ncommunities and the working age population is increased to rebalance our economy”\n18\nhttps://www.gloucestershire.gov.uk/council-and-democracy/growgloucestershire/developing-a-new-economic-strategy-for-gloucestershire/intendedoutcomes/\nThe SLP needs to consider the implications of the Gloucestershire Economic Strategy which \nidentifies core propositions, and which underlines the importance of taking a strategic \napproach to planning new residential and employment growth, focused in areas that are most \nsustainable in terms of strategic environmental and social considerations.\nThe Gloucestershire Local Transport Plan (LTP) is also key to formulating the strategy.\nThe LTP 2020-2041 acknowledges that M5 is key for employment growth. Para 4.2.2 states: \n“The CSV CPS area accommodates almost half of Gloucestershire’s total population and has \nthe highest proportion of working age people when compared to the county average. This is \nreflected by the high proportion of travel to work journeys that begin and end within the CPS \narea.”\nThe following paragraphs from the LTP clearly demonstrate the role of the SLP area in terms of \nfunction and relationship.\nPara 4.2.4 states:\n“Growth proposals identified in the adopted JCS and Local Industrial Strategy will significantly \nincrease the CPS area’s population and range of employment opportunities offered, with even \nmore growth expected through the JCS review. This will result in more trips within this area \nand will require careful management to reduce congestion and limit environmental impacts. \nThe JCS aims to locate jobs near to the economically active population thus minimising outcommuting and reducing carbon emissions from car use and instead promoting sustainable \ntransport by improving opportunities for public transport, walking and cycling by making \nroutes more convenient, safe and attractive.\nPara 4.2.5 states:\n“To manage the impacts of growth, the JCS is supported by a comprehensive Transport \nStrategy that details a recommended mitigation package to enable the delivery of the \nproposed development. The schemes detailed in the Transport Strategy are echoed in this \nLocal Transport Plan.”\nParagraph 4.2.6 states:\nIn line with the JCS, GFirst LEP’s Strategic Economic Plan (SEP) supports delivery of \nemployment land around Junctions 9, 10 and 11 of the M5 area. A number of transport related \nproposals for the county will enable the planned growth to be achieved through the release of \nthis employment land.\nParagraph 4.2.7 states:\n“The Local Industrial Strategy identified the Gloucestershire area as a key location for cyber \nresilience alliance – cyber security. This will generate high level skilled employment \nopportunities for which people may be prepared to commute some distance. Gloucestershire \n19\nwill need to support growth in this sector by providing the necessary transport infrastructure \nto facilitate movement through and within the county.”\nIn summary the interaction between employment and housing is critical to sustainable growth. \nAn increase in the number of jobs can it itself generate a requirement for additional housing. It \nmay be that a higher housing figure is needed for economic reasons and a higher housing \nnumber is also needed for housing delivery reasons.","One of the three objectives of the NPPF is an economic objective –\n“to help build a strong, responsive and competitive economy, by ensuring that sufficient land \nof the right types is available in the right places and at the right time to support growth, \ninnovation and improved productivity; and by identifying and coordinating the provision of \ninfrastructure;”\nParagraph 85 of the NPPF: \n“Significant weight should be placed on the need to support economic growth and \nproductivity, taking into account both local business needs and wider opportunities for \ndevelopment. The approach taken should allow each area to build on its strengths, counter\nany weaknesses and address the challenges of the future.”\nParagraph 87\n“Planning policies and decisions should recognise and address the specific locational \nrequirements of different sectors. This includes making provision for clusters or networks of \nknowledge and data-driven, creative or high technology industries; and for storage and \ndistribution operations at a variety of scales and in suitably accessible locations.”\nThe SLP should seek to accommodate employment needs in the most sustainable locations, \naccessible well severed by public transport.\nA range and choice of employment sites to meet requirements will be essential.\nThe SLP should be prepared to reflect the Strategic Economic Plan for Gloucestershire \nhttps://www.gloucestershire.gov.uk/media/wq4ph3zh/glos-5-year-econcomic-strategy.pdf\nThe SLP needs to recognise the implications of failing to address housing needs when there is \na housing crisis, will have adverse implications for the social and economic consequences for \nthe SLP and undermine the objectives of the Strategic Economic Plan for Gloucestershire.","","","","New development needs to be delivered in those locations that are sustainable and /or have \nthe potential to be sustainable e.g. urban extensions and new settlements. Allocations should \nbe located where they can take advantage of existing and committed infrastructure – not \nwhere they need huge expenditure and the long lead in times that go with it.\nAs set out in the NPPF para 8 “Achieving sustainable development means that the planning \nsystem has three overarching objectives, which are interdependent and need to be pursued in \nmutually supportive ways (so that opportunities can be taken to secure net gains across each \nof the different objectives)”\nThe types of infrastructure required will depend on the location and what additional \ninfrastructure is required over and above existing. The Councils will need to assess what is \nrequired and produce an Infrastructure Delivery Plan (IDP) which is a “live” document that sets \nout in detail the strategic infrastructure required in order to deliver the growth planned for \nwithin the Local Plan.\nAuthorities should set out in an Infrastructure Funding Statement which infrastructure they \nintend to fund and detail the different sources of funding (see regulation 121A). This will need to \nbe subject to the Viability Assessment as part of the evidence base to support the SLP. It is \nnoted in paragraph 5.52 that the Council’s intend to produce an IDP and this will be available to \nsupport the next version of the SLP.\nHowever, it should be noted that development can only mitigate its own impact and cannot be \nrequired to address existing issues and shortfalls in provision. As such it would be \nunreasonable of the Councils and such an approach would fail the CIL tests if developers were \nrequired to pay to address existing deficiencies.\nSubstantial bus priority and cycle infrastructure is already in place that can be augmented to \nprovide further advantage for travel to/from Gloucester and other destinations in the SLP area \nincluding the Cheltenham Cyber Central development.","","","Yes","","The consultation document outlines six spatial options, and it is agreed that the final strategy \nwill be a combination of these options (as set out in paragraph 6.8 of the consultation \ndocument).\nIt is important to acknowledge that development on brownfield sites in the urban areas alone \nwill be insufficient to meet housing needs and that the most sustainable, and importantly \ndeliverable strategy will include a range and choice of sites both within and outside the green \nbelt.","No","As mentioned above it is considered that the final strategy will include elements from all of the \noptions as none of the options individually will deliver the scale of development required to \nsupport the sustainable strategy for the SLP. This is acknowledged in the consultation \ndocument at paragraph 6.8 and also in the SA paragraph E18.\nAt this stage the SA is unable to consider the specific scenarios without understanding the \ndetailed locations and the quantum of growth. The only consideration at this stage has been \nthe strengths and weaknesses of each option in principle. \nA degree of urban concentration will be included in the final strategy in line with the NPPF, \nhowever it should be noted at this stage that: \n“S4 (New Strategic Settlements) was identified as the best performing in relation to SA\nObjectives 6, 9, 10, 13 and 14 (pollution, housing, health, education and the economy) due to \nthis scenario having the greatest potential to deliver cohesive communities with new \ninfrastructure and services located in close proximity to new housing.”\n“S6 (Sustainable Transport) performs strongest against SA Objective 12 (transport and\naccessibility) due to its focus on growth alongside sustainable transport routes. This scenario \nalso performs relatively well in terms of accessibility to social infrastructure, such as schools \n(SA Objective 13) and employment opportunities (SA Objective 14).”\n“S2, S3 and S5 were not identified as the best performing against any SA Objectives,\nrelative to the other three scenarios, although each do have some strengths. S2 (Urban\nExtensions) and S3 (Urban Extensions avoiding the Green Belt) would focus growth in\nrelatively accessible areas close to urban areas, although potential major negative impacts\nhave been identified for S2 in terms of SA Objectives 4 and 7 (landscape and natural\nresources) and so S3 would be preferable in this regard. S5 (Rural Dispersal) could help to \nprovide a range of housing types and tenures and conserve the viability of smaller scale\nsettlements, however this scenario could lead to a major negative impact on SA Objective\n4 (landscape) due to this dispersed development towards potentially sensitive villages and\ntowns.”\nWe comment below on each of the 6 Scenarios:\nScenario 1 Urban Concentration\nWhilst an element of urban concentration, making the efficient use of brownfield land will be an \nelement of any strategy, the capacity does not exist to meet all housing needs and even if it \ndid it would not be appropriate as brownfield sites are notorious difficult to deliver, they are\ncomplex sites, and additional cost is required to bring forward schemes, e.g. land assembly and \nremedial works take longer than anticipated. Brownfield redevelopment of sites is more \nexpensive, which means that there are inevitably viability challenges which come from \ndeveloping brownfield sites, and this often has a consequence for local authorities who have to \nmake concessions on matters such as affordable housing provision, or other infrastructure \nimpacts. This scenario would focus development within Cheltenham and Gloucester.\nThe urban concentration option would necessitate building at increased density which \nappears to fly in the opposite direction of the recent changes to the NPPF of achieving welldesigned and beautiful places (B.I D.E.N.) - paragraphs 20, 96, and paragraph 128.\n“Planning policies and decisions should support development that makes efficient use of land, \ntaking into account:\na) the identified need for different types of housing and other forms of development, and the \navailability of land suitable for accommodating it;\nb) local market conditions and viability;\nc) the availability and capacity of infrastructure and services – both existing and proposed –\nas well as their potential for further improvement and the scope to promote sustainable travel \nmodes that limit future car use;\nd) the desirability of maintaining an area’s prevailing character and setting\n(including residential gardens), or of promoting regeneration and change; and\ne) the importance of securing well-designed and beautiful, attractive and healthy\nplaces.”\nWhilst paragraph 129 encourages a significant uplift in the average density of residential \ndevelopment in urban areas, as stated in paragraph 130, this should not be at the expense of \nthe character of the area. A judgment is required, a significant uplift in average residential \ndevelopment will be not necessarily be appropriate as it could be wholly out of character with \nthe existing area. \nThe DLUHC consultation “Strengthening planning policy for Brownfield development” published \non 13th February by DHLUC, comes within weeks of a revised NPPF which states that urban \ndensification should not happen if the uplift is out of character with the existing area.\nIt is considered that this scenario would be unable to meet housing needs and economic \ngrowth as there would be insufficient opportunities. In order to ensure the delivery of \nsustainable development to meet housing and economic needs a range and choice of sites is \nrequired, which will mean that elements of each of the scenarios are included.\nScenario 2 Urban Extensions\nThis scenario would include some loss of Green Belt land and would essentially be a \ncontinuation of the current strategy in the adopted JCS.\nUrban extensions are supported as is development in the Green Belt.\nIn the preparation of the JCS exceptional circumstances were demonstrated to remove land \nfrom the Green Belt in accordance with the NPPF.\nThe adopted JCS identified safeguarded land which may be required beyond the plan period \nof the JCS. However, safeguarded areas of land are not allocated and their inclusion in any \nfuture version of the Plan would need to be evaluated with other options.\nDevelopment Scenario 2 diagram illustrates an urban extension to the north of Tewkesbury on \nthe county boundary and although diagrammatic appears to be located in part in \nWorcestershire. This location also appears in Development Scenario 3 diagram. It is \nconsidered that there are sustainable options within the Vale that can accommodate the \nhousing needs without the need to utilise the Duty to Co-operate and for development to be \naccommodated in Worcestershire.\nThere are other opportunities that have been promoted to Tewkesbury Borough Council \nthrough the HELAA which are sustainable locations and vary in scale but can assist in meeting \nthe housing needs of the SLP and compliment a strategy that includes new settlements. These \nsites are:\n• Land West of Fiddington Lane (a planning application has been submitted on this site\nfor 30 dwellings ref 23/00930/OUT). Part of HELAA ref ASHC036. The site is \napproximately 3km east of the centre of Tewkesbury and 1.2km north of the hamlet of \nFiddington. The centre of Cheltenham is located c.10km south of the Site, and \nGloucester city centre c.16km south-west of the site. The land which is well related to \nexisting and proposed facilities and infrastructure comprise some 1.0ha. of agricultural \nland, surrounded by existing/consented development and lies to the west of \nFiddington Lane as shown on the plan below.\n• Land South East of Fiddington – comprising approximately 12.0 ha of land to the \nsouth east of Fiddington Lane (comprising a part of HELAA site ASHC035) is well \nrelated to existing and proposed facilities and infrastructure and would be suitable for \nallocation for residential development. An application is currently being prepared on \npart of this site for up to 140 dwellings and associated works including infrastructure, \nopen space and landscaping, with vehicular access from Fiddington Lane on land to \nthe south of Fiddington Lane, Ashchurch, Tewkesbury. The site is close to the recently \npermitted ’Fiddington’ development which is located to the north. \n• Land at Ty Gwyn (part of HELAA site ref ASH036) and lies adjacent to land west of \nFiddington. The site is adjacent to existing and consented development and is well \nrelated to existing infrastructure and proposed new facilities (see red line plan below).\n• Land south of Stoke Road, Bishops Cleeve (HELAA ref BIS018) and comprises \napproximately 9.40 hectares, is well related to the settlement of Bishops Cleeve and \nlocated opposite residential development on the north side of Stoke Road and Malvern \nBusiness Park. The HELAA considers that the site is potentially suitable for housing. \nThe HELAA also considers that site is potentially suitable for employment subject to \nfurther assessment in an Employment Land Study as part of the update to the SLP \nevidence base. (see red line plan below).\n• Land at Aston Fields, Ashchurch. (HELAA ref ASHC002) and comprises some 21.4 \nhectares and lies immediately adjacent to the built up area of Ashchurch with direct \npedestrian access to the railway station and is considered suitable for residential \ndevelopment (see red line plan below).\n• Land at Badgeworth – there are two new sites which are promoted to the HELAA (see \nCall for Sites submission forms and plans – Appendix 2):\n- Land off Cold Pool Lane which is approximately 10.9 hectares and can be \ndeveloped for housing, at 40 dph about 434 homes could be provided at 35 dph\nabout 380 homes could be provided. \n- Land of Badgeworth Lane comprises approximately 2.3 hectares and could \naccommodate at 40 dph about 90 homes and at 35 dph about 79 homes.\nScenario 3 Urban Extensions, avoiding the Green Belt\nIt is considered that urban extensions will form part of the strategy.\nScenario 4: New strategic settlement\nScenario 4 refers to three options land at Boddington within the Green Belt, land at Churcham \nbeyond the Green Belt and the Tewkesbury Garden Town. Tewkesbury Garden Town only \nmeets the needs of Tewkesbury, whereas land at Churcham (West of Severn), because of its \nlocation can meet the needs of Gloucester and Tewkesbury, but particularly Gloucester’s \nneeds. \nThe principle of new settlements is supported, both within the Green Belt and beyond. It is \nconsidered that following the implementation of the sites in the adopted JCS, there are \ninsufficient options to meet housing and employment needs in sustainable locations without \nthe need for new settlements. It is considered that it is now necessary to address the longerterm requirements and opportunities that arise from the inclusion of new settlements in the \nstrategy. It is necessary to make the decisions for the longer-term direction of development \nrather than a continuation of incremental growth.\nThe advantages of new settlements and urban extensions have long been acknowledged e.g.\nthe TCPA Best Practice in Urban Extensions (2007) both new settlements and urban \nextensions provide opportunities for concentrated rather than sprawling development. By \nvirtue of their scale, and if carefully designed and developed to produce integrated, ‘holistic’ \nsettlements, they can encourage and accommodate highly-sustainable patterns of living.\nScenario 5 Rural Dispersal\nAn objection is made to this scenario as this is the most unsustainable option. Growth would \nbe distributed across the rural areas at many of the existing settlements. This option would \nnot provide for the full number of new homes and economic needs, insufficient affordable \nhousing would be provided and increased journeys would be made to facilities and services \nand employment. Those journeys from dispersed locations would more likely be made using \nthe private car, resulting in congestion and increases in emissions etc. A series of smaller more \ndispersed development would not provide for the range and choice of house sizes, types and \ntenures and lead to pressure on limited rural services. Economies of scale cannot be achieved.\nThe locations would not necessarily be attractive to employers/businesses as they would be \nlocated away from the main centres and at some distance from the main transport arteries \nrunning through the SLP. Therefore, such locations may not provide a suitable range of \nemployment locations and types of employment.\nThat is not to say that there is no development to the villages – the strategy should be \nconsistent with the NPPF paragraphs 82- 84 and 88 to 89.\nScenario 6 Sustainable transport scenario\nThis option in principle is supported – as development will be along existing and potential high \nfrequency transport routes for public transport, cycling, walking etc. This should be implicit in \nthe preferred strategy that the Councils include in the version of the Local Plan. Such a \nstrategy would be consistent with the County Council in terms of the Local Transport Plan and \nalso consistent with the objectives of the NPPF.\nHowever, this scenario is not entirely consistent with the Local Transport Plan (LTP) as it only \nfeatures one sustainable transport corridor, whereas the spatial element of the LTP is \nstructured around a number of travel corridors, each of which has distinctive transport issues \nand opportunities set out in six spatial strategies entitled Connecting Places Strategy.\nParagraph 3.2.28 of the LTP states: \n“Gloucestershire plans to move towards an interchange model, which is multi-modal and \nencompasses; car share, community transport demand responsive services, bus, rail and bike \ninterchange facilities. These Transport Interchange Hubs will replace existing Park & Ride \nfacilities and consider additional locations. These hubs should be located on strategic rail or \nbus corridors where existing commercial super high frequency services (core super routes) \nand frequent services (high frequency) are in place. In addition, Strategic Interchange Hubs will \nbecome a vital transport strategy at interchange points on the highway network, e.g., at \nmotorway junctions, such as M5 J10 & J12 where the opportunities to remove traffic from the \nhighway network is greatest and the potential to attract commercial bus services is viable in \nthe long-term.”\nIn paragraph 4.2.1 the LTP identifies \n“Key routes in the CSV are the M5 linking north south and the A40 and A417 linking east west \nto provide access to the M4 corridor. The M5 and part of the A40/ A417 corridors are part of \nthe SRN and have also been identified within the Western Gateway Sub-National Transport \nBody (SNTB) as strategic links. The A38, A417 and the A40 make up a part of the newly formed \nMRN83 proposal which forms a middle tier of the country’s busiest\nand most economically important local authority ‘A’ roads. The MRN will sit between the SRN \nand the rest of the local road network.\nParagraph 4.2.2 The CSV CPS area accommodates almost half of Gloucestershire’s total\npopulation and has the highest proportion of working age people when compared to the \ncounty average. This is reflected by the high proportion of travel to work journeys that begin \nand end within the CPS area.”\nExtract from the LTP Figure STP (A) Strategic Transport Priorities in the Cheltenham and \nGloucester City Region\nIf the strategy included development based on the sustainable transport scenario, then this \nwould make a significant contribution to reducing carbon emissions which all the local \nauthorities in Gloucestershire have signed up to – i.e. to reduce carbon emissions from \ntransport in line with science-based targets to achieve net zero ambitions by 2050.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","","","[Q1.] The Strategic Local Plan (SLP) should cover a period of a minimum period of 15 years from the point of adoption. The LDS (July 2023) envisages that the Plan will be submitted to the Secretary of State for examination in April 2026.\nDLUHC Planning for the Future (January 2023) states that: “The average time taken from plan publication to adoption rose from an average of 450 days in 2009 to 815 days in 2019.”, is on average just over 2 years.\nThe JCS took nine years to prepare until it was adopted in 2017 and that required an immediate review which has not taken place.\nIt is considered that the SLP will not be adopted until 2028 at the earliest. Consequently, the plan period should be at least until 2043 in order to ensure at least 15yrs post adoption.. \nHowever, as outlined in paragraph 22 of the NPPF there are also circumstances where a longer plan period is appropriate. \n“Strategic policies should look ahead over a minimum 15 year period from adoption13, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery14.”\nThe PPG Plan Making in referring to paragraph 22 of the NPPF provides further guidance on the plan period including circumstances when it is appropriate to set out a vision for a longer period of time, the PPG states:\n“This policy requirement would need to be applied where most of the development arising from larger scale developments proposed in the plan will be delivered well beyond the plan period, and where delivery of those developments extends 30 years or longer from the start of the plan period.Where the policy applies, the authority will need to ensure that their vision reflects the longterm nature of their strategy for the plan or those larger scale developments. It is not anticipated that such visions would require evidence in addition to that already produced to support the plan.Paragraph: 083 Reference ID: 61-083-20211004”\nGiven that the SLP is to consider new settlements and/or significant urban extensions as part of the strategy then there is a clear justification for a longer plan period, e.g. to 2045 andbeyond. It is noted that the Sustainability Appraisal at paragraph 3.2.1 states that “the CGT Councils have prepared a draft vision for the area in 2045” and also in paragraph 3.2.3\nWhatever plan period is chosen there is a need for evidence to cover the whole plan period, it would therefore be sensible to ensure the evidence covers a longer time frame as well.\n\n[Q8.] The mandatory minimum of 10% BNG has only been introduced for all major planning applications in February 2024. It is considered that the Council’s should not deviate from the Government’s requirement for 10% biodiversity net gain as set out in the Environment Act. \nNew government guidance has advised Council’s preparing plans that they should not seek a higher percentage of BNG from developers than the statutory 10% unless justified. This was included in the new PPG.\nThe PPG states that plan-makers “should not seek a higher percentage than the statutory objective of ten per cent biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.”Paragraph: 006 Reference ID: 74-006-20240214\nLocal Plans should not include policies which are incompatible with the national system, for example by applying BNG to exempt categories of development.\nThe PPG states:\n\"Plan-makers should be aware of the statutory framework for biodiversity net gain, but they do not need to include policies which duplicate the detailed provisions of this statutory framework. It will also be inappropriate for plans or supplementary planning documents to include policies or guidance which are incompatible with this framework, for instance by applying biodiversity net gain to exempt categories of development or encouraging the use of a different biodiversity metric or biodiversity gain hierarchy.”\nThere are significant additional costs associated with biodiversity gain, which should be fully accounted for in the Council’s viability assessment. The PPG on Viability has also recently been updated adding BNG as a material consideration for viability assessments.\nIt is important that BNG does not prevent, delay or reduce housing delivery. \nIt is also important to note that large and complex sites where the development is phased, that. \"The biodiversity gain objective of at least 10% net gain applies to the overall development (not each phase). The contribution of each phase to achieving net gain may vary, providing a net gain of at least 10% is achieved for the overall development at the time of its completion.”Paragraph 056 Reference ID: 74-056-20240214. \n\n[Q15.] It is considered that the provision of sites for traveller communities relates to a bespoke need which can best be accommodated on specific sites, which enables access for HGV and storage of vehicles and maintenance of equipment.\nParagraph 8.14 of the GTAA Report Nov 2022 states:\n“Due to the need for both accommodation space and space for storage and maintenance of very large equipment, the size and space required for a Showpeople plot needs to much larger than a standard Gypsy and Traveller pitch.”\nSuch uses are not necessarily compatible with large developments of housing. \nThe GTAA Report (November 2022) concludes in para 8.5 that:\n“There is general consensus that smaller sites, yards and moorings are preferred by Gypsy, Traveller, Showpeople and boat dweller communities due to better management and maintenance of provision and security.” (my emphasis)\nThe GTAA Report does not make any recommendations to include sites for the traveller community on large developments for housing and/or employment.\nParagraph 8.7 outlines a number of factors which could be considered in terms of identifying broad locations for new permanent sites.\nThe planning policy conclusions at para 8.23 are:\n“As well as quantifying accommodation need, the study also makes recommendations on other key issues including:\nPlanning policy:\n• Implement corporate policy to provide negotiated stopping arrangements to address unauthorised encampments for set periods of time at agreed locations.\n• To liaise with owners of the sites and yards to determine how they could expand the number of pitches to meet the family’s accommodation needs.\n• To work closely with CRT and CCT to meet the needs of the boat dwellers and constant cruisers across the study area.\n• To liaise with marinas and boat yards in the area to see which could accommodate more permanent moorings (including converting some of their leisure moorings to permanent).\n• To consider how the accommodation needs can be met by expanding existing provision and/or providing new sites, yards or moorings.\n• To consider alternative options for developing new sites, yards and moorings such as developing them on a cooperative basis e.g. community land trust, shared ownership, or small sites owned by a local authority but rented to families for their own use.\n•To consider alternative site funding mechanisms such as: site acquisition funds; loans for private site provision through Community Development Financial Institutions; and joint ventures with members of the Gypsy and Traveller, Showpeople and boat dweller communities.\n• Prior to action being taken against sites or yards being used without planning permission, the local authorities, in partnership with landowners, occupants and relevant agencies (e.g. Showmen’s Guild and National Federation of Gypsy Liaison Groups, CRT, CCT, and NBTA), to review its current, historic and potential planning status, and review the most effective way forward.\n• To consider safeguarding Gypsy and Traveller site and Travelling Showpeople yards with permanent planning permission for their current use unless it can be demonstrated that they are no longer needed to meet identified need.\n• The population size and demographics of the Gypsy, Traveller, Travelling Showpeople and boat dweller communities can change rapidly. As such, their accommodation needs should be reviewed every 5 to 7 years.”\nThe Councils have not considered the GTAA report and neither have they considered the effect on viability, market forces and delivery. As such an inflexible approach in policy terms could result in a reduced speed of delivery or a sterilised site/part of a site crucial to the development strategy.\nFurthermore, the approach needs to be consistent with the government guidance – Planning Policy for Traveller sites - there is no reference in the guidance to allocations being included on strategic sites.\n\n[Q26.] Sites or routes for longer term infrastructure projects should be safeguarded but kept under review as the safeguarded land may or may not be needed. \n\n[Q29.] In order to meet housing needs in full and to support economic growth etc for the reasons set out above, the housing requirement should be increase from the Standard Method minimum housing need. In order to provide a range and choice of sites and to ensure a 5-year housing supply, the strategy for the SLP should be based on the following:\n- Previously developed land in urban locations\n- Urban extensions within and outside the Green Belt on existing and potential high frequency public transport \nThese scenarios alone will be insufficient to meet housing needs and therefore the strategy will need to include sustainably located new settlements which will complement the range and choice of sites in sustainable locations\n\n[Q31.] Monitoring of the Plan is critical for a number of reasons and in terms of the review of the plan. As set out in the PPG Plan Making in determining whether a plan or policies within a plan should \nbe updated, the success of policies against indicators in the Development Plan should be set out in the Councils Monitoring Report                                                       \n\n\nOur submission comprises:\n\nCompleted SLP Response Form with reference to the following sites in Tewkesbury Borough: \n•\tLand West of Fiddington Lane \n•\tLand South of Fiddington \n•\tLand at Ty Gwyn, Fiddington \n•\tLand south of Stoke Road, Bishops Cleeve \n•\tLand at Aston Fields, Ashchurch \n•\tLand off Cold Pool Lane, Badgeworth \n•\tLand off Badgeworth Lane, Badgeworth \n\nThe SLP submission is supported by the following appendices: \n•\tAppendix 1: Economic Overview and Housing Need Report \n•\tAppendix 2: Call for Sites Submission forms for Land off Cold Pool Lane, Badgeworth and Land of Badgeworth Lane, Badgeworth "]
["Planning agent or developer","Robert Hitchins Ltd","","Paragraph 2.4 of the consultation reflects the NPPF paragraph 20 in terms of what strategic \npolicies should address in the plan. \n“Strategic policies should set out an overall strategy for the pattern, scale and design quality \nof places (to ensure outcomes support beauty and placemaking), and make sufficient \nprovision11 for:\na) housing (including affordable housing), employment, retail, leisure and other commercial \ndevelopment;\nb) infrastructure for transport, telecommunications, security, waste management, water \nsupply, wastewater, flood risk and coastal change management, and the provision of minerals \nand energy (including heat);\nc) community facilities (such as health, education and cultural infrastructure); and\nd) conservation and enhancement of the natural, built and historic environment, including \nlandscapes and green infrastructure, and planning measures to address climate change \nmitigation and adaptation.”\nSection 19(1B) - (1E) of the Planning and Compulsory Purchase Act 2004 sets out that each \nlocal planning authority must identify their strategic priorities and have policies to address \nthese in their development plan documents (taken as a whole).\nIt is essential that cross boundary matters are considered as strategic policies. Cross \nboundary matters should include the review of the Green Belt, provision of housing and \nemployment needs (as previously in the adopted JCS) and infrastructure.\nIt is noted that the intention is for the SLP to include separate sections that will cover each \nlocal authority area only providing “locality policies” that address issues and opportunities \nspecific to that area. \nThrough the SLP it should be clear which policies are strategic and which are non-strategic as \nset out in the NPPF paragraph 21. The PPG states:\n“…Where a local plan contains both strategic and non-strategic policies, the non-strategic \npolicies should be clearly distinguished from the strategic policies…”. Paragraph: 002 \nReference ID: 61-002-20190315\nRevision date: 15 03 2019","Non-strategic policies provide more detailed policies for a specific area(s), neighbourhoods or \ntypes of development. Paragraph 28 provides guidance on what matters can be covered by \nnon- strategic policies.","Yes","In general, the Vision is supported. Through the objectives the Vision should be capable of \nbeing monitored.\nThe first paragraph of the Vision seems only to apply to larger scale developments, surely \nharnessing the opportunities for “green growth” etc should apply throughout the plan area.\n“Green Growth” should be defined in the glossary. The OECD definition of green growth and \nsustainable development is:\n“Green Growth means fostering economic growth and development, while ensuring that \nnatural assets continue to provide the resources and environmental services on which our \nwell-being relies.”\nFurthermore, it is not clear who will deliver “green growth” or how it will be delivered. Maybe it \nshould say “Working with our partners…”\nThis point also applies to the second paragraph of the Vision.\nThe third paragraph of the Vision is supported as whilst it acknowledges that there is a focus \non making the best possible use of brownfield sites etc, it also acknowledges that there is a \nneed for comprehensive planned new development to ensure housing and employment needs \nare met in sustainable locations. The point is that this will involve building on greenfield sites. \nThere is a need to provide a range and choice of sites and clearly not all needs can be met in \nthe urban areas on brownfield sites.\nThe fourth paragraph is supported i.e. “Growth in sustainable locations will have enabled the \nprovision of healthy, accessible and walkable neighbourhoods, the promotion of active travel \nand sustainable travel, and provision of new transport systems that work for local people.”\nThe fifth paragraph should be split into separate points:\nI.e. “Growth will have been supported by the provision of a range of essential digital, transport, \ncommunity and other infrastructure.”\nAnd then “Equally, alongside conserving the area’s special landscapes and its attractiveness \nas a place to visit, a network of interconnected green spaces and waterways will have secured a high-quality environment for people and nature. Together with necessary retention and \nmanagement of existing sports and leisure facilities, this will have unlocked opportunities for \nhealthy lifestyles, inclusive access to sport and recreation, active flood risk management and \nimprovements to biodiversity.”","No","The objectives are set out under 8 themes. The objectives should be capable of monitoring in \norder to assess whether the plan is delivering in accordance with the NPPF. \n“Meeting the challenges of climate change”\nObjective 1 should be redrafted, as currently drafted it duplicates part of Objective 5 as it \nrefers to the delivery of zero and low carbon development. The achievement of BNG is a \nseparate issue and should reflect current policy guidance. E.g. “Maintain and improve the \nnatural and built environment including biodiversity, landscape, green Infrastructure and \nwaterways by ensuring new development achieves high-quality design standards and \nconserves and enhances the natural, historic, cultural and landscape assets”.\n“Delivering a wide choice of homes that meet the needs of our communities.”\nAdded to this should be \"which supports economic growth\"\nObjective 1 “Delivering sufficient new homes in the right places to meet the needs…”\nThis should read meeting housing needs in full. It is not clear what “sufficient” means it should \nbe sufficient to meet needs. For clarity the objective should be redrafted to read to meet \nneeds in full. \nIn order to ensure sustainable growth in Cheltenham, Gloucester and Tewkesbury, especially to \naddress the issue of an ageing population, younger people and people of working age need to \nbe retained and attracted to the area. One way of doing this is to provide a sufficient supply of \nhousing. \nBuilding strong, competitive and sustainable urban and rural economics\nThe objective should also include to support the growth in total employment across the SLP \narea. (Tewkesbury has one of the strongest performances in the south west being in the top 10 \nwhereas Cheltenham is one of the lowest).","The most effective way that SLP should address climate change is to plan for sustainable \ndevelopment, i.e. development in those locations that have the greatest opportunity to deliver \nand support development. Policies should not seek to go beyond national policy, instead they \nshould be consistent with the NPPF and government guidance. (see response below to \nQuestion 7).","Any measures and standards should be consistent with the Government’s policy. A Written \nMinisterial Statement was issued by Lee Rowley on 13th December 2023 which states that: \n“For a number of years, the plans of some local authorities have sought to go further than \nnational standards in terms of such efficiency for new-build properties. Equally, there is a \nlegitimate consideration for the Government to want to strike the best balance between \nmaking progress on improving the efficiency and performance of homes whilst still wanting to \nensure housing is built in sufficient numbers to support those who wish to own or rent their \nown home.\nIn 2015, in reference to an uncommenced provision in the Deregulation Act 2015 which \namended the Planning and Energy Act 2008, a written ministerial statement (WMS) (HC Deb, \n25 March 2015, vol 584, cols 131-138WS) stated that until that amendment was commenced, \nlocal plan policies exceeding minimum energy efficiency standards should not go beyond level \n4 of the Code for Sustainable Homes. Since then, the introduction of the 2021 Part L uplift to \nthe Building Regulations set national minimum energy efficiency standards that are higher than \nthose referenced in the 2015 WMS rendering it effectively moot. A further change to energy \nefficiency building regulations is planned for 2025 meaning that homes built to that standard \nwill be net zero ready and should need no significant work to ensure that they have zero \ncarbon emissions as the grid continue to decarbonise. Compared to varied local standards, \nthese nationally applied standards provide much-needed clarity and consistency for \nbusinesses, large and small, to invest and prepare to build net-zero ready homes.\nThe improvement in standards already in force, alongside the ones which are due in 2025, \ndemonstrates the Government’s commitment to ensuring new properties have a much lower \nimpact on the environment in the future. In this context, the Government does not expect \nplan-makers to set local energy efficiency standards for buildings that go beyond current \nor planned buildings regulations. The proliferation of multiple, local standards by local \nauthority area can add further costs to building new homes by adding complexity and \nundermining economies of scale. Any planning policies that propose local energy efficiency \nstandards for buildings that go beyond current or planned buildings regulation should be \nrejected at examination if they do not have a well-reasoned and robustly costed rationale that \nensures:\nThat development remains viable, and the impact on housing supply and affordability is \nconsidered in accordance with the National Planning Policy Framework.\nThe additional requirement is expressed as a percentage uplift of a dwelling’s Target \nEmissions Rate (TER) calculated using a specified version of the Standard Assessment \nProcedure (SAP).\nWhere plan policies go beyond current or planned building regulations, those polices should \nbe applied flexibly to decisions on planning applications and appeals where the applicant can \ndemonstrate that meeting the higher standards is not technically feasible, in relation to the \navailability of appropriate local energy infrastructure (for example adequate existing and \nplanned grid connections) and access to adequate supply chains.\nTo be sound, local plans must be consistent with national policy – enabling the delivery of \nsustainable development in accordance with the policies in the National Planning Policy \nFramework and other statements of national planning policy, including this one.” (my\nemphasis)\nIf the Councils were to set their own standards there is a real risk of adding to the complexity \nof the approach of policy, regulations and standards that housebuilders are already expected \nto comply with. There is also a risk to the viability and consequently the delivery of sites.\nThe key to success is standardisation and avoidance of individual Councils specifying their \nown policy approach, which undermines economies of scale for product manufacturers, \nsuppliers and developers.","","No","","","The provision of key services and facilities within easy reach of development, depends on the \nprovision of existing services, capacity in schools etc and whether it can be justified and\nwhether it is viable depending on the level of development to support such facilities. ","","","No","It is noted that the Councils have not yet prepared an update of the Local Housing Needs \nAssessment (2020). This document reflected the standard method applicable at the time. \nThe consultation document acknowledges that since then, the figures have changed, (every \nyear the figures are updated due to the affordability ratio which is published in March).\nThe Standard Method figure changes annually until the Local Plan is submitted for Examination. \n(PPG Paragraph: 008 Reference ID: 2a-008-20190220.) The Government have reaffirmed the \nuse of the standard method in the NPPF Dec 2023, the standard method is the starting point. \nHowever, the standard method does not generate a housing requirement, other factors \nneed to be considered, as set out in the PPG.\n“Assessing housing need is the first step in the process of deciding how many homes need to \nbe planned for. It should be undertaken separately from assessing land availability, \nestablishing a housing requirement figure and preparing policies to address this such as site \nallocations”. PPG Paragraph: 001 Reference ID: 2a-001-20190220\nAn insufficient number of homes have been delivered nationally to meet the need for 300,000 \nhomes per annum, with only 232,816 built in 2021/22. The necessary consequence of this is \nthat the need for housing will have increased regardless of the results of the Government’s \nstandard method.\nIn this context, it remains the case that local authorities need to be aiming above the minimum \nlocal housing need to address housing needs in full and to deliver the 300,000 homes per \nannum sought by the Government. With the standard method still providing a minimum target \nbelow 300,000, it is inevitable that we will continue to see a shortfall in national housing \ndelivery without this.\nAs stated above, the Standard Method identifies a minimum housing need figure, it does not \nproduce a housing requirement (PPG Housing and Economic Needs Assessments paragraph\n002 Reference ID: 2a-002-20190220).\nThe PPG outlines the circumstances when it might be appropriate to plan for a higher housing \nneed figure than the standard method indicates:\n“The standard method for assessing local housing need provides a minimum starting point in \ndetermining the number of homes needed in an area. It does not attempt to predict the \nimpact that future government policies, changing economic circumstances or other factors \nmight have on demographic behaviour. Therefore, there will be circumstances where it is \nappropriate to consider whether actual housing need is higher than the standard method \nindicates.\nThis will need to be assessed prior to, and separate from, considering how much of the overall \nneed can be accommodated (and then translated into a housing requirement figure for the \nstrategic policies in the plan). Circumstances where this may be appropriate include, but are \nnot limited to situations where increases in housing need are likely to exceed past trends \nbecause of:\n• growth strategies for the area that are likely to be deliverable, for example where \nfunding is in place to promote and facilitate additional growth (e.g. Housing Deals);\n• strategic infrastructure improvements that are likely to drive an increase in the homes \nneeded locally; or\n• an authority agreeing to take on unmet need from neighbouring authorities, as set out \nin a statement of common ground;”\nPara 010 Reference ID:2a 010-20201216\nThe current standard method for each of the LPAs is shown in the Table on page 23 of the \nconsultation document and is based on the March 2023 affordability ratio.\nWhen compared with the adopted JCS (2017) which has a housing requirement of 35,175 \ndwellings over a 20-year period, which is 1,759 dwellings per annum, the SLP is now proposing \nonly a slight increase in the number of dwellings to 1,785 dwellings per annum, i.e. an increase \nof only 26 dwellings per annum. This is not consistent with the NPPF (Dec 2023) paragraphs\n60 and 61 as set out below.\nParagraph 60 states that in order to support the Government’s objective of significantly \nboosting housing supply, it is important that sufficient amount and variety of land can come \nforward where it is needed.\n“The overall aim should be to meet as much of an area’s identified housing need as possible, \nincluding with an appropriate mix of housing types for the local community.”\nThe outcome of the standard method is advisory as stated in para 61 of the NPPF (Dec 2023) \nstates:\n“The outcome of the standard method is an advisory starting-point for establishing a housing \nrequirement for the area (see paragraph 67 below). There may be exceptional circumstances, \nincluding relating to the particular demographic characteristics of an area25 which justify an \nalternative approach to assessing housing need; in which case the alternative approach \nshould also reflect current and future demographic trends and market signals. In addition to \nthe local housing need figure, any needs that cannot be met within neighbouring areas should \nalso be taken into account in establishing the amount of housing to be planned for.”\nNPPF para 67 states:\n“Strategic policy-making authorities should establish a housing requirement figure for their \nwhole area, which shows the extent to which their identified housing need (and any needs that \ncannot be met within neighbouring areas) can be met over the plan period. The requirement \nmay be higher than the identified housing need if, for example, it includes provision for \nneighbouring areas, or reflects growth ambitions linked to economic development or \ninfrastructure investment. Within this overall requirement, strategic policies should also set \nout a housing requirement for designated neighbourhood areas which reflects the overall \nstrategy for the pattern and scale of development and any relevant allocations33 “ (my \nemphasis)\nThe consultation document acknowledges that the standard method is the minimum housing \nneed figure and that this figure provided by the government is the starting point. In paragraph \n5.17 and 5.18 the consultation document reports the NPPF advice referred to above, but then \nconcludes “our current evidence exploring economic growth forecasts and their relationship \nto the need for new homes have concluded there is currently no justification for amending the \nneeds figures, this evidence is required to be kept under review.”\nHowever, the evidence that the consultation relies upon is out of date, as there is no uptodate \nLocal Housing Need Assessment or Economic Assessment (LHNA) available to support the \nconsultation, both are dated 2020. It is noted that a new LHNA is being undertaken.\nIt is noted in the Gloucestershire Statement of Common Ground that it has been agreed \n(February 2022),\n\"Housing Agreement \n7 The Parties agree that making provision to meet the full range of housing needs in the right \nplaces at the right time is a vital role for the Gloucestershire authorities. The parties \nacknowledge this may result in one local authority accommodating the identified needs of \nanother local authority, particularly where a local authority is unable to accommodate all of the \nidentified need and where accommodating need in a neighbouring authority represents the \nmost sustainable form of development.”\n8 That the district councils \"agree to deliver housing where it promotes sustainable patterns of \ngrowth in Gloucestershire and is designed to respect the local character and address \npotential impacts on existing communities.”\nIt is considered that there is a justification for increasing the housing requirement above the \nminimum need provided by the standard method. In particular addressing the current housing \ncrisis, meeting housing need, providing a range and choice of sites, providing affordable \nhousing and providing homes to support economic growth.\nCheltenham, Gloucester and Tewkesbury have seen significant growth in the number of people \naged 65+ over the last decade. While past change in Cheltenham and Gloucester has been \ndriven largely by natural change, in Tewkesbury internal migration has played a big role in \ngrowing the population.\nWith all three areas projected to continue experiencing significant growth in its older \npopulation, younger people and people of working age need to be attracted to the local \nauthority. One way of doing this is through providing attractive and suitable housing options.\nOver the last seven years (from 2015-2022), Tewkesbury’s labour market has performed \nextremely well. In relative terms, it has seen the second highest employment growth of all \nSouth West local authorities. \nIf the positive trend of strong jobs growth continues in Tewkesbury, more people are likely to \nbe attracted to the area and this will make it even more important to ensure the housing offer \ncan meet the likely increase in demand for properties. For Cheltenham and Gloucester, jobs \ngrowth is equally as important in moving both areas closer to regional and national trends. If \nthey are successful in improving the performance of their respective labour markets, it is not \nunreasonable to expect more people to want to move to the area, which would increase \nhousing demand. Indeed, significant growth is anticipated as Cheltenham’s reputation as the \ncyber capital of the UK is established. As set out in Cheltenham’s Corporate Plan, Key Priority 1 \nCyber Cheltenham.\n“With a significant development site next to GCHQ, in a highly accessible location with great \nconnectivity, the opportunity exists to create a destination of global significance.”\nThere will be “spin offs” in terms of employment and other opportunities arising.\nBetween 2012 and 2022, the affordability ratios in Cheltenham (8.94), Gloucester (7.70) and \nTewkesbury (8.68) increased. The affordability ratios in the LPAs are currently below the ratio \nin the South West (9.41) but above the ratio in England (8.28), with the exception of Gloucester. \nMortgage providers will typically only lend 4-4.5 times a persons’ salary showing that housing \nin all areas is becoming increasingly unaffordable for many households. To put the affordability \nissue into perspective, as of 2022 the median house price in Tewkesbury is £300,000 and the \nmedian workplace-based wage is £34,544.\nHousing delivery has been strong in Tewkesbury, which has coincided with an increase in net \ninternal migration. For this to continue, a good supply of housing sites needs to be provided. \nCheltenham and Gloucester have both been consistently below target, which makes it vital for \nhousing delivery to increase in the long-term. Simply basing housing need on the Standard \nMethod (including the projections which reflect past under delivery) will not significantly boost \nsupply.\nHousing affordability in Cheltenham, Gloucester and Tewkesbury is a serious issue, for people \nearning median salaries and those in the lowest 25% of earners. This situation is unlikely to \nimprove unless more homes can be delivered.\nBoth Cheltenham and Gloucester have performed poorly in terms of past housing delivery, \nwhich makes it even more important to set ambitious housing targets. To address the trend of \nan ageing population which is projected in all three areas up to 2041 and also to improve \nlabour market performance, consideration needs to be given to increasing the standard\nmethod figure. The Issues and Options Consultation document states that the most recent \n2020 Housing Needs Assessment will be updated later in the SLP process. Once this new \nevidence is published and has been reviewed, a suggested housing target will be provided. The \nsame comment applies to the employment land requirements, which should also be updated \nlater in the SLP process. \nFrom our analysis it is considered that simply going with the standard method for housing \nneed in Cheltenham, Gloucester and Tewkesbury is not enough, the Standard method does not \nproduce a housing requirement. There is justification for a higher figure for housing i.e. above \nthe minimum figure generated by the standard method.\nThis is set out in Appendix 1 and should be kept under review until the Local Plan is submitted \nfor examination.","No","It is considered that when the opportunities and constraints are reviewed that there are sites \nin highly sustainable locations that are available, and which can assist the Council’s in meeting \na higher housing figure in the plan period. There is no reason why the housing requirement \nshould be constrained.","Yes","NPPF paragraph 63 states that, “the size, type and tenure of housing needed for different \ngroups in the community should be assessed and reflected in planning policies. These groups \nshould include (but are not limited to) those who require affordable housing; families with \nchildren; older people (including those who require retirement housing, housing-with-care and \ncare homes); students; people with disabilities; service families; travellers28; people who rent \ntheir homes and people wishing to commission or build their own homes29\n.”\nClearly the plan needs to provide a range and choice of sites, in terms of house types, sizes \nand tenure.\nIt can be seen from the analysis in Appendix 1 that the proportion of homes that were owned \nwith a mortgage or loan decreased in every area between 2011 and 2021, with Gloucester \nexperiencing a decline from 38% to 32.3%. Additionally, the proportion of homes that were \nprivately rented increased at similar rates in every area.\nThere is a significantly higher proportion of homes that are owned outright in all areas by those \naged 65 and over compared to the younger population (those aged 64 and under).\nAffordability is also an issue – for example, in 2012, the affordability ratio in Cheltenham was \n5.81. By 2022, the affordability ratio in the local authority had increased to 8.94. As of 2022, the \nmedian affordability ratio in Cheltenham was higher than the ratios seen in Gloucester (7.70), \nTewkesbury (8.68) and England (8.28) but was below the ratio in the South West (9.41). \nTo put the affordability ratios into perspective, as of 2022 the median house price in \nTewkesbury is £300,000 and the median workplace-based wage is £34,544. Mortgage \nproviders will typically only lend 4-4.5 times a persons’ salary. Therefore, the affordability ratio \nin all areas presented in Figure 4.1 is significantly above the 4-4.5 times salary to house price \nratio.\nAs of 2022, the typical lower quartile house price in Tewkesbury is £230,000 and the lower \nquartile workplace-based earnings are £25,886, highlighting how difficult it is for the lowest \n25% of earners to get a foot on the property ladder.\nAll of which points to need to increase the supply of housing for all.","","The GTAA Report provides advice to the local authorities.","The GTAA Report provides the advice.","The Gloucestershire Statement of Common Ground (February 2022) states at paragraph 10 \n\"10. The Parties agree it is important to take advantage of the location and characteristics of \nGloucestershire and its economic strengths. The parties will take a pro-active role in creating \nthe conditions within which existing and potential new employers can flourish, with a particular \nemphasis on spatial planning. Action will be taken to identify the appropriate scale and \ndistribution of employment allocations, with the potential value of strategic sites to serve a \nlarger area fully considered.\n11. Parties agree that collaboration is essential to deliver a purposeful Gloucestershire \napproach to inward investment and business retention.”\nThe Gloucestershire Economic Needs Assessment (August 2020) needs to be updated – this \nwas prepared at the time of the COVID 19 pandemic and considered the potential impact on \nGloucestershire’s economy. Paragraph 5.32 of the consultation document acknowledges the \nneed to update the assessment – this will be critical in terms of providing the growth needed \nover the plan period.\nAny evidence will need to take account of ‘market signals’, which includes what changes in \nskills are likely to be needed; how many people will there be to take up jobs; and whether \nexisting employment land meets the needs of existing businesses or people looking to set up \nbusinesses in the area.\nThe SLP needs to recognise and support the delivery of the Gloucestershire Economic \nStrategy produced by Gloucestershire County Council and the GFirst LEP – due for approval in \nearly 2024. This strategy supports the county’s economic priorities for the next 5 years but \nimportantly for the SLP provides a long term view to 2050.\nThe introduction to the Economic Strategy states:\n“To meet the needs of the economy, the county requires a robust long-term vision for \neconomic growth and prosperity supported by a countywide spatial strategy. This will provide \nconfidence to businesses and communities about how the county will grow. It will sustain a \nquality employment offer within the county and improve ease of access to the opportunities \nprovided across the region. Over the next 30 years, the county will need to balance the need \nfor additional infrastructure, affordable housing, the need to combat climate change, increase \nits working age population while sustainably managing its natural and historic environment. To \nachieve this, it is important think strategically and on a countywide basis.”\nGloucestershire has an ageing population and high housing costs which have implications for \nthe workforce with the number of jobs expected to exceed the number of working age people \nby 2035. (Gloucestershire Economic Strategy Draft – July 2023)\nThe intended outcomes of the Gloucestershire Economic Strategy focus around “Place\" and \n“People.” E.g. the county growth strategy delivers vibrant delivers vibrant and sustainable \ncommunities and the working age population is increased to rebalance our economy”\nhttps://www.gloucestershire.gov.uk/council-and-democracy/growgloucestershire/developing-a-new-economic-strategy-for-gloucestershire/intendedoutcomes/\nThe SLP needs to consider the implications of the Gloucestershire Economic Strategy which \nidentifies core propositions, and which underlines the importance of taking a strategic \napproach to planning new residential and employment growth, focused in areas that are most \nsustainable in terms of strategic environmental and social considerations.\nThe Gloucestershire Local Transport Plan (LTP) is also key to formulating the strategy.\nThe LTP 2020-2041 acknowledges that M5 is key for employment growth. Para 4.2.2 states: \n“The CSV CPS area accommodates almost half of Gloucestershire’s total population and has \nthe highest proportion of working age people when compared to the county average. This is \nreflected by the high proportion of travel to work journeys that begin and end within the CPS \narea.”\nThe following paragraphs from the LTP clearly demonstrate the role of the SLP area in terms of \nfunction and relationship.\nPara 4.2.4 states:\n“Growth proposals identified in the adopted JCS and Local Industrial Strategy will significantly \nincrease the CPS area’s population and range of employment opportunities offered, with even \nmore growth expected through the JCS review. This will result in more trips within this area \nand will require careful management to reduce congestion and limit environmental impacts. \nThe JCS aims to locate jobs near to the economically active population thus minimising outcommuting and reducing carbon emissions from car use and instead promoting sustainable \ntransport by improving opportunities for public transport, walking and cycling by making \nroutes more convenient, safe and attractive.\nPara 4.2.5 states:\n“To manage the impacts of growth, the JCS is supported by a comprehensive Transport \nStrategy that details a recommended mitigation package to enable the delivery of the \nproposed development. The schemes detailed in the Transport Strategy are echoed in this \nLocal Transport Plan.”\nParagraph 4.2.6 states:\nIn line with the JCS, GFirst LEP’s Strategic Economic Plan (SEP) supports delivery of \nemployment land around Junctions 9, 10 and 11 of the M5 area. A number of transport related \nproposals for the county will enable the planned growth to be achieved through the release of \nthis employment land.\nParagraph 4.2.7 states:\n“The Local Industrial Strategy identified the Gloucestershire area as a key location for cyber \nresilience alliance – cyber security. This will generate high level skilled employment \nopportunities for which people may be prepared to commute some distance. Gloucestershire \nwill need to support growth in this sector by providing the necessary transport infrastructure \nto facilitate movement through and within the county.”\nIn summary the interaction between employment and housing is critical to sustainable growth. \nAn increase in the number of jobs can it itself generate a requirement for additional housing. It \nmay be that a higher housing figure is needed for economic reasons and a higher housing \nnumber is also needed for housing delivery reasons.","One of the three objectives of the NPPF is an economic objective –\n“to help build a strong, responsive and competitive economy, by ensuring that sufficient land \nof the right types is available in the right places and at the right time to support growth, \ninnovation and improved productivity; and by identifying and coordinating the provision of \ninfrastructure;”\nParagraph 85 of the NPPF: \n“Significant weight should be placed on the need to support economic growth and \nproductivity, taking into account both local business needs and wider opportunities for \ndevelopment. The approach taken should allow each area to build on its strengths, counter\nany weaknesses and address the challenges of the future.”\nParagraph 87\n“Planning policies and decisions should recognise and address the specific locational \nrequirements of different sectors. This includes making provision for clusters or networks of \nknowledge and data-driven, creative or high technology industries; and for storage and \ndistribution operations at a variety of scales and in suitably accessible locations.”\nThe SLP should seek to accommodate employment needs in the most sustainable locations, \naccessible well severed by public transport.\nA range and choice of employment sites to meet requirements will be essential.\nThe SLP should be prepared to reflect the Strategic Economic Plan for Gloucestershire \nhttps://www.gloucestershire.gov.uk/media/wq4ph3zh/glos-5-year-econcomic-strategy.pdf\nThe SLP needs to recognise the implications of failing to address housing needs when there is \na housing crisis, will have adverse implications for the social and economic consequences for \nthe SLP and undermine the objectives of the Strategic Economic Plan for Gloucestershire.","","","","New development needs to be delivered in those locations that are sustainable and /or have \nthe potential to be sustainable e.g. urban extensions and new settlements. Allocations should \nbe located where they can take advantage of existing and committed infrastructure – not \nwhere they need huge expenditure and the long lead in times that go with it.\nAs set out in the NPPF para 8 “Achieving sustainable development means that the planning \nsystem has three overarching objectives, which are interdependent and need to be pursued in \nmutually supportive ways (so that opportunities can be taken to secure net gains across each \nof the different objectives)”\nThe types of infrastructure required will depend on the location and what additional \ninfrastructure is required over and above existing. The Councils will need to assess what is \nrequired and produce an Infrastructure Delivery Plan (IDP) which is a “live” document that sets \nout in detail the strategic infrastructure required in order to deliver the growth planned for \nwithin the Local Plan.\nAuthorities should set out in an Infrastructure Funding Statement which infrastructure they \nintend to fund and detail the different sources of funding (see regulation 121A). This will need to \nbe subject to the Viability Assessment as part of the evidence base to support the SLP. It is \nnoted in paragraph 5.52 that the Council’s intend to produce an IDP and this will be available to \nsupport the next version of the SLP.\nHowever, it should be noted that development can only mitigate its own impact and cannot be \nrequired to address existing issues and shortfalls in provision. As such it would be \nunreasonable of the Councils and such an approach would fail the CIL tests if developers were \nrequired to pay to address existing deficiencies.\nSubstantial bus priority and cycle infrastructure is already in place that can be augmented to \nprovide further advantage for travel to/from Gloucester and other destinations in the SLP area \nincluding the Cheltenham Cyber Central development.","","","Yes","","The consultation document outlines six spatial options, and it is agreed that the final strategy \nwill be a combination of these options (as set out in paragraph 6.8 of the consultation \ndocument).\nIt is important to acknowledge that development on brownfield sites in the urban areas alone \nwill be insufficient to meet housing needs and that the most sustainable, and importantly \ndeliverable strategy will include a range and choice of sites both within and outside the green \nbelt.","No","As mentioned above it is considered that the final strategy will include elements from all of the \noptions as none of the options individually will deliver the scale of development required to \nsupport the sustainable strategy for the SLP. This is acknowledged in the consultation \ndocument at paragraph 6.8 and also in the SA paragraph E18.\nAt this stage the SA is unable to consider the specific scenarios without understanding the \ndetailed locations and the quantum of growth. The only consideration at this stage has been \nthe strengths and weaknesses of each option in principle. \nA degree of urban concentration will be included in the final strategy in line with the NPPF, \nhowever it should be noted at this stage that: \n“S4 (New Strategic Settlements) was identified as the best performing in relation to SA\nObjectives 6, 9, 10, 13 and 14 (pollution, housing, health, education and the economy)\ndue to this scenario having the greatest potential to deliver cohesive communities with\nnew infrastructure and services located in close proximity to new housing.”\n“S6 (Sustainable Transport) performs strongest against SA Objective 12 (transport and\naccessibility) due to its focus on growth alongside sustainable transport routes. This\nscenario also performs relatively well in terms of accessibility to social infrastructure, such as schools (SA Objective 13) and employment opportunities (SA Objective 14).”\n“S2, S3 and S5 were not identified as the best performing against any SA Objectives,\nrelative to the other three scenarios, although each do have some strengths. S2 (Urban\nExtensions) and S3 (Urban Extensions avoiding the Green Belt) would focus growth in\nrelatively accessible areas close to urban areas, although potential major negative impacts\nhave been identified for S2 in terms of SA Objectives 4 and 7 (landscape and natural\nresources) and so S3 would be preferable in this regard. S5 (Rural Dispersal) could help to \nprovide a range of housing types and tenures and conserve the viability of smaller scale\nsettlements, however this scenario could lead to a major negative impact on SA Objective\n4 (landscape) due to this dispersed development towards potentially sensitive villages and\ntowns.”\nWe comment below on each of the 6 Scenarios:\nScenario 1 Urban Concentration\nWhilst an element of urban concentration, making the efficient use of brownfield land will be an \nelement of any strategy, the capacity does not exist to meet all housing needs and even if it \ndid it would not be appropriate as brownfield sites are notorious difficult to deliver, they are\ncomplex sites, and additional cost is required to bring forward schemes, e.g. land assembly and \nremedial works take longer than anticipated. Brownfield redevelopment of sites is more \nexpensive, which means that there are inevitably viability challenges which come from \ndeveloping brownfield sites, and this often has a consequence for local authorities who have to \nmake concessions on matters such as affordable housing provision, or other infrastructure \nimpacts. This scenario would focus development within Cheltenham and Gloucester.\nThe urban concentration option would necessitate building at increased density which \nappears to fly in the opposite direction of the recent changes to the NPPF of achieving welldesigned and beautiful places (B.I D.E.N.) - paragraphs 20, 96, and paragraph 128.\n“Planning policies and decisions should support development that makes efficient use of land, \ntaking into account:\na) the identified need for different types of housing and other forms of development, and the \navailability of land suitable for accommodating it;\nb) local market conditions and viability;\nc) the availability and capacity of infrastructure and services – both existing and proposed –\nas well as their potential for further improvement and the scope to promote sustainable travel \nmodes that limit future car use;\nd) the desirability of maintaining an area’s prevailing character and setting\n(including residential gardens), or of promoting regeneration and change; and\ne) the importance of securing well-designed and beautiful, attractive and healthy\nplaces.”\nWhilst paragraph 129 encourages a significant uplift in the average density of residential \ndevelopment in urban areas, as stated in paragraph 130, this should not be at the expense of \nthe character of the area. A judgment is required, a significant uplift in average residential \ndevelopment will be not necessarily be appropriate as it could be wholly out of character with \nthe existing area. \nThe DLUHC consultation “Strengthening planning policy for Brownfield development” published \non 13th February by DHLUC, comes within weeks of a revised NPPF which states that urban \ndensification should not happen if the uplift is out of character with the existing area.\nIt is considered that this scenario would be unable to meet housing needs and economic \ngrowth as there would be insufficient opportunities. In order to ensure the delivery of \nsustainable development to meet housing and economic needs a range and choice of sites is \nrequired, which will mean that elements of each of the scenarios are included.\nScenario 2 Urban Extensions\nThis scenario would include some loss of Green Belt land and would essentially be a \ncontinuation of the current strategy in the adopted JCS.\nUrban extensions are supported as is development in the Green Belt.\nIn the preparation of the JCS exceptional circumstances were demonstrated to remove land \nfrom the Green Belt in accordance with the NPPF.\nThe adopted JCS identified safeguarded land which may be required beyond the plan period \nof the JCS. However, safeguarded areas of land are not allocated and their inclusion in any \nfuture version of the Plan would need to be evaluated with other options.\nDevelopment Scenario 2 diagram illustrates an urban extension to the north of Tewkesbury on \nthe county boundary and although diagrammatic appears to be located in part in \nWorcestershire. This location also appears in Development Scenario 3 diagram. It is \nconsidered that there are sustainable options within the Vale that can accommodate the \nhousing needs without the need to utilise the Duty to Co-operate and for development to be \naccommodated in Worcestershire.\nThere are other opportunities that have been promoted to Tewkesbury Borough Council \nthrough the HELAA which are sustainable locations and vary in scale but can assist in meeting \nthe housing needs of the SLP and compliment a strategy that includes new settlements. \nLand at The Mythe has previously been promoted to Tewkesbury Borough Council. In March \n2022, Pegasus provided an update on sites within Tewkesbury Borough. The site is part of \nTEWK012 (SUB309) and appears in the Tewkesbury SHLAA https://tewkesbury.gov.uk/wpcontent/uploads/2022/Planning%20policy/Planning%20policy%20evidence%20base/Housing/\nAssessment%20of%20land%20availability/August%202019%20Publication/Appendix%20B%2\n0-%20submitted%20site%20maps.pdf\nIt is not clear why the site has not been included in the latest HELAA. \nThe site is located to the north of Tewkesbury, about 1.5km from the town centre to the east of \nthe A38 Mythe Road and comprises approximately 12.66 hectares of agricultural land. The site \nis suitably located to a range of services within a distance that enables alternative modes to \nthe car to be a realistic option.\nA planning application was submitted in May 2022 for 235 dwellings, but in response to \nconsultation responses the number of dwellings has been reduced to 165. The Transport \nAssessment demonstrates the local facilities required during day-to-day life which are within \nwalking distance from the site, with the majority of facilities being within the recommended \ncycling distance for future residents. The nearest bus stop is located 250m north of the site \nand there is a service which routes between Worcester and Tewkesbury. There is also a \nDemand Responsive Service and a Tewkesbury Shopper Service. Ashchurch Railway Station is \nlocated approximately 4.8km to the southeast of the site.\nThe site plan for the Mythe is below.\nScenario 3 Urban Extensions, avoiding the Green Belt\nIt is considered that urban extensions will form part of the strategy.\nScenario 4: New strategic settlement\nScenario 4 refers to three options land at Boddington within the Green Belt, land at Churcham \nbeyond the Green Belt and the Tewkesbury Garden Town. Tewkesbury Garden Town only\nmeets the needs of Tewkesbury, whereas land at Churcham (West of Severn), because of its \nlocation can meet the needs of Gloucester and Tewkesbury, but particularly Gloucester’s \nneeds. \nThe principle of new settlements is supported, both within the Green Belt and beyond. It is \nconsidered that following the implementation of the sites in the adopted JCS, there are \ninsufficient options to meet housing and employment needs in sustainable locations without \nthe need for new settlements. It is considered that it is now necessary to address the longerterm requirements and opportunities that arise from the inclusion of new settlements in the \nstrategy. It is necessary to make the decisions for the longer-term direction of development \nrather than a continuation of incremental growth.\nThe advantages of new settlements and urban extensions have long been acknowledged e.g.\nthe TCPA Best Practice in Urban Extensions (2007) both new settlements and urban \nextensions provide opportunities for concentrated rather than sprawling development. By \nvirtue of their scale, and if carefully designed and developed to produce integrated, ‘holistic’ \nsettlements, they can encourage and accommodate highly-sustainable patterns of living.\nScenario 5 Rural Dispersal\nAn objection is made to this scenario as this is the most unsustainable option. Growth would \nbe distributed across the rural areas at many of the existing settlements. This option would \nnot provide for the full number of new homes and economic needs, insufficient affordable \nhousing would be provided and increased journeys would be made to facilities and services \nand employment. Those journeys from dispersed locations would more likely be made using \nthe private car, resulting in congestion and increases in emissions etc. A series of smaller more \ndispersed development would not provide for the range and choice of house sizes, types and \ntenures and lead to pressure on limited rural services. Economies of scale cannot be achieved.\nThe locations would not necessarily be attractive to employers/businesses as they would be \nlocated away from the main centres and at some distance from the main transport arteries \nrunning through the SLP. Therefore, such locations may not provide a suitable range of \nemployment locations and types of employment.\nThat is not to say that there is no development to the villages – the strategy should be \nconsistent with the NPPF paragraphs 82- 84 and 88 to 89.\nScenario 6 Sustainable transport scenario\nThis option in principle is supported – as development will be along existing and potential high \nfrequency transport routes for public transport, cycling, walking etc. This should be implicit in \nthe preferred strategy that the Councils include in the version of the Local Plan. Such a \nstrategy would be consistent with the County Council in terms of the Local Transport Plan and \nalso consistent with the objectives of the NPPF.\nHowever, this scenario is not entirely consistent with the Local Transport Plan (LTP) as it only \nfeatures one sustainable transport corridor, whereas the spatial element of the LTP is \nstructured around a number of travel corridors, each of which has distinctive transport issues \nand opportunities set out in six spatial strategies entitled Connecting Places Strategy.\nParagraph 3.2.28 of the LTP states: \n“Gloucestershire plans to move towards an interchange model, which is multi-modal and \nencompasses; car share, community transport demand responsive services, bus, rail and bike \ninterchange facilities. These Transport Interchange Hubs will replace existing Park & Ride \nfacilities and consider additional locations. These hubs should be located on strategic rail or \nbus corridors where existing commercial super high frequency services (core super routes) \nand frequent services (high frequency) are in place. In addition, Strategic Interchange Hubs will \nbecome a vital transport strategy at interchange points on the highway network, e.g., at \nmotorway junctions, such as M5 J10 & J12 where the opportunities to remove traffic from the \nhighway network is greatest and the potential to attract commercial bus services is viable in \nthe long-term.”\nIn paragraph 4.2.1 the LTP identifies \n“Key routes in the CSV are the M5 linking north south and the A40 and A417 linking east west \nto provide access to the M4 corridor. The M5 and part of the A40/ A417 corridors are part of \nthe SRN and have also been identified within the Western Gateway Sub-National Transport \nBody (SNTB) as strategic links. The A38, A417 and the A40 make up a part of the newly formed \nMRN83 proposal which forms a middle tier of the country’s busiest\nand most economically important local authority ‘A’ roads. The MRN will sit between the SRN \nand the rest of the local road network.\nParagraph 4.2.2 The CSV CPS area accommodates almost half of Gloucestershire’s total\npopulation and has the highest proportion of working age people when compared to the \ncounty average. This is reflected by the high proportion of travel to work journeys that begin \nand end within the CPS area.”\nExtract from the LTP Figure STP (A) Strategic Transport Priorities in the Cheltenham and \nGloucester City Region\nIf the strategy included development based on the sustainable transport scenario, then this \nwould make a significant contribution to reducing carbon emissions which all the local \nauthorities in Gloucestershire have signed up to – i.e. to reduce carbon emissions from \ntransport in line with science-based targets to achieve net zero ambitions by 2050.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","","","Pegasus Group on behalf of Robert Hitchins Ltd have been instructed to submitrepresentations in response to the consultation on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan Issues and Options: Spatial Options and key policy areas.\nOur submission comprises:\n• Completed SLP Response Form with reference to The Mythe, Tewkesbury\no Appendix 1: Economic Overview and Housing Need Report \n\n[Q1.] The Strategic Local Plan (SLP) should cover a period of a minimum period of 15 years from the point of adoption. The LDS (July 2023) envisages that the Plan will be submitted to the Secretary of State for examination in April 2026.\nDLUHC Planning for the Future (January 2023) states that: “The average time taken from plan publication to adoption rose from an average of 450 days in 2009 to 815 days in 2019.”, is on average just over 2 years.\nThe JCS took nine years to prepare until it was adopted in 2017 and that required an immediate review which has not taken place.\nIt is considered that the SLP will not be adopted until 2028 at the earliest. Consequently, the plan period should be at least until 2043 in order to ensure at least 15yrs post adoption. However, as outlined in paragraph 22 of the NPPF there are also circumstances where a longer plan period is appropriate. \n“Strategic policies should look ahead over a minimum 15 year period from adoption13, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery14.”\nThe PPG Plan Making in referring to paragraph 22 of the NPPF provides further guidance on the plan period including circumstances when it is appropriate to set out a vision for a longer period of time, the PPG states:\n“This policy requirement would need to be applied where most of the development arising from larger scale developments proposed in the plan will be delivered well beyond the plan \nperiod, and where delivery of those developments extends 30 years or longer from the startof the plan period.\nWhere the policy applies, the authority will need to ensure that their vision reflects the longterm nature of their strategy for the plan or those larger scale developments. It is not anticipated that such visions would require evidence in addition to that already produced to support the plan. Paragraph: 083 Reference ID: 61-083-20211004”\nGiven that the SLP is to consider new settlements and/or significant urban extensions as part of the strategy then there is a clear justification for a longer plan period, e.g. to 2045 andbeyond. It is noted that the Sustainability Appraisal at paragraph 3.2.1 states that “the CGT Councils have prepared a draft vision for the area in 2045” and also in paragraph 3.2.3\nWhatever plan period is chosen there is a need for evidence to cover the whole plan period, it would therefore be sensible to ensure the evidence covers a longer time frame as well. \n\n[Q8.] The mandatory minimum of 10% BNG has only been introduced for all major planning applications in February 2024. It is considered that the Council’s should not deviate from the Government’s requirement for 10% biodiversity net gain as set out in the Environment Act. \nNew government guidance has advised Council’s preparing plans that they should not seek a higher percentage of BNG from developers than the statutory 10% unless justified. This was included in the new PPG.\nThe PPG states that plan-makers “should not seek a higher percentage than the statutory objective of ten per cent biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.” Paragraph: 006 Reference ID: 74-006-20240214\nLocal Plans should not include policies which are incompatible with the national system, for example by applying BNG to exempt categories of development.\nThe PPG states:\n\"Plan-makers should be aware of the statutory framework for biodiversity net gain, but they do not need to include policies which duplicate the detailed provisions of this statutory framework. It will also be inappropriate for plans or supplementary planning documents to include policies or guidance which are incompatible with this framework, for instance by applying biodiversity net gain to exempt categories of development or encouraging the use of a different biodiversity metric or biodiversity gain hierarchy.”\nThere are significant additional costs associated with biodiversity gain, which should be fully accounted for in the Council’s viability assessment. The PPG on Viability has also recently been updated adding BNG as a material consideration for viability assessments.\nIt is important that BNG does not prevent, delay or reduce housing delivery. \nIt is also important to note that large and complex sites where the development is phased, that. \n\"The biodiversity gain objective of at least 10% net gain applies to the overall development (not each phase). The contribution of each phase to achieving net gain may vary, providing a net gain of at least 10% is achieved for the overall development at the time of its completion.”Paragraph 056 Reference ID: 74-056-20240214\n\n[Q15.] It is considered that the provision of sites for traveller communities relates to a bespoke need which can best be accommodated on specific sites, which enables access for HGV and storage of vehicles and maintenance of equipment.\nParagraph 8.14 of the GTAA Report Nov 2022 states:\n“Due to the need for both accommodation space and space for storage and maintenance of very large equipment, the size and space required for a Showpeople plot needs to much larger than a standard Gypsy and Traveller pitch.”\nSuch uses are not necessarily compatible with large developments of housing. The GTAA Report (November 2022) concludes in para 8.5 that:\n“There is general consensus that smaller sites, yards and moorings are preferred by Gypsy, Traveller, Showpeople and boat dweller communities due to better management and maintenance of provision and security.” (my emphasis)\nThe GTAA Report does not make any recommendations to include sites for the traveller community on large developments for housing and/or employment.\nParagraph 8.7 outlines a number of factors which could be considered in terms of identifying broad locations for new permanent sites.\nThe planning policy conclusions at para 8.23 are:\n“As well as quantifying accommodation need, the study also makes recommendations on other key issues including:\nPlanning policy:\n• Implement corporate policy to provide negotiated stopping arrangements to address unauthorised encampments for set periods of time at agreed locations.\n• To liaise with owners of the sites and yards to determine how they could expand the number of pitches to meet the family’s accommodation needs.\n• To work closely with CRT and CCT to meet the needs of the boat dwellers and constant cruisers across the study area.\n• To liaise with marinas and boat yards in the area to see which could accommodate more permanent moorings (including converting some of their leisure moorings to permanent).\n• To consider how the accommodation needs can be met by expanding existing provision and/or providing new sites, yards or moorings.\n• To consider alternative options for developing new sites, yards and moorings such as developing them on a cooperative basis e.g. community land trust, shared ownership, or small sites owned by a local authority but rented to families for their own use.\n•To consider alternative site funding mechanisms such as: site acquisition funds; loans for private site provision through Community Development Financial Institutions; and joint ventures with members of the Gypsy and Traveller, Showpeople and boat dweller communities.\n• Prior to action being taken against sites or yards being used without planning permission, the local authorities, in partnership with landowners, occupants and relevant agencies (e.g. Showmen’s Guild and National Federation of Gypsy Liaison Groups, CRT, CCT, and NBTA), to review its current, historic and potential planning status, and review the most effective way forward.\n• To consider safeguarding Gypsy and Traveller site and Travelling Showpeople yards with permanent planning permission for their current use unless it can be demonstrated that they are no longer needed to meet identified need.\n• The population size and demographics of the Gypsy, Traveller, Travelling Showpeople and boat dweller communities can change rapidly. As such, their accommodation needs should be reviewed every 5 to 7 years.”\nThe Councils have not considered the GTAA report and neither have they considered the effect on viability, market forces and delivery. As such an inflexible approach in policy terms could result in a reduced speed of delivery or a sterilised site/part of a site crucial to the development strategy.\nFurthermore, the approach needs to be consistent with the government guidance – Planning Policy for Traveller sites - there is no reference in the guidance to allocations being included on strategic sites.\n\n[Q26.] Sites or routes for longer term infrastructure projects should be safeguarded but kept under review as the safeguarded land may or may not be needed.\n\n[Q29.] In order to meet housing needs in full and to support economic growth etc for the reasons set out above, the housing requirement should be increased from the Standard Method minimum housing need.\nIn order to provide a range and choice of sites and to ensure a 5-year housing supply, the strategy for the SLP should be based on the following:\n- Previously developed land in urban locations\n- Urban extensions within and outside the Green Belt on existing and potential high frequency public transport routes (a range and choice of sites to ensure delivery)\nThese scenarios alone will be insufficient to meet housing needs and therefore the strategy will need to include sustainably located new settlements which will complement the range and choice of sites in sustainable locations.\n\n[Q31.] Monitoring of the Plan is critical for a number of reasons and in terms of the review of the plan. As set out in the PPG Plan Making in determining whether a plan or policies within a plan should be updated, the success of policies against indicators in the Development Plan should be set out in the Councils Monitoring Report."]
["Planning agent or developer","Robert Hitchins Ltd","","Paragraph 2.4 of the consultation reflects the NPPF paragraph 20 in terms of what strategic \npolicies should address in the plan. \n“Strategic policies should set out an overall strategy for the pattern, scale and design quality \nof places (to ensure outcomes support beauty and placemaking), and make sufficient \nprovision11 for:\na) housing (including affordable housing), employment, retail, leisure and other commercial \ndevelopment;\nb) infrastructure for transport, telecommunications, security, waste management, water \nsupply, wastewater, flood risk and coastal change management, and the provision of minerals \nand energy (including heat);\nc) community facilities (such as health, education and cultural infrastructure); and\nd) conservation and enhancement of the natural, built and historic environment, including \nlandscapes and green infrastructure, and planning measures to address climate change \nmitigation and adaptation.”\nSection 19(1B) - (1E) of the Planning and Compulsory Purchase Act 2004 sets out that each \nlocal planning authority must identify their strategic priorities and have policies to address \nthese in their development plan documents (taken as a whole).\nIt is essential that cross boundary matters are considered as strategic policies. Cross \nboundary matters should include the review of the Green Belt, provision of housing and \nemployment needs (as previously in the adopted JCS) and infrastructure.\nIt is noted that the intention is for the SLP to include separate sections that will cover each \nlocal authority area only providing “locality policies” that address issues and opportunities \nspecific to that area. \nThrough the SLP it should be clear which policies are strategic and which are non-strategic as \nset out in the NPPF paragraph 21. The PPG states:\n“…Where a local plan contains both strategic and non-strategic policies, the non-strategic \npolicies should be clearly distinguished from the strategic policies…”. Paragraph: 002 \nReference ID: 61-002-20190315","Non-strategic policies provide more detailed policies for a specific area(s), neighbourhoods or \ntypes of development. Paragraph 28 provides guidance on what matters can be covered by \nnon- strategic policies.","Yes","In general, the Vision is supported. Through the objectives the Vision should be capable of \nbeing monitored.\nThe first paragraph of the Vision seems only to apply to larger scale developments, surely \nharnessing the opportunities for green growth etc should apply throughout the plan area.\nGreen Growth should be defined in the glossary. The OECD definition of green growth and \nsustainable development is:\n“Green Growth means fostering economic growth and development, while ensuring that \nnatural assets continue to provide the resources and environmental services on which our \nwell-being relies.”\nFurthermore, it is not clear who will delivery or how it will be delivered. Maybe it should say \n“Working with our partners…”\nThis point also applies to the second paragraph of the Vision.\nThe third paragraph of the Vision is supported as whilst it acknowledges that there is a focus \non making the best possible use of brownfield sites etc, it also acknowledges that there is a \nneed for comprehensive planned new development to ensure housing and employment needs \nare met in sustainable locations. The point is that this will involve building on greenfield sites. \nThere is a need to provide a range and choice of sites and clearly not all needs can be met in \nthe urban areas on brownfield sites.\nThe fourth paragraph is supported i.e. “Growth in sustainable locations will have enabled the \nprovision of healthy, accessible and walkable neighbourhoods, the promotion of active travel \nand sustainable travel, and provision of new transport systems that work for local people.”\nThe fifth paragraph should be split into separate points:\nI.e. “Growth will have been supported by the provision of a range of essential digital, transport, \ncommunity and other infrastructure.”\nAnd then “Equally, alongside conserving the area’s special landscapes and its attractiveness \nas a place to visit, a network of interconnected green spaces and waterways will have secured \na high-quality environment for people and nature. Together with necessary retention and\nmanagement of existing sports and leisure facilities, this will have unlocked opportunities for \nhealthy lifestyles, inclusive access to sport and recreation, active flood risk management and \nimprovements to biodiversity.”","No","The objectives are set out under 8 themes. The objectives should be capable of monitoring in \norder to assess whether the plan is delivering in accordance with the NPPF. \n“Meeting the challenges of climate change”\nObjective 1 should be redrafted, as currently drafted it duplicates part of Objective 5 as it \nrefers to the delivery of zero and low carbon development. The achievement of BNG is a \nseparate issue and should reflect current policy guidance. E.g. “Maintain and improve the \nnatural and built environment including biodiversity, landscape, green Infrastructure and \nwaterways by ensuring new development achieves high-quality design standards and \nconserves and enhances the natural, historic, cultural and landscape assets”.\n“Delivering a wide choice of homes that meet the needs of our communities.”\nAdded to this should be \"which supports economic growth\"\nObjective 1 “Delivering sufficient new homes in the right places to meet the needs…”\nThis should read meeting housing needs in full. It is not clear what “sufficient” means it should \nbe sufficient to meet needs. For clarity the objective should be redrafted to read to meet \nneeds in full. \nIn order to ensure sustainable growth in Cheltenham, Gloucester and Tewkesbury, especially to \naddress the issue of an ageing population, younger people and people of working age need to \nbe retained and attracted to the area. One way of doing this is to provide a sufficient supply of \nhousing. \nBuilding strong, competitive and sustainable urban and rural economics\nThe objective should also include, to support the growth in total employment across the SLP \narea. (Tewkesbury has one of the strongest performances in the south west being in the top 10 \nwhereas Cheltenham is one of the lowest).","The most effective way that SLP should address climate change is to plan for sustainable \ndevelopment, i.e. development in those locations that have the greatest opportunity to deliver\nand support sustainable development. Policies should not seek to go beyond national policy, \ninstead they should be consistent with the NPPF and government guidance. (see response \nbelow to Question 7).","Any measures and standards should be consistent with the Government’s policy. A Written \nMinisterial Statement was issued by Lee Rowley on 13th December 2023 which states that: \n“For a number of years, the plans of some local authorities have sought to go further than \nnational standards in terms of such efficiency for new-build properties. Equally, there is a \nlegitimate consideration for the Government to want to strike the best balance between \nmaking progress on improving the efficiency and performance of homes whilst still wanting to \nensure housing is built in sufficient numbers to support those who wish to own or rent their \nown home.\nIn 2015, in reference to an uncommenced provision in the Deregulation Act 2015 which \namended the Planning and Energy Act 2008, a written ministerial statement (WMS) (HC Deb, \n25 March 2015, vol 584, cols 131-138WS) stated that until that amendment was commenced, \nlocal plan policies exceeding minimum energy efficiency standards should not go beyond level \n4 of the Code for Sustainable Homes. Since then, the introduction of the 2021 Part L uplift to \nthe Building Regulations set national minimum energy efficiency standards that are higher than \nthose referenced in the 2015 WMS rendering it effectively moot. A further change to energy \nefficiency building regulations is planned for 2025 meaning that homes built to that standard \nwill be net zero ready and should need no significant work to ensure that they have zero \ncarbon emissions as the grid continue to decarbonise. Compared to varied local standards, \nthese nationally applied standards provide much-needed clarity and consistency for \nbusinesses, large and small, to invest and prepare to build net-zero ready homes.\nThe improvement in standards already in force, alongside the ones which are due in 2025, \ndemonstrates the Government’s commitment to ensuring new properties have a much lower \nimpact on the environment in the future. In this context, the Government does not expect \nplan-makers to set local energy efficiency standards for buildings that go beyond current \nor planned buildings regulations. The proliferation of multiple, local standards by local \nauthority area can add further costs to building new homes by adding complexity and \nundermining economies of scale. Any planning policies that propose local energy efficiency \nstandards for buildings that go beyond current or planned buildings regulation should be \nrejected at examination if they do not have a well-reasoned and robustly costed rationale that \nensures:\nThat development remains viable, and the impact on housing supply and affordability is \nconsidered in accordance with the National Planning Policy Framework.\nThe additional requirement is expressed as a percentage uplift of a dwelling’s Target \nEmissions Rate (TER) calculated using a specified version of the Standard Assessment \nProcedure (SAP).\nWhere plan policies go beyond current or planned building regulations, those polices should \nbe applied flexibly to decisions on planning applications and appeals where the applicant can \ndemonstrate that meeting the higher standards is not technically feasible, in relation to the \navailability of appropriate local energy infrastructure (for example adequate existing and \nplanned grid connections) and access to adequate supply chains.\nTo be sound, local plans must be consistent with national policy – enabling the delivery of \nsustainable development in accordance with the policies in the National Planning Policy \nFramework and other statements of national planning policy, including this one.” (my\nemphasis)\nIf the Councils were to set their own standards there is a real risk of adding to the complexity \nof the approach of policy, regulations and standards that housebuilders are already expected \nto comply with. There is also a risk to the viability and consequently the delivery of sites.\nThe key to success is standardisation and avoidance of individual Councils specifying their \nown policy approach, which undermines economies of scale for product manufacturers, \nsuppliers and developers.","","No","","","The provision of key services and facilities within easy reach of development, depends on the \nprovision of existing services, capacity in schools etc and whether it can be justified and \nwhether it is viable, depending on the level of development to support such facilities. ","","","No","It is noted that the Councils have not yet prepared an update of the Local Housing Needs \nAssessment (2020). This document reflected the standard method applicable at the time. \nThe consultation document acknowledges that since then, the figures have changed, (every \nyear the figures are updated due to the affordability ratio which is published in March).\nThe Standard Method figure changes annually until the Local Plan is submitted for Examination. \n(PPG Paragraph: 008 Reference ID: 2a-008-20190220.) The Government have reaffirmed the \nuse of the standard method in the NPPF Dec 2023, the standard method is the starting point. \nHowever, the standard method does not generate a housing requirement, other factors \nneed to be considered, as set out in the PPG.\n“Assessing housing need is the first step in the process of deciding how many homes need to \nbe planned for. It should be undertaken separately from assessing land availability, \nestablishing a housing requirement figure and preparing policies to address this such as site \nallocations”. PPG Paragraph: 001 Reference ID: 2a-001-20190220\nAn insufficient number of homes have been delivered nationally to meet the need for 300,000 \nhomes per annum, with only 232,816 built in 2021/22. The necessary consequence of this is \nthat the need for housing will have increased regardless of the results of the Government’s \nstandard method.\nIn this context, it remains the case that local authorities need to be aiming above the minimum \nlocal housing need to address housing needs in full and to deliver the 300,000 homes per \nannum sought by the Government. With the standard method still providing a minimum target \nbelow 300,000, it is inevitable that we will continue to see a shortfall in national housing \ndelivery without this.\nAs stated above, the Standard Method identifies a minimum housing need figure, it does not \nproduce a housing requirement (PPG Housing and Economic Needs Assessments para 002 \nReference ID: 2a-002-20190220).\nThe PPG outlines the circumstances when it might be appropriate to plan for a higher housing \nneed figure than the standard method indicates:\n“The standard method for assessing local housing need provides a minimum starting point in \ndetermining the number of homes needed in an area. It does not attempt to predict the \nimpact that future government policies, changing economic circumstances or other factors \nmight have on demographic behaviour. Therefore, there will be circumstances where it is \nappropriate to consider whether actual housing need is higher than the standard method \nindicates.\nThis will need to be assessed prior to, and separate from, considering how much of the overall \nneed can be accommodated (and then translated into a housing requirement figure for the \nstrategic policies in the plan). Circumstances where this may be appropriate include, but are \nnot limited to situations where increases in housing need are likely to exceed past trends \nbecause of:\n• growth strategies for the area that are likely to be deliverable, for example where \nfunding is in place to promote and facilitate additional growth (e.g. Housing Deals);\n• strategic infrastructure improvements that are likely to drive an increase in the homes \nneeded locally; or\n• an authority agreeing to take on unmet need from neighbouring authorities, as set out \nin a statement of common ground;”\nPara 010 Reference ID:2a 010-20201216\nThe current standard method for each of the LPAs is shown in the Table on page 23 of the \nconsultation document and is based on the March 2023 affordability ratio.\nWhen compared with the adopted JCS (2017) which has a housing requirement of 35,175 \ndwellings over a 20-year period, which is 1,759 dwellings per annum; the SLP is now proposing \nonly a slight increase in the number of dwellings to 1,785 dwellings per annum, i.e. an increase \nof only 26 dwellings per annum. This is not consistent with the NPPF (Dec 2023) paragraphs\n60 and 61 as set out below.\nParagraph 60 states that in order to support the Government’s objective of significantly \nboosting housing supply, it is important that sufficient amount and variety of land can come \nforward where it is needed.\n“The overall aim should be to meet as much of an area’s identified housing need as possible, \nincluding with an appropriate mix of housing types for the local community.”\nThe outcome of the standard method is advisory as stated in paragraph 61 of the NPPF (Dec \n2023) states:\n“The outcome of the standard method is an advisory starting-point for establishing a housing \nrequirement for the area (see paragraph 67 below). There may be exceptional circumstances, \nincluding relating to the particular demographic characteristics of an area25 which justify an \nalternative approach to assessing housing need; in which case the alternative approach \nshould also reflect current and future demographic trends and market signals. In addition to \nthe local housing need figure, any needs that cannot be met within neighbouring areas should \nalso be taken into account in establishing the amount of housing to be planned for.”\nNPPF paragraph 67 states:\n“Strategic policy-making authorities should establish a housing requirement figure for their \nwhole area, which shows the extent to which their identified housing need (and any needs that \ncannot be met within neighbouring areas) can be met over the plan period. The requirement \nmay be higher than the identified housing need if, for example, it includes provision for \nneighbouring areas, or reflects growth ambitions linked to economic development or \ninfrastructure investment. Within this overall requirement, strategic policies should also set \nout a housing requirement for designated neighbourhood areas which reflects the overall \nstrategy for the pattern and scale of development and any relevant allocations33 “ (my \nemphasis)\nThe consultation document acknowledges that the standard method is the minimum housing \nneed figure and that this figure provided by the government is the starting point. In paragraph \n5.17 and 5.18 the consultation document reports the NPPF advice referred to above, but then \nconcludes “our current evidence exploring economic growth forecasts and their relationship \nto the need for new homes have concluded there is currently no justification for amending the \nneeds figures, this evidence is required to be kept under review.”\nHowever, the evidence that the consultation relies upon is out of date, as there is no uptodate \nLocal Housing Need Assessment or Economic Assessment (LHNA) available to support the \nconsultation, both are dated 2020. It is noted that a new LHNA is being undertaken.\nIt is noted in the Gloucestershire Statement of Common Ground that it has been agreed \n(February 2022),\n\"Housing Agreement \n7 The Parties agree that making provision to meet the full range of housing needs in the right \nplaces at the right time is a vital role for the Gloucestershire authorities. The parties \nacknowledge this may result in one local authority accommodating the identified needs of \nanother local authority, particularly where a local authority is unable to accommodate all of the \nidentified need and where accommodating need in a neighbouring authority represents the \nmost sustainable form of development.”\n8 That the district councils \"agree to deliver housing where it promotes sustainable patterns of \ngrowth in Gloucestershire and is designed to respect the local character and address \npotential impacts on existing communities.”\nIt is considered that there is a justification for increasing the housing requirement above the \nminimum need provided by the standard method. In particular addressing the current housing \ncrisis, meeting housing need, providing a range and choice of sites, providing affordable \nhousing and providing homes to support economic growth.\nCheltenham, Gloucester and Tewkesbury have seen significant growth in the number of people \naged 65+ over the last decade. While past change in Cheltenham and Gloucester has been \ndriven largely by natural change, in Tewkesbury internal migration has played a big role in \ngrowing the population. \nWith all three areas projected to continue experiencing significant growth in its older \npopulation, younger people and people of working age need to be attracted to the local \nauthority. One way of doing this is through providing attractive and suitable housing options.\nOver the last seven years (from 2015-2022), Tewkesbury’s labour market has performed \nextremely well. In relative terms, it has seen the second highest employment growth of all \nSouth West local authorities. \nIf the positive trend of strong jobs growth continues in Tewkesbury, more people are likely to \nbe attracted to the area and this will make it even more important to ensure the housing offer \ncan meet the likely increase in demand for properties. For Cheltenham and Gloucester, jobs \ngrowth is equally as important in moving both areas closer to regional and national trends. If \nthey are successful in improving the performance of their respective labour markets, it is not \nunreasonable to expect more people to want to move to the area, which would increase \nhousing demand. Indeed, significant growth is anticipated as Cheltenham’s reputation as the \ncyber capital of the UK is established. As set out in Cheltenham’s Corporate Plan, Key Priority 1 \nCyber Cheltenham.\n“With a significant development site next to GCHQ, in a highly accessible location with great \nconnectivity, the opportunity exists to create a destination of global significance.”\nThere will be “spin offs” in terms of employment and other opportunities arising.\nBetween 2012 and 2022, the affordability ratios in Cheltenham (8.94), Gloucester (7.70) and \nTewkesbury (8.68) increased. The affordability ratios in the LPAs are currently below the ratio \nin the South West (9.41) but above the ratio in England (8.28), with the exception of Gloucester. \nMortgage providers will typically only lend 4-4.5 times a persons’ salary showing that housing \nin all areas is becoming increasingly unaffordable for many households. To put the affordability \nissue into perspective, as of 2022 the median house price in Tewkesbury is £300,000 and the \nmedian workplace-based wage is £34,544.\nHousing delivery has been strong in Tewkesbury, which has coincided with an increase in net \ninternal migration. For this to continue, a good supply of housing sites needs to be provided. \nCheltenham and Gloucester have both been consistently below target, which makes it vital for \nhousing delivery to increase in the long-term. Simply basing housing need on the Standard \nMethod (including the projections which reflect past under delivery) will not significantly boost \nsupply.\nHousing affordability in Cheltenham, Gloucester and Tewkesbury is a serious issue, for people \nearning median salaries and those in the lowest 25% of earners. This situation is unlikely to \nimprove unless more homes can be delivered.\nBoth Cheltenham and Gloucester have performed poorly in terms of past housing delivery, \nwhich makes it even more important to set ambitious housing targets. To address the trend of \nan ageing population which is projected in all three areas up to 2041 and also to improve \nlabour market performance, consideration needs to be given to increasing the standard \nmethod figure. The Issues and Options Consultation document states that the most recent \n2020 Housing Needs Assessment will be updated later in the SLP process. Once this new \nevidence is published and has been reviewed, a suggested housing target will be provided. The \nsame comment applies to the employment land requirements, which should also be updated \nlater in the SLP process. \nFrom our analysis it is considered that simply going with the standard method for housing \nneed in Cheltenham, Gloucester and Tewkesbury is not enough, the Standard Method does not \nproduce a housing requirement. There is justification for a higher figure for housing i.e. above \nthe minimum figure generated by the standard method.\nThis is set out in Appendix 1: Economic Overview and Housing Need Report, and should be \nkept under review until the Local Plan is submitted for examination.","No","It is considered that when the opportunities and constraints are reviewed that there are sites \nin highly sustainable locations that are available, and which can assist the Council’s in meeting \na higher housing figure in the plan period. There is no reason why the housing requirement \nshould be constrained.\nLand at Boddington - “Boddington Villages” although within the Green Belt is a highly \nsustainable location and well related to Cheltenham. Importantly Boddington Villages is \nlocated in a part of the Green Belt that makes a limited contribution to Green Belt purposes \nand is a highly sustainable location that can meet future development needs arising from \nCheltenham, Gloucester and Tewkesbury, but particularly Cheltenham, it is a non-sensitive \nlocation in the Green Belt. (see Appendix 2: Vision for Boddington Villages)\nThe Statement of Common Ground states at paragraphs 12 and 13 that:\n\"12. The Parties agree that the Green Belt in Gloucestershire is a strategic issue to be \nconsidered in the context of strategic spatial planning for the County.\n13. The Parties agree that changes to the Green Belt boundary will be considered through the \nlocal plan making process, particularly through the JCS Review, in order to provide more \nsustainable locations for development that support the overall spatial strategy.”","Yes","NPPF paragraph 63 states that, “the size, type and tenure of housing needed for different \ngroups in the community should be assessed and reflected in planning policies. These groups \nshould include (but are not limited to) those who require affordable housing; families with \nchildren; older people (including those who require retirement housing, housing-with-care and \ncare homes); students; people with disabilities; service families; travellers28; people who rent \ntheir homes and people wishing to commission or build their own homes29.”\nClearly the plan needs to provide a range and choice of sites, in terms of house types, sizes \nand tenure.\nIt can be seen from the analysis in Appendix 1 that the proportion of homes that were owned \nwith a mortgage or loan decreased in every area between 2011 and 2021, with Gloucester \nexperiencing a decline from 38% to 32.3%. Additionally, the proportion of homes that were \nprivately rented increased at similar rates in every area.\nThere is a significantly higher proportion of homes that are owned outright in all areas by those \naged 65 and over compared to the younger population (those aged 64 and under).\nAffordability is also an issue – for example, in 2012, the affordability ratio in Cheltenham was \n5.81. By 2022, the affordability ratio in the local authority had increased to 8.94. As of 2022, the \nmedian affordability ratio in Cheltenham was higher than the ratios seen in Gloucester (7.70), \nTewkesbury (8.68) and England (8.28) but was below the ratio in the South West (9.41). \nTo put the affordability ratios into perspective, as of 2022 the median house price in \nTewkesbury is £300,000 and the median workplace-based wage is £34,544. Mortgage \nproviders will typically only lend 4-4.5 times a persons’ salary. Therefore, the affordability ratio \nin all areas presented in Figure 4.1 is significantly above the 4-4.5 times salary to house price \nratio.\nAs of 2022, the typical lower quartile house price in Tewkesbury is £230,000 and the lower \nquartile workplace-based earnings are £25,886, highlighting how difficult it is for the lowest \n25% of earners to get a foot on the property ladder.\nAll of which points to need to increase the supply of housing for all.","","The GTAA Report provides advice to the local authorities.","The GTAA Report provides the advice","The SLP should acknowledge that the “largest commercial market in Gloucestershire is along \nthe M5 corridor which broadly includes the majority of the county’s largest employment areas \nand the settlements of Cheltenham, Gloucester, Tewkesbury, and Stroud.”\nThe Gloucestershire Statement of Common Ground (February 2022) states at paragraph 10 \n\"10. The Parties agree it is important to take advantage of the location and characteristics of \nGloucestershire and its economic strengths. The parties will take a pro-active role in creating \nthe conditions within which existing and potential new employers can flourish, with a particular \nemphasis on spatial planning. Action will be taken to identify the appropriate scale and \ndistribution of employment allocations, with the potential value of strategic sites to serve a \nlarger area fully considered.\n11. Parties agree that collaboration is essential to deliver a purposeful Gloucestershire \napproach to inward investment and business retention.”\nThe Gloucestershire Economic Needs Assessment (August 2020) needs to be updated – this \nwas prepared at the time of the COVID 19 pandemic and considered the potential impact on \nGloucestershire’s economy. Paragraph 5.32 of the consultation document acknowledges the \nneed to update the assessment – this will be critical in terms of providing the growth needed \nover the plan period.\nAny evidence will need to take account of ‘market signals’, which includes what changes in \nskills are likely to be needed; how many people will there be to take up jobs; and whether \nexisting employment land meets the needs of existing businesses or people looking to set up \nbusinesses in the area.\nThe SLP needs to recognise and support the delivery of the Gloucestershire Economic \nStrategy produced by Gloucestershire County Council and the GFirst LEP – due for approval in \nearly 2024. This strategy supports the county’s economic priorities for the next 5 years but \nimportantly for the SLP provides a long-term view to 2050.\nThe introduction to the Economic Strategy states:\n“To meet the needs of the economy, the county requires a robust long-term vision for \neconomic growth and prosperity supported by a countywide spatial strategy. This will provide \nconfidence to businesses and communities about how the county will grow. It will sustain a \nquality employment offer within the county and improve ease of access to the opportunities \nprovided across the region. Over the next 30 years, the county will need to balance the need \nfor additional infrastructure, affordable housing, the need to combat climate change, increase \nits working age population while sustainably managing its natural and historic environment. To \nachieve this, it is important think strategically and on a countywide basis.”\nGloucestershire has an ageing population and high housing costs which have implications for \nthe workforce with the number of jobs expected to exceed the number of working age people \nby 2035. (Gloucestershire Economic Strategy Draft – July 2023)\nThe intended outcomes of the Gloucestershire Economic Strategy focus around “Place\" and \n“People.” E.g. the county growth strategy delivers vibrant delivers vibrant and sustainable \ncommunities and the working age population is increased to rebalance our economy”\nhttps://www.gloucestershire.gov.uk/council-and-democracy/growgloucestershire/developing-a-new-economic-strategy-for-gloucestershire/intendedoutcomes/\nThe SLP needs to consider the implications of the Gloucestershire Economic Strategy which \nidentifies core propositions, and which underlines the importance of taking a strategic \napproach to planning new residential and employment growth, focused in areas that are most \nsustainable in terms of strategic environmental and social considerations.\nThe Gloucestershire Local Transport Plan (LTP) is also key to formulating the strategy.\nThe LTP 2020-2041 acknowledges that M5 is key for employment growth. Para 4.2.2 states: \n“The CSV CPS area accommodates almost half of Gloucestershire’s total population and has \nthe highest proportion of working age people when compared to the county average. This is \nreflected by the high proportion of travel to work journeys that begin and end within the CPS \narea.”\nThe following paragraphs from the LTP clearly demonstrate the role of the SLP area in terms of \nfunction and relationship.\nParagraph 4.2.4 states:\n“Growth proposals identified in the adopted JCS and Local Industrial Strategy will significantly \nincrease the CPS area’s population and range of employment opportunities offered, with even \nmore growth expected through the JCS review. This will result in more trips within this area \nand will require careful management to reduce congestion and limit environmental impacts. \nThe JCS aims to locate jobs near to the economically active population thus minimising outcommuting and reducing carbon emissions from car use and instead promoting sustainable\ntransport by improving opportunities for public transport, walking and cycling by making \nroutes more convenient, safe and attractive.\nParagraph 4.2.5 states:\n“To manage the impacts of growth, the JCS is supported by a comprehensive Transport \nStrategy that details a recommended mitigation package to enable the delivery of the \nproposed development. The schemes detailed in the Transport Strategy are echoed in this \nLocal Transport Plan.”\nParagraph 4.2.6 states:\nIn line with the JCS, GFirst LEP’s Strategic Economic Plan (SEP) supports delivery of \nemployment land around Junctions 9, 10 and 11 of the M5 area. A number of transport related \nproposals for the county will enable the planned growth to be achieved through the release of \nthis employment land.\nParagraph 4.2.7 states:\n“The Local Industrial Strategy identified the Gloucestershire area as a key location for cyber \nresilience alliance – cyber security. This will generate high level skilled employment \nopportunities for which people may be prepared to commute some distance. Gloucestershire \nwill need to support growth in this sector by providing the necessary transport infrastructure \nto facilitate movement through and within the county.”\nIn summary the interaction between employment and housing is critical to sustainable growth. \nAn increase in the number of jobs can it itself generate a requirement for additional housing. It \nmay be that a higher housing figure is needed for economic reasons and a higher housing \nnumber is also needed for housing delivery reasons.","One of the three objectives of the NPPF is an economic objective –\n“to help build a strong, responsive and competitive economy, by ensuring that sufficient land \nof the right types is available in the right places and at the right time to support growth, \ninnovation and improved productivity; and by identifying and coordinating the provision of \ninfrastructure;”\nParagraph 85 of the NPPF: \n“Significant weight should be placed on the need to support economic growth and \nproductivity, taking into account both local business needs and wider opportunities for \ndevelopment. The approach taken should allow each area to build on its strengths, counter\nany weaknesses and address the challenges of the future.”\nParagraph 87\n“Planning policies and decisions should recognise and address the specific locational \nrequirements of different sectors. This includes making provision for clusters or networks of \nknowledge and data-driven, creative or high technology industries; and for storage and \ndistribution operations at a variety of scales and in suitably accessible locations.”\nThe SLP should seek to accommodate employment needs in the most sustainable locations, \naccessible well severed by public transport.\nA range and choice of employment sites to meet requirements will be essential.\nThe SLP should be prepared to reflect the Strategic Economic Plan for Gloucestershire \nhttps://www.gloucestershire.gov.uk/media/wq4ph3zh/glos-5-year-econcomic-strategy.pdf\nThe SLP needs to recognise the implications of failing to address housing needs when there is \na housing crisis, will have adverse implications for the social and economic consequences for \nthe SLP and undermine the objectives of the Strategic Economic Plan for Gloucestershire.","","","","New development needs to be delivered in those locations that are sustainable and /or have \nthe potential to be sustainable e.g. urban extensions and new settlements. Allocations should \nbe located where they can take advantage of existing and committed infrastructure – not \nwhere they need huge expenditure and the long lead in times that go with it.\nAs set out in the NPPF paragraph 8 “Achieving sustainable development means that the \nplanning system has three overarching objectives, which are interdependent and need to be \npursued in mutually supportive ways (so that opportunities can be taken to secure net gains \nacross each of the different objectives)”\nThe types of infrastructure required will depend on the location and what additional \ninfrastructure is required over and above existing. The Councils will need to assess what is \nrequired and produce an Infrastructure Delivery Plan (IDP) which is a “live” document that sets \nout in detail the strategic infrastructure required in order to deliver the growth planned for \nwithin the Local Plan.\nAuthorities should set out in an Infrastructure Funding Statement which infrastructure they \nintend to fund and detail the different sources of funding (see regulation 121A). This will need to \nbe subject to the Viability Assessment as part of the evidence base to support the SLP. It is\nnoted in paragraph 5.52 that the Council’s intend to produce an IDP and this will be available to \nsupport the next version of the SLP.\nHowever, it should be noted that development can only mitigate its own impact and cannot be \nrequired to address existing issues and shortfalls in provision. As such it would be \nunreasonable of the Councils and such an approach would fail the CIL tests if developers were \nrequired to pay to address existing deficiencies.\nIn terms of a new settlement at Boddington, improvements are to be made to the M5 Junction \nJ10 and also improvements to the A4019 Tewkesbury Road widening.\nBus services will be extended /or new/ enhance services provided serving the site together \nwith pedestrian and cycle links to connect into existing or planned routes in the locality.","See Appendix 2 Boddington Villages","","Yes","","The consultation document outlines six spatial options, and it is agreed that the final strategy \nwill be a combination of these options (as set out in paragraph 6.8 of the consultation \ndocument).\nIt is important to acknowledge that development on brownfield sites in the urban areas alone \nwill be insufficient to meet housing needs and that the most sustainable, and importantly \ndeliverable strategy will include a range and choice of sites both within and outside the green \nbelt.","No",{"$cut":{"chars":22648,"head":"As mentioned above it is considered that the final strategy will include elements from all of the \noptions as none of the options individually will deliver the scale of development required to \nsupport the sustainable strategy for the SLP. This is acknowledged in the consultation \ndocument at paragraph 6.8 and also in the SA paragraph E18.\nAt this stage the SA is unable to consider the specific scenarios without understanding the \ndetailed locations and the quantum of growth. The only consideration at this stage has been \nthe strengths and weaknesses of each option in principle. \nA degree of urban concentration will be included in the final strategy in line with the NPPF, \nhowever it should be noted at this stage that: \n“S4 (New Strategic Settlements) was identified as the best performing in relation to SA\nObjectives 6, 9, 10, 13 and 14 (pollution, housing, health, education and the economy) due to \nthis scenario having the greatest potential to deliver cohesive communities with new \ninfrastructure and services located in close proximity to new housing.”\n“S6 (Sustainable Transport) performs strongest against SA Objective 12 (transport and\naccessibility) due to its focus on growth alongside sustainable transport routes. This\nscenario also performs relatively well in terms of accessibility to social infrastructure, such as \nschools (SA Objective 13) and employment opportunities (SA Objective 14).”\n“S2, S3 and S5 were not identified as the best performing against any SA Objectives,\nrelative to the other three scenarios, although each do have some strengths. S2 (Urban\nExtensions) and S3 (Urban Extensions avoiding the Green Belt) would focus growth in\nrelatively accessible areas close to urban areas, although potential major negative impacts\nhave been identified for S2 in terms of SA Objectives 4 and 7 (landscape and natural\nresources) and so S3 would be preferable in this regard. S5 (Rural Dispersal) could help to \nprovide a range of housing types and tenures and conserve the viability of smaller scale\nsettlements, however this scenario could lead to a major negative impact on SA Objective\n4 (landscape) due to this dispersed development towards potentially sensitive villages and\ntowns.”\nWe comment below on each of the 6 Scenarios:\nScenario 1 Urban Concentration\nWhilst an element of urban concentration, making the efficient use of brownfield land will be an \nelement of any strategy, the capacity does not exist to meet all housing needs and even if it \ndid it would not be appropriate as brownfield sites are notorious difficult to deliver, they are \ncomplex sites, and additional cost is required to bring forward schemes, e.g. land assembly and \nremedial works take longer than anticipated. Brownfield redevelopment of sites is more \nexpensive, which means that there are inevitably viability challenges which come from \ndeveloping brownfield sites, and this often has a consequence for local authorities who have to \nmake concessions on matters such as affordable housing provision, or other infrastructure \nimpacts. This scenario would focus development within Cheltenham and Gloucester\nThe urban concentration option would necessitate building at increased density which \nappears to fly in the opposite direction of the recent changes to the NPPF of achieving welldesigned and beautiful places (B.I D.E.N.) - paragraphs 20, 96, and paragraph 128.\n“Planning policies and decisions should support development that makes efficient use of land, \ntaking into account:\na) the identified need for different types of housing and other forms of development, and the \navailability of land suitable for accommodating it;\nb) local market conditions and viability;\nc) the availability and capacity of infrastructure and services – both existing and proposed –\nas well as their potential for further improvement and the scope to promote sustainable travel \nmodes that limit future car use;\nd) the desirability of maintaining an area’s prevailing character and setting\n(including residential gardens), or of promoting regeneration and change; and\ne) the importance of "}},"Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 6: Sustainable transport scenario","","","Pegasus Group on behalf of Robert Hitchins Ltd have been instructed to submitrepresentations in response to the consultation on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan Issues and Options: Spatial Options and key policy areas.\nOur submission comprises:\n• Completed SLP Response Form supported by the following appendices:\no Appendix 1: Economic Overview and Housing Need Report \no Appendix 2: Vision for Boddington Villages\no Appendix 3: Technical Note on Flood Risk for Boddington Villages\no Appendix 4: Transport Appraisal for Boddington Villages\n\n[Q1.] The Strategic Local Plan (SLP) should cover a period of a minimum period of 15 years from the point of adoption. The LDS (July 2023) envisages that the Plan will be submitted to the Secretary of State for examination in April 2026.\nDLUHC Planning for the Future (January 2023) states that: “The average time taken from plan publication to adoption rose from an average of 450 days in 2009 to 815 days in 2019.”, is on average just over 2 years.\nThe JCS took nine years to prepare until it was adopted in 2017 and that required an immediate review which has not taken place.\nIt is considered that the SLP will not be adopted until 2028 at the earliest. Consequently, the plan period should be at least until 2043 in order to ensure at least 15 years post adoption. However, as outlined in paragraph 22 of the NPPF there are also circumstances where a longer plan period is appropriate. \n“Strategic policies should look ahead over a minimum 15 year period from adoption13, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery14.”\nThe PPG Plan Making in referring to paragraph 22 of the NPPF provides further guidance on the plan period including circumstances when it is appropriate to set out a vision for a longer period of time, the PPG states:\n“This policy requirement would need to be applied where most of the development arising from larger scale developments proposed in the plan will be delivered well beyond the plan period, and where delivery of those developments extends 30 years or longer from the start of the plan period.\nWhere the policy applies, the authority will need to ensure that their vision reflects the longterm nature of their strategy for the plan or those larger scale developments. It is not anticipated that such visions would require evidence in addition to that already produced to support the plan.Paragraph: 083 Reference ID: 61-083-20211004”\nGiven that the SLP is to consider new settlements and/or significant urban extensions as part of the strategy then there is a clear justification for a longer plan period, e.g. to 2045 andbeyond. It is noted that the Sustainability Appraisal at paragraph 3.2.1 states that “the CGT Councils have prepared a draft vision for the area in 2045” and also in paragraph 3.2.3.\nWhatever plan period is chosen there is a need for evidence to cover the whole plan period, it would therefore be sensible to ensure the evidence covers a longer time frame as well.\n\n[Q8.] The mandatory minimum of 10% BNG has only been introduced for all major planning applications in February 2024. It is considered that the Council’s should not deviate from the Government’s requirement for 10% biodiversity net gain as set out in the Environment Act. \nNew government guidance has advised Council’s preparing plans that they should not seek a higher percentage of BNG from developers than the statutory 10% unless justified. This was included in the new PPG.\nThe PPG states that plan-makers “should not seek a higher percentage than the statutory objective of ten per cent biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.”Paragraph: 006 Reference ID: 74-006-20240214\nLocal Plans should not include policies which are incompatible with the national system, for example by applying BNG to exempt categories of development.\nThe PPG states:\n\"Plan-makers should be aware of the statutory framework for biodiversity net gain, but they do not need to include policies which duplicate the detailed provisions of this statutory framework. It will also be inappropriate for plans or supplementary planning documents to include policies or guidance which are incompatible with this framework, for instance by applying biodiversity net gain to exempt categories of development or encouraging the use of a different biodiversity metric or biodiversity gain hierarchy.”\nThere are significant additional costs associated with biodiversity gain, which should be fully accounted for in the Council’s viability assessment. The PPG on Viability has also recently been updated adding BNG as a material consideration for viability assessments.\nIt is important that BNG does not prevent, delay or reduce housing delivery. \nIt is also important to note that large and complex sites where the development is phased, that. \n\"The biodiversity gain objective of at least 10% net gain applies to the overall development (not each phase). The contribution of each phase to achieving net gain may vary, providing a net gain of at least 10% is achieved for the overall development at the time of its completion.”Paragraph 056 Reference ID: 74-056-20240214\n\n[Q15.] It is considered that the provision of sites for traveller communities relates to a bespoke need which can best be accommodated on specific sites, which enables access for HGV and storage of vehicles and maintenance of equipment.\nParagraph 8.14 of the GTAA Report Nov 2022 states:\n“Due to the need for both accommodation space and space for storage and maintenance of very large equipment, the size and space required for a Showpeople plot needs to much larger than a standard Gypsy and Traveller pitch.”\nSuch uses are not necessarily compatible with large developments of housing. \nThe GTAA Report (November 2022) concludes in paragraph 8.5 that:\n“There is general consensus that smaller sites, yards and moorings are preferred by Gypsy, Traveller, Showpeople and boat dweller communities due to better management and maintenance of provision and security.” (my emphasis)\nThe GTAA Report does not make any recommendations to include sites for the traveller community on large developments for housing and/or employment.\nParagraph 8.7 outlines a number of factors which could be considered in terms of identifying broad locations for new permanent sites.\nThe planning policy conclusions at paragraph 8.23 are:\n“As well as quantifying accommodation need, the study also makes recommendations on other key issues including:\nPlanning policy:\n• Implement corporate policy to provide negotiated stopping arrangements to address unauthorised encampments for set periods of time at agreed locations.\n• To liaise with owners of the sites and yards to determine how they could expand the number of pitches to meet the family’s accommodation needs.\n• To work closely with CRT and CCT to meet the needs of the boat dwellers and constant cruisers across the study area.\n• To liaise with marinas and boat yards in the area to see which could accommodate more permanent moorings (including converting some of their leisure moorings to permanent).\n• To consider how the accommodation needs can be met by expanding existing provision and/or providing new sites, yards or moorings.\n• To consider alternative options for developing new sites, yards and moorings such as developing them on a cooperative basis e.g. community land trust, shared ownership, or small sites owned by a local authority but rented to families for their own use.\n•To consider alternative site funding mechanisms such as: site acquisition funds; loans for private site provision through Community Development Financial Institutions; and joint ventures with members of the Gypsy and Traveller, Showpeople and boat dweller communities.\n• Prior to action being taken against sites or yards being used without planning permission, the local authorities, in partnership with landowners, occupants and relevant agencies (e.g. Showmen’s Guild and National Federation of Gypsy Liaison Groups, CRT, CCT, and NBTA), to review its current, historic and potential planning status, and review the most effective way forward.\n• To consider safeguarding Gypsy and Traveller site and Travelling Showpeople yards with permanent planning permission for their current use unless it can be demonstrated that they are no longer needed to meet identified need.\n• The population size and demographics of the Gypsy, Traveller, Travelling Showpeople and boat dweller communities can change rapidly. As such, their accommodation needs should be reviewed every 5 to 7 years.”\nThe Councils have not considered the GTAA report and neither have they considered the effect on viability, market forces and delivery. As such an inflexible approach in policy terms could result in a reduced speed of delivery or a sterilised site/part of a site crucial to the development strategy.\nFurthermore, the approach needs to be consistent with the government guidance – Planning Policy for Traveller sites - there is no reference in the guidance to allocations being included on strategic sites.\n\n[Q26.] Yes, but keep under review as the safeguarded land may or may not be needed.\n\n[Q29.] In order to meet housing needs in full and to support economic growth etc for the reasons set out above, the housing requirement should be increase from the Standard Method minimum housing need. \nIn order to provide a range and choice of sites and to ensure a 5-year housing supply, the strategy for the SLP should be based on the following:\n- Previously developed land in urban locations\n- Urban extensions within and outside the Green Belt on existing and potential high frequency public transport \n- New settlement within the Green Belt – in order to future proof the plan and provide the long-term strategy – development at Boddington Villages (in a series of villages well related to the historic core) would be brought forward over a 20-year period, so the site’s inclusion in this plan period addresses the long-term requirements and opportunities and vision for the long term.\nAlthough there would be some of loss of the Green Belt the areas removed would not be critical to the purposes of the Green Belt as set out in the NPPF.\nAppendix 2 illustrates the vision and concept for a Boddington Villages.\n\n[Q31.] Monitoring of the Plan is critical for a number of reasons and in terms of the review of the plan. As set out in the PPG Plan Making in determining whether a plan or policies within a plan should be updated, the success of policies against indicators in the Development Plan should be set out in the Councils Monitoring Report."]
["Planning agent or developer","Robert Hitchins Ltd","","Paragraph 2.4 of the consultation reflects the NPPF paragraph 20 in terms of what strategic \npolicies should address in the plan. \n“Strategic policies should set out an overall strategy for the pattern, scale and design quality \nof places (to ensure outcomes support beauty and placemaking), and make sufficient \nprovision11 for:\na) housing (including affordable housing), employment, retail, leisure and other commercial \ndevelopment;\nb) infrastructure for transport, telecommunications, security, waste management, water \nsupply, wastewater, flood risk and coastal change management, and the provision of minerals \nand energy (including heat);\nc) community facilities (such as health, education and cultural infrastructure); and\nd) conservation and enhancement of the natural, built and historic environment, including \nlandscapes and green infrastructure, and planning measures to address climate change \nmitigation and adaptation.”\nSection 19(1B) - (1E) of the Planning and Compulsory Purchase Act 2004 sets out that each \nlocal planning authority must identify their strategic priorities and have policies to address \nthese in their development plan documents (taken as a whole).\nIt is essential that cross boundary matters are considered as strategic policies. Cross \nboundary matters should include the review of the Green Belt, provision of housing and \nemployment needs (as previously in the adopted JCS) and infrastructure.\nIt is noted that the intention is for the SLP to include separate sections that will cover each \nlocal authority area only providing “locality policies” that address issues and opportunities \nspecific to that area. \nThrough the SLP it should be clear which policies are strategic and which are non-strategic as \nset out in the NPPF paragraph 21. The PPG states:\n“…Where a local plan contains both strategic and non-strategic policies, the non-strategic \npolicies should be clearly distinguished from the strategic policies…”. Paragraph: 002 \nReference ID: 61-002-20190315","Non-strategic policies provide more detailed policies for a specific area(s), neighbourhoods or \ntypes of development. Paragraph 28 provides guidance on what matters can be covered by \nnon- strategic policies.","Yes","In general, the Vision is supported. Through the objectives the Vision should be capable of \nbeing monitored.\nThe first paragraph of the Vision seems only to apply to larger scale developments, surely \nharnessing the opportunities for “green growth” etc should apply throughout the plan area.\n“Green Growth” should be defined in the glossary. The OECD definition of green growth and \nsustainable development is:\n“Green Growth means fostering economic growth and development, while ensuring that \nnatural assets continue to provide the resources and environmental services on which our \nwell-being relies.”\nFurthermore, it is not clear who will deliver “green growth” or how it will be delivered. Maybe it \nshould say “Working with our partners…”\nThis point also applies to the second paragraph of the Vision.\nThe third paragraph of the Vision is supported as whilst it acknowledges that there is a focus \non making the best possible use of brownfield sites etc, it also acknowledges that there is a \nneed for comprehensive planned new development to ensure housing and employment needs \nare met in sustainable locations. The point is that this will involve building on greenfield sites. \nThere is a need to provide a range and choice of sites and clearly not all needs can be met in \nthe urban areas on brownfield sites.\nThe fourth paragraph is supported i.e. “Growth in sustainable locations will have enabled the \nprovision of healthy, accessible and walkable neighbourhoods, the promotion of active travel \nand sustainable travel, and provision of new transport systems that work for local people.”\nThe fifth paragraph should be split into separate points:\nI.e. “Growth will have been supported by the provision of a range of essential digital, transport, \ncommunity and other infrastructure.”\nAnd then “Equally, alongside conserving the area’s special landscapes and its attractiveness \nas a place to visit, a network of interconnected green spaces and waterways will have secured \na high-quality environment for people and nature. Together with necessary retention and \nmanagement of existing sports and leisure facilities, this will have unlocked opportunities for \nhealthy lifestyles, inclusive access to sport and recreation, active flood risk management and \nimprovements to biodiversity.”","No","The objectives are set out under 8 themes. The objectives should be capable of monitoring in \norder to assess whether the plan is delivering in accordance with the NPPF. \n“Meeting the challenges of climate change”\nObjective 1 should be redrafted, as currently drafted it duplicates part of Objective 5 as it \nrefers to the delivery of zero and low carbon development. The achievement of BNG is a \nseparate issue and should reflect current policy guidance. E.g. “Maintain and improve the \nnatural and built environment including biodiversity, landscape, green Infrastructure and \nwaterways by ensuring new development achieves high-quality design standards and \nconserves and enhances the natural, historic, cultural and landscape assets”.\n“Delivering a wide choice of homes that meet the needs of our communities.”\nAdded to this should be \"which supports economic growth\"\nObjective 1 “Delivering sufficient new homes in the right places to meet the needs…”\nThis should read meeting housing needs in full. It is not clear what “sufficient” means it should \nbe sufficient to meet needs. For clarity the objective should be redrafted to read to meet \nneeds in full. \nIn order to ensure sustainable growth in Cheltenham, Gloucester and Tewkesbury, especially to \naddress the issue of an ageing population, younger people and people of working age need to \nbe retained and attracted to the area. One way of doing this is to provide a sufficient supply of \nhousing. \nBuilding strong, competitive and sustainable urban and rural economics\nThe objective should also include to support the growth in total employment across the SLP \narea. (Tewkesbury has one of the strongest performances in the south west being in the top 10 \nwhereas Cheltenham is one of the lowest).","The most effective way that SLP should address climate change is to plan for sustainable \ndevelopment, i.e. development in those locations that have the greatest opportunity to deliver \nand support sustainable development. Policies should not seek to go beyond national policy, \ninstead they should be consistent with the NPPF and government guidance. (see response \nbelow to Question 7).","Any measures and standards should be consistent with the Government’s policy. A Written \nMinisterial Statement was issued by Lee Rowley on 13th December 2023 which states that: \n“For a number of years, the plans of some local authorities have sought to go further than \nnational standards in terms of such efficiency for new-build properties. Equally, there is a \nlegitimate consideration for the Government to want to strike the best balance between \nmaking progress on improving the efficiency and performance of homes whilst still wanting to \nensure housing is built in sufficient numbers to support those who wish to own or rent their \nown home.\nIn 2015, in reference to an uncommenced provision in the Deregulation Act 2015 which \namended the Planning and Energy Act 2008, a written ministerial statement (WMS) (HC Deb, \n25 March 2015, vol 584, cols 131-138WS) stated that until that amendment was commenced, \nlocal plan policies exceeding minimum energy efficiency standards should not go beyond level \n4 of the Code for Sustainable Homes. Since then, the introduction of the 2021 Part L uplift to \nthe Building Regulations set national minimum energy efficiency standards that are higher than \nthose referenced in the 2015 WMS rendering it effectively moot. A further change to energy \nefficiency building regulations is planned for 2025 meaning that homes built to that standard \nwill be net zero ready and should need no significant work to ensure that they have zero \ncarbon emissions as the grid continue to decarbonise. Compared to varied local standards, \nthese nationally applied standards provide much-needed clarity and consistency for \nbusinesses, large and small, to invest and prepare to build net-zero ready homes.\nThe improvement in standards already in force, alongside the ones which are due in 2025, \ndemonstrates the Government’s commitment to ensuring new properties have a much lower \nimpact on the environment in the future. In this context, the Government does not expect \nplan-makers to set local energy efficiency standards for buildings that go beyond current \nor planned buildings regulations. The proliferation of multiple, local standards by local \nauthority area can add further costs to building new homes by adding complexity and \nundermining economies of scale. Any planning policies that propose local energy efficiency \nstandards for buildings that go beyond current or planned buildings regulation should be \nrejected at examination if they do not have a well-reasoned and robustly costed rationale that \nensures:\nThat development remains viable, and the impact on housing supply and affordability is \nconsidered in accordance with the National Planning Policy Framework.\nThe additional requirement is expressed as a percentage uplift of a dwelling’s Target \nEmissions Rate (TER) calculated using a specified version of the Standard Assessment \nProcedure (SAP).\nWhere plan policies go beyond current or planned building regulations, those polices should \nbe applied flexibly to decisions on planning applications and appeals where the applicant can \ndemonstrate that meeting the higher standards is not technically feasible, in relation to the \navailability of appropriate local energy infrastructure (for example adequate existing and \nplanned grid connections) and access to adequate supply chains.\nTo be sound, local plans must be consistent with national policy – enabling the delivery of \nsustainable development in accordance with the policies in the National Planning Policy \nFramework and other statements of national planning policy, including this one.” (my\nemphasis)\nIf the Councils were to set their own standards there is a real risk of adding to the complexity \nof the approach of policy, regulations and standards that housebuilders are already expected \nto comply with. There is also a risk to the viability and consequently the delivery of sites.\nThe key to success is standardisation and avoidance of individual Councils specifying their \nown policy approach, which undermines economies of scale for product manufacturers, \nsuppliers and developers.","","No","","","The provision of key services and facilities within easy reach of development, depends on the \nprovision of existing services, capacity in schools etc and whether it can be justified and\nwhether it is viable, depending on the level of development to support such facilities. ","","","No","It is noted that the Councils have not yet prepared an update of the Local Housing Needs \nAssessment (2020). This document reflected the standard method applicable at the time. \nThe consultation document acknowledges that since then, the figures have changed, (every \nyear the figures are updated due to the affordability ratio which is published in March).\nThe Standard Method figure changes annually until the Local Plan is submitted for Examination. \n(PPG Paragraph: 008 Reference ID: 2a-008-20190220.) The Government have reaffirmed the \nuse of the standard method in the NPPF Dec 2023, the standard method is the starting point. \nHowever, the standard method does not generate a housing requirement, other factors \nneed to be considered, as set out in the PPG.\n“Assessing housing need is the first step in the process of deciding how many homes need to \nbe planned for. It should be undertaken separately from assessing land availability, \nestablishing a housing requirement figure and preparing policies to address this such as site \nallocations”. PPG Paragraph: 001 Reference ID: 2a-001-20190220\nAn insufficient number of homes have been delivered nationally to meet the need for 300,000 \nhomes per annum, with only 232,816 built in 2021/22. The necessary consequence of this is \nthat the need for housing will have increased regardless of the results of the Government’s \nstandard method.\nIn this context, it remains the case that local authorities need to be aiming above the minimum \nlocal housing need to address housing needs in full and to deliver the 300,000 homes per \nannum sought by the Government. With the standard method still providing a minimum target \nbelow 300,000, it is inevitable that we will continue to see a shortfall in national housing \ndelivery without this.\nAs stated above, the Standard Method identifies a minimum housing need figure, it does not \nproduce a housing requirement (PPG Housing and Economic Needs Assessments paragraph\n002 Reference ID: 2a-002-20190220).\nThe PPG outlines the circumstances when it might be appropriate to plan for a higher housing \nneed figure than the standard method indicates:\n“The standard method for assessing local housing need provides a minimum starting point in \ndetermining the number of homes needed in an area. It does not attempt to predict the \nimpact that future government policies, changing economic circumstances or other factors \nmight have on demographic behaviour. Therefore, there will be circumstances where it is \nappropriate to consider whether actual housing need is higher than the standard method \nindicates.\nThis will need to be assessed prior to, and separate from, considering how much of the overall \nneed can be accommodated (and then translated into a housing requirement figure for the \nstrategic policies in the plan). Circumstances where this may be appropriate include, but are \nnot limited to situations where increases in housing need are likely to exceed past trends \nbecause of:\n• growth strategies for the area that are likely to be deliverable, for example where \nfunding is in place to promote and facilitate additional growth (e.g. Housing Deals);\n• strategic infrastructure improvements that are likely to drive an increase in the homes \nneeded locally; or\n• an authority agreeing to take on unmet need from neighbouring authorities, as set out \nin a statement of common ground;”\nParagraph 010 Reference ID:2a 010-20201216\nThe current standard method for each of the LPAs is shown in the Table on page 23 of the \nconsultation document and is based on the March 2023 affordability ratio.\nWhen compared with the adopted JCS (2017) which has a housing requirement of 35,175 \ndwellings over a 20-year period, which is 1,759 dwellings per annum, the SLP is now proposing \nonly a slight increase in the number of dwellings to 1,785 dwellings per annum, i.e. an increase \nof only 26 dwellings per annum. This is not consistent with the NPPF (Dec 2023) paragraphs\n60 and 61 as set out below.\nParagraph 60 states that in order to support the Government’s objective of significantly \nboosting housing supply, it is important that sufficient amount and variety of land can come \nforward where it is needed.\n“The overall aim should be to meet as much of an area’s identified housing need as possible, \nincluding with an appropriate mix of housing types for the local community.”\nThe outcome of the standard method is advisory as stated in paragraph 61 of the NPPF (Dec \n2023) states:\n“The outcome of the standard method is an advisory starting-point for establishing a housing \nrequirement for the area (see paragraph 67 below). There may be exceptional circumstances, \nincluding relating to the particular demographic characteristics of an area25 which justify an \nalternative approach to assessing housing need; in which case the alternative approach \nshould also reflect current and future demographic trends and market signals. In addition to \nthe local housing need figure, any needs that cannot be met within neighbouring areas should \nalso be taken into account in establishing the amount of housing to be planned for.”\nNPPF paragraph 67 states:\n“Strategic policy-making authorities should establish a housing requirement figure for their \nwhole area, which shows the extent to which their identified housing need (and any needs that \ncannot be met within neighbouring areas) can be met over the plan period. The requirement \nmay be higher than the identified housing need if, for example, it includes provision for \nneighbouring areas, or reflects growth ambitions linked to economic development or \ninfrastructure investment. Within this overall requirement, strategic policies should also set \nout a housing requirement for designated neighbourhood areas which reflects the overall \nstrategy for the pattern and scale of development and any relevant allocations33 “ (my \nemphasis)\nThe consultation document acknowledges that the standard method is the minimum housing \nneed figure and that this figure provided by the government is the starting point. In paragraph \n5.17 and 5.18 the consultation document reports the NPPF advice referred to above, but then \nconcludes “our current evidence exploring economic growth forecasts and their relationship \nto the need for new homes have concluded there is currently no justification for amending the \nneeds figures, this evidence is required to be kept under review.”\nHowever, the evidence that the consultation relies upon is out of date, as there is no uptodate \nLocal Housing Need Assessment or Economic Assessment (LHNA) available to support the \nconsultation, both are dated 2020. It is noted that a new LHNA is being undertaken.\nIt is noted in the Gloucestershire Statement of Common Ground that it has been agreed \n(February 2022),\n\"Housing Agreement \n7 The Parties agree that making provision to meet the full range of housing needs in the right \nplaces at the right time is a vital role for the Gloucestershire authorities. The parties \nacknowledge this may result in one local authority accommodating the identified needs of \nanother local authority, particularly where a local authority is unable to accommodate all of the \nidentified need and where accommodating need in a neighbouring authority represents the \nmost sustainable form of development.”\n8 That the district councils \"agree to deliver housing where it promotes sustainable patterns of \ngrowth in Gloucestershire and is designed to respect the local character and address \npotential impacts on existing communities.”\nIt is considered that there is a justification for increasing the housing requirement above the \nminimum need provided by the standard method. In particular addressing the current housing \ncrisis, meeting housing need, providing a range and choice of sites, providing affordable \nhousing and providing homes to support economic growth.\nCheltenham, Gloucester and Tewkesbury have seen significant growth in the number of people \naged 65+ over the last decade. While past change in Cheltenham and Gloucester has been \ndriven largely by natural change, in Tewkesbury internal migration has played a big role in \ngrowing the population. \nWith all three areas projected to continue experiencing significant growth in its older \npopulation, younger people and people of working age need to be attracted to the local \nauthority. One way of doing this is through providing attractive and suitable housing options.\nOver the last seven years (from 2015-2022), Tewkesbury’s labour market has performed \nextremely well. In relative terms, it has seen the second highest employment growth of all \nSouth West local authorities. \nIf the positive trend of strong jobs growth continues in Tewkesbury, more people are likely to \nbe attracted to the area and this will make it even more important to ensure the housing offer \ncan meet the likely increase in demand for properties. For Cheltenham and Gloucester, jobs \ngrowth is equally as important in moving both areas closer to regional and national trends. If \nthey are successful in improving the performance of their respective labour markets, it is not \nunreasonable to expect more people to want to move to the area, which would increase \nhousing demand. Indeed, significant growth is anticipated as Cheltenham’s reputation as the \ncyber capital of the UK is established. As set out in Cheltenham’s Corporate Plan, Key Priority 1 \nCyber Cheltenham.\n“With a significant development site next to GCHQ, in a highly accessible location with great \nconnectivity, the opportunity exists to create a destination of global significance.”\nThere will be “spin offs” in terms of employment and other opportunities arising.\nBetween 2012 and 2022, the affordability ratios in Cheltenham (8.94), Gloucester (7.70) and \nTewkesbury (8.68) increased. The affordability ratios in the LPAs are currently below the ratio \nin the South West (9.41) but above the ratio in England (8.28), with the exception of Gloucester. \nMortgage providers will typically only lend 4-4.5 times a persons’ salary showing that housing \nin all areas is becoming increasingly unaffordable for many households. To put the affordability \nissue into perspective, as of 2022 the median house price in Tewkesbury is £300,000 and the \nmedian workplace-based wage is £34,544.\nHousing delivery has been strong in Tewkesbury, which has coincided with an increase in net \ninternal migration. For this to continue, a good supply of housing sites needs to be provided. \nCheltenham and Gloucester have both been consistently below target, which makes it vital for \nhousing delivery to increase in the long-term. Simply basing housing need on the Standard \nMethod (including the projections which reflect past under delivery) will not significantly boost \nsupply.\nHousing affordability in Cheltenham, Gloucester and Tewkesbury is a serious issue, for people \nearning median salaries and those in the lowest 25% of earners. This situation is unlikely to \nimprove unless more homes can be delivered.\nBoth Cheltenham and Gloucester have performed poorly in terms of past housing delivery, \nwhich makes it even more important to set ambitious housing targets. To address the trend of \nan ageing population which is projected in all three areas up to 2041 and also to improve \nlabour market performance, consideration needs to be given to increasing the standard \nmethod figure. The Issues and Options Consultation document states that the most recent \n2020 Housing Needs Assessment will be updated later in the SLP process. Once this new \nevidence is published and has been reviewed, a suggested housing target will be provided. The \nsame comment applies to the employment land requirements, which should also be updated \nlater in the SLP process. \nFrom our analysis it is considered that simply going with the standard method for housing \nneed in Cheltenham, Gloucester and Tewkesbury is not enough, the Standard method does not \nproduce a housing requirement. There is justification for a higher figure for housing i.e. above \nthe minimum figure generated by the standard method.\nThis is set out in Appendix 1: Economic Overview and Housing Need Report and should be \nkept under review until the Local Plan is submitted for examination.","No","It is considered that when the opportunities and constraints are reviewed that there are sites \nin highly sustainable locations that are available, and which can assist the Council’s in meeting \na higher housing figure in the plan period. There is no reason why the housing requirement \nshould be constrained.\nLand West of Severn is a highly sustainable location and well related to meeting the unmet \nneeds of Gloucester as well as Tewkesbury’s needs (see Appendix 2: Vision for West of \nSevern).","Yes","NPPF paragraph 63 states that, “the size, type and tenure of housing needed for different \ngroups in the community should be assessed and reflected in planning policies. These groups \nshould include (but are not limited to) those who require affordable housing; families with \nchildren; older people (including those who require retirement housing, housing-with-care and \ncare homes); students; people with disabilities; service families; travellers28; people who rent \ntheir homes and people wishing to commission or build their own homes29\n.”\nClearly the plan needs to provide a range and choice of sites, in terms of house types, sizes \nand tenure.\nIt can be seen from the analysis in Appendix 1 that the proportion of homes that were owned \nwith a mortgage or loan decreased in every area between 2011 and 2021, with Gloucester \nexperiencing a decline from 38% to 32.3%. Additionally, the proportion of homes that were \nprivately rented increased at similar rates in every area.\nThere is a significantly higher proportion of homes that are owned outright in all areas by those \naged 65 and over compared to the younger population (those aged 64 and under).\n15\nAffordability is also an issue – for example, in 2012, the affordability ratio in Cheltenham was \n5.81. By 2022, the affordability ratio in the local authority had increased to 8.94. As of 2022, the \nmedian affordability ratio in Cheltenham was higher than the ratios seen in Gloucester (7.70), \nTewkesbury (8.68) and England (8.28) but was below the ratio in the South West (9.41). \nTo put the affordability ratios into perspective, as of 2022 the median house price in \nTewkesbury is £300,000 and the median workplace-based wage is £34,544. Mortgage \nproviders will typically only lend 4-4.5 times a persons’ salary. Therefore, the affordability ratio \nin all areas presented in Figure 4.1 is significantly above the 4-4.5 times salary to house price \nratio.\nAs of 2022, the typical lower quartile house price in Tewkesbury is £230,000 and the lower \nquartile workplace-based earnings are £25,886, highlighting how difficult it is for the lowest \n25% of earners to get a foot on the property ladder.\nAll of which points to need to increase the supply of housing for all.","","The GTAA Report provides advice to the local authorities.","The GTAA Report provides the advice.","The Gloucestershire Statement of Common Ground (February 2022) states at paragraph 10 \n\"10. The Parties agree it is important to take advantage of the location and characteristics of \nGloucestershire and its economic strengths. The parties will take a pro-active role in creating \nthe conditions within which existing and potential new employers can flourish, with a particular \nemphasis on spatial planning. Action will be taken to identify the appropriate scale and \ndistribution of employment allocations, with the potential value of strategic sites to serve a \nlarger area fully considered.\n11. Parties agree that collaboration is essential to deliver a purposeful Gloucestershire \napproach to inward investment and business retention.”\nThe Gloucestershire Economic Needs Assessment (August 2020) needs to be updated – this \nwas prepared at the time of the COVID 19 pandemic and considered the potential impact on \nGloucestershire’s economy. Paragraph 5.32 of the consultation document acknowledges the \nneed to update the assessment – this will be critical in terms of providing the growth needed \nover the plan period.\nAny evidence will need to take account of ‘market signals’, which includes what changes in \nskills are likely to be needed; how many people will there be to take up jobs; and whether \nexisting employment land meets the needs of existing businesses or people looking to set up \nbusinesses in the area.\nThe SLP needs to recognise and support the delivery of the Gloucestershire Economic \nStrategy produced by Gloucestershire County Council and the GFirst LEP – due for approval in \nearly 2024. This strategy supports the county’s economic priorities for the next 5 years but \nimportantly for the SLP provides a long-term view to 2050.\nThe introduction to the Economic Strategy states:\n“To meet the needs of the economy, the county requires a robust long-term vision for \neconomic growth and prosperity supported by a countywide spatial strategy. This will provide \nconfidence to businesses and communities about how the county will grow. It will sustain a \nquality employment offer within the county and improve ease of access to the opportunities \nprovided across the region. Over the next 30 years, the county will need to balance the need \nfor additional infrastructure, affordable housing, the need to combat climate change, increase \nits working age population while sustainably managing its natural and historic environment. To \nachieve this, it is important think strategically and on a countywide basis.”\nGloucestershire has an ageing population and high housing costs which have implications for \nthe workforce with the number of jobs expected to exceed the number of working age people \nby 2035. (Gloucestershire Economic Strategy Draft – July 2023)\nThe intended outcomes of the Gloucestershire Economic Strategy focus around “Place\" and \n“People.” E.g. the county growth strategy delivers vibrant delivers vibrant and sustainable \ncommunities and the working age population is increased to rebalance our economy”\nhttps://www.gloucestershire.gov.uk/council-and-democracy/growgloucestershire/developing-a-new-economic-strategy-for-gloucestershire/intendedoutcomes/\nThe SLP needs to consider the implications of the Gloucestershire Economic Strategy which \nidentifies core propositions, and which underlines the importance of taking a strategic \napproach to planning new residential and employment growth, focused in areas that are most \nsustainable in terms of strategic environmental and social considerations.\nThe Gloucestershire Local Transport Plan (LTP) is also key to formulating the strategy.\nThe LTP 2020-2041 acknowledges that M5 is key for employment growth. Paragraph 4.2.2 \nstates: \n“The CSV CPS area accommodates almost half of Gloucestershire’s total population and has \nthe highest proportion of working age people when compared to the county average. This is \nreflected by the high proportion of travel to work journeys that begin and end within the CPS \narea.”\nThe following paragraphs from the LTP clearly demonstrate the role of the SLP area in terms of \nfunction and relationship.\nParagraph 4.2.4 states:\n“Growth proposals identified in the adopted JCS and Local Industrial Strategy will significantly \nincrease the CPS area’s population and range of employment opportunities offered, with even \nmore growth expected through the JCS review. This will result in more trips within this area \nand will require careful management to reduce congestion and limit environmental impacts. \nThe JCS aims to locate jobs near to the economically active population thus minimising outcommuting and reducing carbon emissions from car use and instead promoting sustainable \ntransport by improving opportunities for public transport, walking and cycling by making \nroutes more convenient, safe and attractive.\nParagraph 4.2.5 states:\n“To manage the impacts of growth, the JCS is supported by a comprehensive Transport \nStrategy that details a recommended mitigation package to enable the delivery of the \nproposed development. The schemes detailed in the Transport Strategy are echoed in this \nLocal Transport Plan.”\nParagraph 4.2.6 states:\nIn line with the JCS, GFirst LEP’s Strategic Economic Plan (SEP) supports delivery of \nemployment land around Junctions 9, 10 and 11 of the M5 area. A number of transport related \nproposals for the county will enable the planned growth to be achieved through the release of \nthis employment land.\nParagraph 4.2.7 states:\n“The Local Industrial Strategy identified the Gloucestershire area as a key location for cyber \nresilience alliance – cyber security. This will generate high level skilled employment \nopportunities for which people may be prepared to commute some distance. Gloucestershire \nwill need to support growth in this sector by providing the necessary transport infrastructure \nto facilitate movement through and within the county.”\nIn summary the interaction between employment and housing is critical to sustainable growth. \nAn increase in the number of jobs can it itself generate a requirement for additional housing. It \nmay be that a higher housing figure is needed for economic reasons and a higher housing \nnumber is also needed for housing delivery reasons.","One of the three objectives of the NPPF is an economic objective –\n“to help build a strong, responsive and competitive economy, by ensuring that sufficient land \nof the right types is available in the right places and at the right time to support growth, \ninnovation and improved productivity; and by identifying and coordinating the provision of \ninfrastructure;”\nParagraph 85 of the NPPF: \n“Significant weight should be placed on the need to support economic growth and \nproductivity, taking into account both local business needs and wider opportunities for \ndevelopment. The approach taken should allow each area to build on its strengths, counter\nany weaknesses and address the challenges of the future.”\nParagraph 87\n“Planning policies and decisions should recognise and address the specific locational \nrequirements of different sectors. This includes making provision for clusters or networks of \nknowledge and data-driven, creative or high technology industries; and for storage and \ndistribution operations at a variety of scales and in suitably accessible locations.”\nThe SLP should seek to accommodate employment needs in the most sustainable locations, \nwhich are accessible well severed by public transport.\nA range and choice of employment sites to meet requirements will be essential.\nThe SLP should be prepared to reflect the Strategic Economic Plan for Gloucestershire \nhttps://www.gloucestershire.gov.uk/media/wq4ph3zh/glos-5-year-econcomic-strategy.pdf\nThe SLP needs to recognise the implications of failing to address housing needs when there is a \nhousing crisis, will have adverse implications for the social and economic consequences for the \nSLP and undermine the objectives of the Strategic Economic Plan for Gloucestershire.","","","","New development needs to be delivered in those locations that are sustainable and /or have \nthe potential to be sustainable e.g. urban extensions and new settlements. Allocations should \nbe located where they can take advantage of existing and committed infrastructure – not \nwhere they need huge expenditure and the long lead in times that go with it.\nAs set out in the NPPF paragraph 8 “Achieving sustainable development means that the \nplanning system has three overarching objectives, which are interdependent and need to be \npursued in mutually supportive ways (so that opportunities can be taken to secure net gains \nacross each of the different objectives)”\nThe types of infrastructure required will depend on the location and what additional \ninfrastructure is required over and above existing. The Councils will need to assess what is \nrequired and produce an Infrastructure Delivery Plan (IDP) which is a “live” document that sets \nout in detail the strategic infrastructure required in order to deliver the growth planned for \nwithin the Local Plan.\nAuthorities should set out in an Infrastructure Funding Statement which infrastructure they \nintend to fund and detail the different sources of funding (see regulation 121A). This will need to \nbe subject to the Viability Assessment as part of the evidence base to support the SLP. It is \nnoted in paragraph 5.52 that the Council’s intend to produce an IDP and this will be available to \nsupport the next version of the SLP.\nHowever, it should be noted that development can only mitigate its own impact and cannot be \nrequired to address existing issues and shortfalls in provision. As such it would be \nunreasonable of the Councils and such an approach would fail the CIL tests if developers were \nrequired to pay to address existing deficiencies.\nIn terms of a new settlement, the West of Severn proposal includes a transport interchange \nhub which will deliver multi-modal integration as envisaged by Gloucestershire County Council \nas part of its emerging multi-modal “interchange model”. \nSubstantial bus priority and cycle infrastructure is already in place that can be augmented to \nprovide further advantage for travel to/from Gloucester and other destinations in the SLP area \nincluding the Cheltenham Cyber Central development.\nThe Transport Interchange Hub is located at the eastern edge of the site and is readily \naccessed from within the proposed development as well as from the A40 via the development \nsite and directly from the A48. \nWest of Severn provides an opportunity to intercept a significant number of existing \ncommuter trips on both the A40 and A48 corridors and provide for onward travel by way of \nalternative modes of transport including bus, bicycle, e‐bike and other emergent technologies \nthat are better integrated, reduce carbon emissions, and are more sustainable than traditional \nmeans of travel.","See Appendix 2: Vision for West of Severn","","Yes","Yes","The consultation document outlines six spatial options, and it is agreed that the final strategy \nwill be a combination of these options (as set out in paragraph 6.8 of the consultation \ndocument).\nIt is important to acknowledge that development on brownfield sites in the urban areas alone \nwill be insufficient to meet housing needs and that the most sustainable, and importantly \ndeliverable strategy will include a range and choice of sites both within and outside the green \nbelt.","No",{"$cut":{"chars":19516,"head":"As mentioned above it is considered that the final strategy will include elements from all of the \noptions as none of the options individually will deliver the scale of development required to \nsupport the sustainable strategy for the SLP. This is acknowledged in the consultation \ndocument at paragraph 6.8 and also in the SA paragraph E18.\nAt this stage the SA is unable to consider the specific scenarios without understanding the \ndetailed locations and the quantum of growth. The only consideration at this stage has been \nthe strengths and weaknesses of each option in principle. \nA degree of urban concentration will be included in the final strategy in line with the NPPF, \nhowever it should be noted at this stage that: \n“S4 (New Strategic Settlements) was identified as the best performing in relation to SA\nObjectives 6, 9, 10, 13 and 14 (pollution, housing, health, education and the economy) due to \nthis scenario having the greatest potential to deliver cohesive communities with new \ninfrastructure and services located in close proximity to new housing.”\n“S6 (Sustainable Transport) performs strongest against SA Objective 12 (transport and\naccessibility) due to its focus on growth alongside sustainable transport routes. This\nscenario also performs relatively well in terms of accessibility to social infrastructure, such as \nschools (SA Objective 13) and employment opportunities (SA Objective 14).”\n“S2, S3 and S5 were not identified as the best performing against any SA Objectives,\nrelative to the other three scenarios, although each do have some strengths. S2 (Urban\nExtensions) and S3 (Urban Extensions avoiding the Green Belt) would focus growth in\nrelatively accessible areas close to urban areas, although potential major negative impacts\nhave been identified for S2 in terms of SA Objectives 4 and 7 (landscape and natural\nresources) and so S3 would be preferable in this regard. S5 (Rural Dispersal) could help to \nprovide a range of housing types and tenures and conserve the viability of smaller scale\nsettlements, however this scenario could lead to a major negative impact on SA Objective\n4 (landscape) due to this dispersed development towards potentially sensitive villages and\ntowns.”\nWe comment below on each of the 6 Scenarios:\nScenario 1 Urban Concentration\nWhilst an element of urban concentration, making the efficient use of brownfield land will be an \nelement of any strategy, the capacity does not exist to meet all housing needs and even if it \ndid it would not be appropriate as brownfield sites are notorious difficult to deliver, they are\ncomplex sites, and additional cost is required to bring forward schemes, e.g. land assembly and \nremedial works take longer than anticipated. Brownfield redevelopment of sites is more \nexpensive, which means that there are inevitably viability challenges which come from \ndeveloping brownfield sites, and this often has a consequence for local authorities who have to \nmake concessions on matters such as affordable housing provision, or other infrastructure \nimpacts. This scenario would focus development within Cheltenham and Gloucester.\nThe urban concentration option would necessitate building at increased density which \nappears to fly in the opposite direction of the recent changes to the NPPF of achieving welldesigned and beautiful places (B.I D.E.N.) - paragraphs 20, 96, and paragraph 128.\n“Planning policies and decisions should support development that makes efficient use of land, \ntaking into account:\na) the identified need for different types of housing and other forms of development, and the \navailability of land suitable for accommodating it;\nb) local market conditions and viability;\nc) the availability and capacity of infrastructure and services – both existing and proposed –\nas well as their potential for further improvement and the scope to promote sustainable travel \nmodes that limit future car use;\nd) the desirability of maintaining an area’s prevailing character and setting\n(including residential gardens), or of promoting regeneration and change; and\ne) the importance of "}},"Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 6: Sustainable transport scenario","","","Pegasus Group on behalf of Robert Hitchins Ltd have been instructed to submitrepresentations in response to the consultation on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan Issues and Options: Spatial Options and key policy areas.\nOur submission comprises:\n• Completed SLP Response Form West of Severn, supported by the following \nappendices:\no Appendix 1: Economic Overview and Housing Need Report \no Appendix 2: Vision for West of Severn\no Appendix 3: Transport Appraisal for West of Severn\n\n[Q1.] The Strategic Local Plan (SLP) should cover a period of a minimum period of 15 years from the point of adoption. The LDS (July 2023) envisages that the Plan will be submitted to the Secretary of State for examination in April 2026.\nDLUHC Planning for the Future (January 2023) states that: “The average time taken from plan publication to adoption rose from an average of 450 days in 2009 to 815 days in 2019.”, is on average just over 2 years.\nThe JCS took nine years to prepare until it was adopted in 2017 and that required an immediate review which has not taken place.\nIt is considered that the SLP will not be adopted until 2028 at the earliest. Consequently, the plan period should be at least until 2043 in order to ensure at least 15 years post adoption. However, as outlined in paragraph 22 of the NPPF there are also circumstances where a longer plan period is appropriate. \n“Strategic policies should look ahead over a minimum 15 year period from adoption13, to anticipate and respond to long-term requirements and opportunities, such as those arising from major improvements in infrastructure. Where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery14.”\nThe PPG Plan Making in referring to paragraph 22 of the NPPF provides further guidance on the plan period including circumstances when it is appropriate to set out a vision for a longer period of time, the PPG states:\n“This policy requirement would need to be applied where most of the development arising from larger scale developments proposed in the plan will be delivered well beyond the plan period, and where delivery of those developments extends 30 years or longer from the start of the plan period.\nWhere the policy applies, the authority will need to ensure that their vision reflects the longterm nature of their strategy for the plan or those larger scale developments. It is not anticipated that such visions would require evidence in addition to that already produced to support the plan.Paragraph: 083 Reference ID: 61-083-20211004”\nGiven that the SLP is to consider new settlements and/or significant urban extensions as part of the strategy then there is a clear justification for a longer plan period, e.g. to 2045 andbeyond. It is noted that the Sustainability Appraisal at paragraph 3.2.1 states that “the CGT Councils have prepared a draft vision for the area in 2045” and also in paragraph 3.2.3.\nWhatever plan period is chosen there is a need for evidence to cover the whole plan period, it would therefore be sensible to ensure the evidence covers a longer time frame as well.\n\n[Q8.] The mandatory minimum of 10% BNG has only been introduced for all major planning applications in February 2024. It is considered that the Council’s should not deviate from the Government’s requirement for 10% biodiversity net gain as set out in the Environment Act. \nNew government guidance has advised Council’s preparing plans that they should not seek a higher percentage of BNG from developers than the statutory 10% unless justified. This was included in the new PPG.\nThe PPG states that plan-makers “should not seek a higher percentage than the statutory objective of ten per cent biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies, they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.”Paragraph: 006 Reference ID: 74-006-20240214\nLocal Plans should not include policies which are incompatible with the national system, for example by applying BNG to exempt categories of development.\nThe PPG states:\n\"Plan-makers should be aware of the statutory framework for biodiversity net gain, but they do not need to include policies which duplicate the detailed provisions of this statutory framework. It will also be inappropriate for plans or supplementary planning documents to include policies or guidance which are incompatible with this framework, for instance by applying biodiversity net gain to exempt categories of development or encouraging the use of a different biodiversity metric or biodiversity gain hierarchy.”\nThere are significant additional costs associated with biodiversity gain, which should be fully accounted for in the Council’s viability assessment. The PPG on Viability has also recently been updated adding BNG as a material consideration for viability assessments.\nIt is important that BNG does not prevent, delay or reduce housing delivery. \nIt is also important to note that large and complex sites where the development is phased, that. \n\"The biodiversity gain objective of at least 10% net gain applies to the overall development (not each phase). The contribution of each phase to achieving net gain may vary, providing a net gain of at least 10% is achieved for the overall development at the time of its completion.”Paragraph 056 Reference ID: 74-056-20240214. \n\n[Q26.] Sites or routes for longer term infrastructure projects should be safeguarded but kept under review as the safeguarded land may or may not be needed.\n\n[Q29.] In order to meet housing needs in full and to support economic growth etc for the reasons set \nout above, the housing requirement should be increase from the Standard Method minimum \nhousing need. \nIn order to provide a range and choice of sites and to ensure a 5-year housing supply, the \nstrategy for the SLP should be based on the following:\n- Previously developed land in urban locations\n- Urban extensions within and outside the Green Belt on existing and potential high \nfrequency public transport \n- New settlement – in order to future proof the plan and provide the long-term strategy –\ndevelopment at West of Severn could be brought forward over a 20-year period, so the \nsite’s inclusion in this plan period addresses the long-term requirements and \nopportunities and vision.\nAppendix 2 illustrates the vision and concept for West of Severn\n\n[Q31.] Monitoring of the Plan is critical for a number of reasons and in terms of the review of the plan. As set out in the PPG Plan Making in determining whether a plan or policies within a plan should be updated, the success of policies against indicators in the Development Plan should be set out in the Councils Monitoring Report"]
["Statutory/Specific Consultee","Wychavon and Malvern Hills District Council",15,"The South Worcestershire Councils suggest that strategic policies should also include additional specific policies on climate change mitigation and adaption, Green Belt policy and health and wellbeing – the latter regarding e.g. the impact of development on health and wellbeing and designed to support positive mental and physical health.","","","The South Worcestershire Councils suggest references in the Vision should be added to nature recovery, biodiversity enhancement and places being safe for all users particularly more vulnerable ones, and also increase the bar for achieving carbon reductions by including word ‘significant’ in para 1 of the Vision to state ‘....which achieves significant carbon reductions’.","","The South Worcestershire Councils agree in general with the draft Strategic Objectives but suggest all places, including city and town centres, residential streets, open spaces should be safe environments for use by all people, particularly more vulnerable ones. Also, should include greater recognition of importance of nature recovery and biodiversity enhancement.","","","","","","","The South Worcestershire Councils suggest schools, GP surgeries, pharmacies, bus and/or rail stops, food shops and post-offices are most important services and facilities to be provided within easy reach of developments.","","","Yes","The NPPF (Para 61) states that the standard method is the advisory starting-point for establishing a housing requirement for the area. Exceptional circumstances may justify an alternative approach to assessing housing need. The South Worcestershire Councils are supportive of the use of the standard method to establish a housing requirement. Should the Strategic Local Plan provide justification for an alternative approach, the SWCs would need to revisit their support until the justifications are fully understood.","","","","","Yes","The South Worcestershire Councils think yes, larger housing development and particularly strategic allocations or new settlements should include new traveller development where possible to ensure travellers are properly catered for and have good access to services and facilities. Employment sites, however, are frequently not suitable for accommodating residential uses, including Traveller sites, because of the poor living environment that may result from e.g. noise, odour, traffic and HGV movements, pollution, poor air quality etc that are often associated with employment sites.","","","","","","","","","","Yes","","","","","Scenario 6: Sustainable transport scenario","","","The South Worcestershire Councils look forward to ongoing cooperation with Cheltenham, Gloucester and Tewkesbury through the progression of the development plan review processes in our respective areas.\n[Q1.] The South Worcestershire Councils consider the plan should look at least 15 years ahead and for strategic growth sites and/or new settlements even longer.\n[Q26.] The South Worcestershire Councils consider this to be essential to ensure that the required infrastructure can be delivered.\n[Q29.] The South Worcestershire Councils (SWC) consider that Development Scenario 6 Sustainable Transport is an option worthy of further investigation because it could allow north Gloucestershire to become significantly more sustainable helping to mitigate against the effects of climate change.\nWith regard to scenarios 2 and 3, the SWC confirm that the allocation at Mitton for 1000 homes is included in the submission version of the South Worcestershire Development Plan Review (SWDPR) but that it has not yet been through examination. The SWDPR allocation at Mitton (refer policy SWDPR54) includes 500 homes to meet the needs of Tewkesbury BC and the other 500 homes for SWC needs. It should be noted that the SWC are unlikely to support an increased number of dwellings at Mitton to meet Tewkesbury’s needs – either as a future expansion of the existing proposed allocation or as a reduction in the number of homes to meet the needs of SW councils.  "]
["Planning agent or developer","Touch Developments","","","","No","It is considered that the draft vision and approach set out in the Local Plan remains relevant and is supported.","No","The Strategic Objectives are considered to remain broadly relevant for the Local Plan Review. The draft Strategic Objectives offers scope to encompass a wide range of development and as well as housing, employment and retail development should include policies and strategic allocations necessary to provide appropriate facilities for other economic, social and environmental factors.","","","","","No","","","No","","No","As the Standard Method mostly calculates an areas housing need based on the existing amount of housing stock, rather than projections of changes to household numbers, the councils will need to consider calculating local housing needs using a method other than the standard method. This could include working with the Local Enterprise Partnership to understand the level of growth that the councils are aiming to achieve and understand the implications for housing growth.","No","As mentioned above, the standard method for assessing local housing need sets out a minimum figure considering household projections and affordability ratios. It does not consider other relevant factors, including cross boundary needs as well as other considerations, such as, any future job growth projections to ensure that the necessary homes to meet social and economic need are provided.","No","","","","","The NPPF advises that each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. This would include an update to the GENA. The councils’ aspirations for economic growth are welcomed and should set out a clear economic vision and strategy which positively and proactively encourages sustainable economic growth. This should also be within easy reach of highway networks, including the M5 motorway to allow for economic development and regeneration.","","","","","Whilst it is understood that an update to the Infrastructure Development Plan (IDP) will be used to inform the new development strategy for the councils, it is the case that the levels of housing, employment and retail growth should be determined first, in order to establish the types of infrastructure required. \n\nWhat is key is that the Council actively engages with infrastructure providers at an early stage to ensure that the required infrastructure is delivered in a timely manner to allow development sites to come forward.","","","","","Touch Developments have an interest in land at Stanboro Nurseries, Hardwicke, Cheltenham. Previous representations have been made in regard to land at Stanboro Nurseries through the Site Assessment of Land Availability (SALA) under reference ELM003. \n\nThe site has been assessed in the Tewkesbury Borough Council HELAA as potentially suitable for housing and for employment subject to further assessment in an Employment Land Study as part of the update to the SLP evidence base. This site is situated outside of Green Belt land and has the opportunity to form part of an option for a strategic site / new settlement with SALA reference ELM011 (land North West of Junction 10 of M5 at Hardwicke, GL51 9TN). \n\nThe site has no physical constraints which could affect the site coming forward. The site is outside of flood zone; situated outside of Ancient Woodland, Tree Preservation Orders, Locally Important Open Space, Special Landscape Area (SLA) and Sites of Special Scientific Interest (SSSI). There is a Grade II listed building situated within 500m, however, this would be taken into consideration when a planning application is prepared. The area west of the site does have some flooding and there are pylons running along the western area of the site, however, this would all be considered when preparing a planning application and would be removed from any proposed development with the appropriate buffers. \n\nThe site is available and is considered achievable and potentially suitable for housing and employment.","","From reviewing the six development scenarios, they would seem fair and accurate in their assessments. \n\nIn terms of Scenario 1, it is considered that focusing the majority of growth within and around the major settlements within and adjacent to the council districts would bring forward certain benefits, such as re-using brownfield land within urban areas, utilising infrastructure that is already in place, supporting existing services and facilities, and building to higher densities where appropriate. However, this would have a huge impact on existing urban sprawl and would only provide a very limited type of housing which would not be suitable for majority of local people trying to purchase a first-time home, or, an alternative home in a more rural setting. \n\nIn terms of Scenario 2, it would be appropriate for some urban extensions to be proposed. However, loss of Green Belt land would reduce the gap between Gloucester, Cheltenham and Bishops Cleeve, including potential loss of higher quality agricultural land for food production.","Scenario 4: New strategic settlement","","","How far into the future should the Strategic and Local Plan cover?\n\nIt is noted that the Council anticipate that the Plan will set out a vision for at least 15 – 20 years. This is considered appropriate and in line with the guidance contained in the National Planning Policy Framework (NPPF, December 2023) at paragraph 22, which advises that strategic policies should look ahead over a minimum 15-year period from adoption. \n\nHowever, it does also state that where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, then the vision should look further ahead (at least 30 years), to take into account the likely timescale for delivery.\n\nShould the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nThe mandatory minimum 10% Biodiversity Net Gain through development seems appropriate, however, it is unclear where land for BNG will be located so a higher percentage would be inappropriate at this stage.\n\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nWe would agree that Scenario 4 is the most appropriate scenario as it would allocate new strategic settlements to allow alternative locations to grow, as opposed to continually building within existing urban areas which have either very limited or no capacity to take on new developments to meet local needs. New strategic settlements can allow the councils to work together with local people and landowners/developers to plan for large sustainable settlement consisting of a wide mix of homes, together with the supporting infrastructure required for schools, health, transport, green infrastructure, and other community facilities. \n\nAs stated in the Strategic Local Plan, Scenario 4 would allow development through one or more comprehensive, master-planned new settlements, of a minimum of around 4,000 new homes with supporting infrastructure. Boddington is included as a potential settlement location, which is positioned south of the A4109 between the A38 and M5 corridors. However, Boddington is located in Green Belt, therefore, it would be an inappropriate location for development. Stanboro Nurseries (SALA reference ELM003) is located north of Boddington, along the A4019 and is situated outside of Green Belt and in close proximity to the A38 and M5 corridors. \n\nIt is considered that the Scenario 4 offers scope to encompass a wide range of development and as well as housing, employment and retail development should include policies and strategic allocations necessary to provide appropriate leisure, recreation, infrastructure and community facilities. However, alternative sites should be reviewed as new settlements which do not conflict with Green Belt policies as referred to in Chapter 13 of the NPPF."]
["Planning agent or developer","Greystoke Land","","","","Yes","while it is appropriate for priority to be placed on the re-use of previously developed land, it has to accepted that within the Borough of Tewkesbury there are insufficient sources of brownfield land to make the requirements for new homes.","","The Strategic Objectives are supported. These objectives would be embraced within a Garden Community at Ashchurch","Addressing the impacts of climate change will be embedded within the principles of a Garden Community. By recognising the scale of the community and the comprehensive masterplan approach, a Garden Community can more effectively address the impacts of climate change, when compared to smaller scale developments.","It is important that the Local Plan confines policy provision to land use planning matters – and does not seek to usurp or duplicate measures and standards which are more appropriately addressed in other templates, for example, Building Regulations.","It is important that the Local Plan confines policy provision to land use planning matters – and does not seek to usurp or duplicate measures and standards which are more appropriately addressed in other templates, for example, Building Regulations.","","No","","Services that provide for day to day needs, such as a local shop, primary school, should be within easy reach of new residents through active travel. It should be acknowledged that promoting sustainable transport is not simply about the provision of sustainable patterns of transport, but includes limiting the need to travel. As such, for some trips, car movement will be used. In these circumstances facilities should be available through short car journeys.","","","Yes","","No","the Tewkesbury Garden Community (TGC) will provide an unrivalled opportunity within the Borough to achieve very substantial housing delivery in a highly sustainable location. The engagement of Homes England is welcomed in seeking to  accelerate the delivery of land for housing at TGC.","","","","","","","","","","","The most critical types of such infrastructure are the provision of education and health facilities\nto meet the needs of a new resident community. Even infrastructure should similarly be provided\nso that new residents have access to open spaces. Often it is suggested that new road\ninfrastructure is required. However, such demands maybe overstated because outside of peak\nhours, existing transport infrastructure may be adequate. All new transport infrastructure should\nbe properly justified as being necessary to make development acceptable.","It is clearly acknowledged that a comprehensive provision of infrastructure will be required to support the successful development of the Tewkesbury Garden Community. ","","Yes","","","","Some of the ‘contrary’ points against a new strategic settlement are not supported. It is not accepted that in not providing ‘all of the new homes and new jobs needed’ directly results in ‘worsening housing unaffordability and constrained economic growth’. It is not suggested that a new strategic settlement should encompass all development needs for the Borough. The SLP will inevitably make provision for other development needs in locations beyond TGC.\n\nIt is not accepted that a new strategic settlement may frustrate the validity and viability of larger city and town centres. Necessarily the range of facilities that will be provided by TGC will not replicate the range and scale of facilities available in larger city and town centres. New residents of the TGC will look to these higher order settlements for a broader range of services and facilities.","","","","[Q1] - Within the context of the Vision and Growth scenarios it is considered that the delivery of a Garden Community at Tewkesbury of some 10,000 homes should be planned for beyond the current option period. It is essential that service providers fully understand the development commitment, and its realistic timescale for delivery of to 10,000 new homes and the associated infrastructure which is required to achieve a new community. Service providers need to plan their investment programmes over this extended timescale. The advice in the Framework paragraph 22 is consistent with such an approach to timescale for delivery. Further, it should be acknowledged that the continued outward expansion of existing settlement can lead to limitations in the delivery of associated physical and social infrastructure. Furthermore the character of existing settlements can be lost. In Tewkesbury Borough, the opportunity is available to plan on a strategic scale and a strategic timescale to establish a new settlement of substantial size. The planning Garden Community at Ashchurch is fully supported.\n\n[Q8] - There is no special justification for the Local Planning seeking to advance a more onerous policy requirement than is provided for by the Environment Act\n[Q26] - Yes where such future infrastructure projects are realistic in terms of potential delivery, rather than being merely aspirational.\n\n[Q.29] Scenario 4 with a portfolio approach to Scenario 3, and be a combination from these two scenarios.\n"]
["","",15,"","","","On the whole, there is agreement with the draft Vision. It is recognised that people’s housing needs must be met through the provision of sustainable, high-quality and affordable housing in sustainable locations. It is also recognised that, in part, this will be through comprehensively planned new development, which takes into consideration the facilities and infrastructure required to accommodate new growth without overwhelming services present in existing settlements. \nThe draft Vision recognises that “Growth will have been supported by the provision of a range of essential digital, transport, community and other infrastructure” – it is therefore essential that new development takes a holistic approach and is directed towards settlements that have the sustainable infrastructure readily in place (which can also be improved where necessary) as well as good local facilities nearby. This is reinforced in the draft Vision in terms of travel – “Growth in \nsustainable locations will have enabled the provision of healthy, accessible and walkable neighbourhoods, the promotion of active travel and sustainable travel, and provision of new transport systems that work for local people” – therefore new developments should be located in locations where sustainable transport infrastructure can be best utilised, i.e. Cheltenham Road East/Gloucester Road, which is the subject of recent major highway/cycle/pedestrian improvements providing links to existing services and facilities, through a range of transport modes.","","The strategic objectives outlined take a positive approach in terms of the direction/location of new growth and reflects the overall approach taken in the draft Vision. For example, there is great emphasis on “integrating new development with existing networks and enhancing wherever  possible”, as well as ensuring growth takes place in locations with “sustainable transport and active travel options”. The strategic objectives also recognise the need to deliver housing of the right size, type and tenure, including “market and affordable, specialist homes, Gypsy, Travellers and Travelling Showpeople \nand self and custom build homes”. It is reinforced that these homes should be built in “sustainable locations, and with good access to shops, services and facilities”. It is positive to see that there is repeated mention within the objectives to integrate new development into existing, sustainable travel networks. The final set of objectives are also beneficial to sustainable growth and you can see that there is a desire to implement sustainable travel in tandem with essential local infrastructure to “maximise wellbeing and active travel opportunities”. It is recognised that new developments be “supported \nby the necessary social and community infrastructure, including schools, open space, playing fields, community facilities and green and blue infrastructure”","","","","","","","","","","Yes","Using the Standard Method, Gloucestershire’s identified need is 35,700 new homes over a 20-year  period – 1,785 annually. The Strategic and Local Plan should use the local annual housing need calculation from the Standard Method in order to provide fully for the housing need of the combined area.","No"," the housing requirement should reflect the calculated housing need, in order to meet the full need of the area","","","","","","","","","","","","","","","","","Yes",null,"Scenario 1: Urban concentration; Scenario 2: Urban extensions","","","[Q1] It is really positive that the three councils are adopting a strategic approach to development and  working together in preparing the joint plan. As set out in the document, the intended plan period of 15 years should be considered a minimum, ideally a longer time period should be considered, especially for strategic level growth, which it is acknowledged does take a significant period of time to deliver. This long time horizon is important to provide the certainty that is required, for the development industry, stakeholders and the community in enabling investment and ensuring that long term patterns of development are clearly understood and accepted.]\n\n[Q29] It is accepted that redevelopment of brownfield land within settlements (Scenario 1) is a sustainable approach and is supported. However, as set out in the Cons for this scenario, this will not deliver sufficient levels of development to meet need.  As a result, it is proposed that a combinations of development options will need to be explored and  this should include Development Scenario #2 (Urban Extensions). In this way, growth can be directed towards settlements with good existing facilities and integrate and improve on existing transport infrastructure within these areas. In order to deliver this growth the plan will need to consider the release of Green Belt land. By definition this includes land on the edge of settlements where growth can be best managed and integrate well with existing infrastructure and local facilities. Where there are exceptional circumstances, release of Green Belt land to meet the housing need will result in delivery in sustainable locations. One of the suitable locations for sustainable urban extension, is the land north of Churchdown  which was previously identified as a draft allocation in the JCS and remains available for  development.]\n"]
["Planning agent or developer","SF Planning","","","","No","","No","The strategic objectives should be more specific about building the right homes in the right places, potentially acknowledging the role of non-traditional housing options.","","","","No","No","","","No","","Yes","Yes, there do not appear to be any exceptional circumstances to justify not using the standard method.","No","","Yes","Not necessarily a requirement for particular groups but there should be a permissive policy for park homes and other non-traditional types of housing to give greater choice. Suggested wording is included at Q31.","","","","","","","","By ensuring that there are enough people living in the villages (and surrounding smaller settlements) to utilise the services and facilities. \n\nA flexible approach to the location of development assists with this. Although this does not apply specifically to the site, the removal of settlement boundaries, or boundaries which are deliberately drawn to allow expansion of a settlement will also ensure that a business can grow rather than experiencing stagnation in profits as prices rise and the economic climate becomes more challenging. Settlement boundaries are often drawn relatively tight to existing settlements which does not allow for the additional customers these businesses and services need. \n\nPolicy criteria could apply in place of settlement boundaries for example by identifying a list of services which a development should have good access to. \n\nDevelopment which accords with the criteria should be supported; other development should not necessarily be refused but material considerations will need to come into play to support such development.","","","The question isn’t as simple as just looking at how many services a rural settlement has. Account should be \ntaken of the ability to easily access services via public transport too. A settlement could have no services \nwhatsoever but could be on an excellent public transport route with a relatively short journey time to a larger settlement. This should still be considered acceptable – as has been demonstrated through DM decisions recently at e.g. The Leigh","","","","","Due to the growth both planned and recently carried out at Twigworth, development in this location can effectively be seen as part of an urban extension of Gloucester. This is in accordance with both scenarios 2 and 3 outlined in the SLP Consultation Document. However, although the site is not affected by green belt, it is considered that scenario 2 which allows for the allocation of green belt sites for housing is generally more appropriate and more likely to deliver sustainable development than scenario 3. \n\nGenerally speaking the pros and cons are accurately identified in relation to these two options. \n\nTraditionally, development at the site would align with the Rural Dispersal scenario (5) which is also considered an appropriate means for distributing housing development. However, this scenario advocates for development at the smallest of hamlets. \n\nThere does not appear to be a scenario which directs growth to locations which have access to a base level of facilities, whether or not that is a small village with good transport links or a larger villages with more services in the village itself. \n\nWe agree that scenario 5 would help to support thriving communities by supporting shops, services and facilities and with the other pros identified in relation to this scenario. \n\nIn terms of the cons for scenario 5, we do not consider it is ‘likely’ that the character and setting of existing settlements will be harmed by development in more rural locations. Much will depend on the scale and size of the development and, more critically, how it is designed. \n\nAlso, policies which incentivise certain types of housing which are needed could overcome some of the more significant impacts of the reduced ability to provide a full range of housing sizes, types, and tenures. \n\nWe are not aware of any rural services or facilities which would experience undue pressure as a result of a small amount of additional housing in the vicinity","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","A hierarchy of settlements is not necessarily the most appropriate way to ensure that policies remain applicable and relevant (i.e. up to date) across the whole plan period. \n\nInstead, each application should be considered with reference to accessibility to different services. This ensures that the situation at the time the decision is made can be taken into account rather than being based on information which, at some stage, could become 10 years out of date. Permission should be granted where the site has access to a certain level of services on foot or public transport within a certain timeframe (e.g. 20 minutes). Where a site does not meet this criteria, this shouldn’t necessarily mean that permission should be refused but then other considerations would become relevant. \n\nWhere the Council still considers it appropriate to have a settlement hierarchy, settlements scoring 8 or more on what was the settlement audit (2014) produced as part of the JCS evidence base (although a new audit should be conducted to inform the SLP). An additional tier may be appropriate if the concept of a rural settlement hierarchy is to be retained so that those villages scoring very highly are assessed for a more significant level of growth than the smaller settlements.","Please see paragraphs 2 – 8 of this letter. In addition, we propose a policy which is supportive of park homes. Suggested wording could be similar to the following (adapted from an interim policy statement by Swale Borough Council): \n\nProposals for residential park homes will be granted provided that all of the following criteria are met: 1. the site is in a sustainable location with access to services and facilities; 2. if the site is within an area at high risk of flooding, the risks must be mitigated through design solutions to the satisfaction of the Environment Agency and these solutions will not lead to other material planning harm; 3. the accommodation that is the subject of the application complies or will comply within 12 months of the granting of planning permission with standards BS3632 and meets the requirements of the Caravan sites and Control of Development Act 1960 (as amended) and the Mobile Homes Act 2013 in terms of both standard and condition of the unit and external layout within the context of surrounding area; 4. the proposed development will demonstrate that they are designed in line with the ‘Lifetime Homes’ criteria; and 5. the site layout is acceptable in terms of privacy and amenity of site occupants.\n\n\n2. This part of our client’s representation seeks to demonstrate why the land at the above address is suitable for park homes to be used as permanent residential dwellings (i.e. not as holiday lets).\n\n3. The park homes for this site will be bungalow style prefabricated single-storey homes which have been manufactured off-site and then installed on the land on which they are proposed to be sited. They are to be timber framed structures which are mounted onto a steel frame and finished with a durable weatherproof exterior. Once assembled on site they are connected to mains services. Usually, they are provided fully furnished with built-in cupboards and wardrobes, kitchen \nwith integrated appliances and central heating, double glazing and carpeting throughout. They will typically be 2 bed and will have a 100 year life expectancy. \n\n4. The site comprises the land edged in red on the accompanying plan.\n\n5. Site description \n\n5.1 Our client’s site measures over 4 hectares and comprises the land previously associated with Court Farm on the northwest side of the A38 Tewkesbury Road as it runs between Longford and Norton.\n\n5.2 Court Farm includes a Grade II listed farmhouse and barn as well as a number of curtilage listed barns, although these are excluded from the proposed site as shown edged in red on the accompanying plan. \n\n5.3 The site is well related to existing forms of development, being bordered to the north, east and south west by commercial and residential developments, and to the south by the A38 which provides good access. The site is already well served by bus services with Stagecoach’s 71 \nservice linking the site with Gloucester and Tewkesbury and Marchants’ M14 school service using bus stops adjacent to the site entrance and accessible via footways.\n\n5.4 The site is highly sustainable, being within walking distance of a number of local amenities in the vicinity, including a shop, filling station, hotel and employment opportunities. \n\n5.5 The existing provision of local services is set to grow further through the development of the Twigworth Strategic Allocation, allocated through the Joint Core Strategy. The land to the south and on the opposite side of the A38 benefits from outline planning permission for up to 725 dwellings as well as a local centre (retail and leisure/healthcare uses), a primary school, green infrastructure and public transport connections, and is currently under construction. Other developments have also been permitted in the area, including at land to the south of Down Hatherley Lane immediately opposite the site, to the east of the A38 (ref. 19/00771/OUT & 22/00465/APP) for up to 32 dwellings; Yew Tree Farm, Tewkesbury Road (ref. 17/00852/OUT & 19/00953/APP) for 74 dwellings; and land at Chestnut Tree Farm (ref. 22/01343/OUT) for 85 dwellings which is in close proximity to the site and will alter its character to a reasonable extent. \n\n5.6 The site is located within Flood Zone 1 and therefore not considered at risk of flooding, and is outside of both the Green Belt and AONB. There are no public rights of way or other statutory restrictions or landscape designations relevant to this submission.\n\n6. Suitability of the site for park homes\n\n6.1 The site was assessed in the draft HELAA (December 2023) as being potentially suitable for housing under reference TWIG015 and TWIG005.The HELAA does not go into detail about specific housing types. It is unclear why the rating was only potentially suitable as the only \nknown ‘constraint’ is the listed building.\n\n6.2 Taking the above into account, the site is suitable for park homes for the following reasons;\n\n6.2.1 The consultation document indicates that 1,785 homes will need to be provided annually across the SLP area and 35,700 homes will be required over the next 20 years. The allocation of the site would make a contribution to housing supply at a time when two of the three SLP \nauthorities do not currently have a five year housing land supply and have struggled to demonstrate one since the adoption of the Joint Core Strategy (JCS).\n\n6.2.2 This is a highly sustainable location, with good accessibility and connections to existing and planned services and amenities locally. The established site access and proximity of bus stops would encourage sustainable transport modes.\n\n6.2.3 The site relates well to surrounding development and is unconstrained by designations such as Green Belt, flood risk or landscape protection. Its development potential has been recognised through significant growth in the area in recent years. Such growth has led to Twigworth’s evolution as an urban extension or suburb of Gloucester, rather than a rural village.\n\n6.3 In terms of additional considerations, one of the Council’s draft strategic objectives is to deliver housing of the right size, type and tenure for people in the area. Paragraph 5.9 of the SLP consultation document acknowledges the need for housing which is suitable for older people. It is \nwell established that park homes are often occupied by elderly people who require a smaller single storey/bungalow style home which is easier to manage and maintain. Sometimes sites are exclusively for residents aged over 55, others simply end up being a location where elderly people prefer to live. Facilitating the construction of more park homes in the area could help to address housing need for elderly people. \n\n6.4 In addition, paragraph 5.6 of the SLP consultation document confirms that housing is becoming increasingly unaffordable in the area (and across the country). These park homes will be lower cost because they are cheaper to construct and tend to be smaller than the average brick built dwelling. There is a clear advantage to increasing the amount of park homes in the \narea in order to support those looking to buy their own home who are priced out of more traditional options and who do not require larger accommodation. It is anticipated that these homes will cost around 1/5 –1/4 of the price of other homes in the immediate vicinity. \n\n6.5 The site is in the vicinity of a listed building, Court Farmhouse and the barn to its east. However, through the design and layout of any scheme coming forward, impacts on the listed building and its setting can be mitigated by appropriate design and landscaping. Therefore, this should not be considered a barrier at this stage.\n\n7. Availability and achievability \n\n7.1 The draft HELAA has identified this site as available but only potentially achievable. It is not clear why this conclusion has been reached. Previous assessments of this land have found the site to be available, suitable, and achievable for both housing and employment and has assessed the likely timescale of the development to be completed within five years There is no reason for this assessment to change.\n\n7.2 For clarity, the site is owned by the client, presently available for residential development, and there is no impediment to its delivery within the next five years.\n\n7.3 We note that paragraph 70 of the NPPF places emphasis on the importance of small to medium housing sites such as this as they can make an important contribution to local housing requirements and are often built out relatively quickly. This site is no exception.\n\n7.4 Park homes have a particular advantage in that they are quick to build out. A recent report by the CMA – Housebuilding Market Study (26 February 2024) highlighted (at paragraph 4.119) that; “the rate at which housebuilders could feasibly supply homes on a given site is affected by a \nrange of external factors, including labour and materials constraints; adverse weather conditions; site characteristics; and the types of homes being constructed. In addition, delays can be caused by infrastructure issues on-site, or environmental negotiations”.\n\n7.5 Whilst a park home does not overcome all of these issues, the build out rate is less susceptible to many of these factors. This means that park homes can often be delivered much more quickly than the equivalent number of ‘brick built’ dwellings.\n\n8. Call for sites summary\n\n8.1 The site is of a reasonable size that could be advanced quickly following the grant of permission, and therefore could aid with housing supply in the short to medium term, thereby helping to sustain a five-year housing land supply of deliverable sites, particularly for older people or those looking for a more affordable or less traditional housing option. \n\n8.2 The site is ideal for residential development due to its sustainable \nlocation. \n\n8.3 Any potential harm that might be identified can be mitigated through a \ncarefully considered, appropriate design and landscaping.\n\nShould the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nNo as it can be very difficult to meet this target on constrained sites, but there could be positively worded policies to incentivise providing more than 10% BNG.\n\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nDue to the growth both planned and recently carried out at Twigworth, development in this location can effectively be seen as part of an urban extension of Gloucester. This is in accordance with both scenarios 2 and 3 outlined in the SLP Consultation Document. However, although the site is not affected by green belt, it is considered that scenario 2 which allows for the allocation of green belt sites for housing is generally more appropriate and more likely to deliver sustainable development than scenario 3. \n\nGenerally speaking the pros and cons are accurately identified in relation to these two options. \n\nTraditionally, development at the site would align with the Rural Dispersal scenario (5) which is also considered an appropriate means for distributing housing development. However, this scenario advocates for development at the smallest of hamlets. \n\nThere does not appear to be a scenario which directs growth to locations which have access to a base level of facilities, whether or not that is a small village with good transport links or a larger villages with more services in the village itself. \n\nWe agree that scenario 5 would help to support thriving communities by supporting shops, services and facilities and with the other pros identified in relation to this scenario. \n\nIn terms of the cons for scenario 5, we do not consider it is ‘likely’ that the character and setting of existing settlements will be harmed by development in more rural locations. Much will depend on the scale and size of the development and, more critically, how it is designed. \n\nAlso, policies which incentivise certain types of housing which are needed could overcome some of the more significant impacts of the reduced ability to provide a full range of housing sizes, types, and tenures. \n\nWe are not aware of any rural services or facilities which would experience undue pressure as a result of a small amount of additional housing in the vicinity"]
["Local Councillor","Ashchurch Rural Parish Council","","Yes, there is no mention of preserving the character and amenity of existing settlements as extensive strategic development affects them.  The Ashchurch Neighbourhood Development Plan  (ARNDP) Review will consider how buffer zones can be utilised to protect the amenity and character of existing settlements from the construction and development pressures of the garden town.\n\nThe strategy topics do not mention traffic.  Traffic pressures in Ashchurch Rural Parish are extensive and will become greater as development increases.  Since Gloucestershire County Council is now a party to the joint strategic plan, this is a matter that should be given a great deal of consideration.  Traffic impacts must be better managed in future than they have been in the past.\n\nThe busy roads and strategic road network create severance of communities.  This is particularly true in Ashchurch Rural Parish where the M5 and the A46 sever north from south and east from west in what is identified as the future garden town.  These blockages to movement by any mode other than private cars makes it difficult for residents to use greener types of transport such as rail (the station can only be safely reached by car) and walking and cycling which is dangerous.  Rat running between destinations through rural areas in Ashchurch is dangerous and damaging to local amenity.","Ashchurch Rural Parish neighbourhood plan sets out the key issues affecting the parish which will only be exacerbated as the plans for the garden town are progressed.  The SLP should consider the full NDP in drawing up matters of importance.  To date, the Parish Council considers that the content of the NDP has been, regrettably, overlooked by officers.\n\nKey matters of importance can be summarised as:\n\n•\tThe NDP sets out clear policies for managing transport and other impacts including during construction.  These policies are part of the development plan for the parish (and therefore for the garden town).  The Reg. 18 consultation draft indicates that replication of policies will be avoided.  On this basis, the NDP policies should be a starting point for the garden town transport and other policies.\n•\tTo date, there are no standards for the provision of play, open space and sport.  The new plan should set out clear standards and requirements for new residential development.  This must include provision of community open space and meeting places such as community halls and sports facilities.  Without clear standards of provision (for instance “xx metres of open space/play area will be provided for each XX bedrooms”) then there will be no ability for viability and provision to be reconciled in S106 agreements.\n•\tThere must be recognition that Ashchurch Rural parish currently provides extensive recreational opportunities (for instance walking and cycling for recreation and equestrian activities).  These must be replaced  elsewhere when the garden town is developed.  Their extent and coverage is detailed in the neighbourhood plan.\n•\tExisting communities’ character and amenity must be respected in the future plans for the garden town.  The joint plan must not consider that the garden town is being placed in an areas where no-one is affected.  The garden town will take decades to deliver.  People will be living there in the meantime and this must not be forgotten.","No","","No","The Vision and Objectives do not include matters raised as of importance in the Ashchurch Rural Neighbourhood Development plan, namely:\n\nOvercoming severance caused by major roads\nReducing rat running\nManaging impacts during construction\nReplacing recreational opportunities that will be lost through development such as rural walking and cycling and equestrian activities\nProvision of sufficient burial space.","The SLP should address the following:\n\nHow land can be identified in Ashchurch Rual Parish that serves multiple purposes of natural flood management, nature recovery and healthy lifestyles to offset development pressure arising from the garden town.\n\nSet out compelling mechanisms for off-site BNG to be delivered in the garden town (and Ashchurch Rural Parish) in a comprehensive nature recovery and flood management strategy in the parish.  Off-site BNG credit generated within the SLP area should be focused on the garden town as a priority.No BNG should be allowed to “escape” to other LPA areas.  This will require the councils to develop an internal BNG credit system (with Gloucestershire Wildlife Trust and other partners) that captures all BNG benefits.","a.\tAll new buildings (including commercial) should be either carbon- neutral in construction, generating their own energy and conserving as much as possible, or the SLP should make provision for energy generation in the area to allow the area as a whole to be more self-sufficient.\n\nb.\tListed buildings are difficult to make more energy efficient, particularly with internal walls and windows where there are significant restrictions from Historic England on what can be achieved.  The policies should seek to allow the owners of listed buildings and buildings in conservation areas to improve their energy performance.  A specialist design guide on this topic be useful, or perhaps a supplementary planning document on energy efficiency in existing buildings (of all types).","a.      All new buildings (including commercial) should be either carbon- neutral in construction, generating their own energy and conserving as much as possible, or the SLP should make provision for energy generation in the area to allow the area as a whole to be more self-sufficient.\n\nb.\tListed buildings are difficult to make more energy efficient, particularly with internal walls and windows where there are significant restrictions from Historic England on what can be achieved.  The policies should seek to allow the owners of listed buildings and buildings in conservation areas to improve their energy performance.  A specialist design guide on this topic be useful, or perhaps a supplementary planning document on energy efficiency in existing buildings (of all types).","Yes","No","The Ashchurch Neighbourhood Development Plan (ARNDP) Review process will work closely with Gloucestershire Wildlife Trust to identify opportunities for local nature recovery.  It is hoped that these results will be incorporated into the Gloucestershire Local Nature Recovery Strategy.  The LNRS and the ARNDP are planned to be mutually supportive.  It is hoped that the SLP would also be part of this process if officers are willing to work with the parish council.","Local Nature Recovery that keeps people separate from species but allows for pleasant and fulling recreation (finding a balance between humans and nature so that all benefit).\n\nProtected water feature that manage flooding.\n\nLong distance recreational opportunities with many access points in linear routes that run in parallel with linear habitats (without causing harm or encroachment).","Yes","All new homes should generate as much renewable energy as possible to meet their own need.  All buildings with large rooves including existing buildings should have PV cells to maximise electricity generation.","No","The standard method remains appropriate in Tewkesbury but perhaps is not so in Cheltenham and Gloucester City where there are more constraints to development and less land available.","No","","No","","","","","Full fibre broadband.\n\nSmall industrial estates scattered across the borough with access to M5 and/or trunk roads.","Improved pubic transport to rural communiites.\n\nStrategic employment zones (this can be a combination of retail and manufacturing, within sustainable travelling distances).","Start up grants and/or loans for new/small businessesBusiness rates holidays for a min of 3 years\n\nTake some small industrial units into TBC ownership to rent out to start up’s with attractive rents\n\nTraining programmes and apprenticeships in skills such as engineering, health and beauty, construction, vehicle mechanics, electronics, hospitality.\n\nLease terms to be easy in and out, e.g. not long leases with large deposits.\n\nEase planning rules for farms wanting to diversify.\n\nDiscourage development of farm buildings for housing.'Local' smaller training facilities","The supporting text does not address the main development programme that the new plan will deliver:  the garden town.  To date, none of the supporting documents for the garden town have provided a reasoned and evidenced statement of what the garden town will require in terms of retail, support serves, community services, public services, banking and post offices, etc.  There are no standards of provision (how much each development should deliver as it’s proportion of a total) and there have been no indicative garden town centre locations that have been firmly identified with landowner agreement.\n\nInstead of asking questions about protecting and expanding existing centres, the Reg.18 consultation should have asked how new development should be served.  It appears that the Retail Study only considered existing centres and did not look to future needs.  This is a very regrettable omission.\n\nAs a matter of urgency, the SLP should commission work on the needs for new town centre activities with a separate vision for what they will require.  Only with a firm understanding of what new development will require in terms of supporting infrastructure will it be possible to leverage developer contributions to provide proportionate contributions.","It is difficult for Ashchurch Rural parish to respond to this since it is probably the preferred location for the garden town.  Investment in rural businesses will be made immediately redundant as wider development progresses.","This is an unhelpful question and it is not possible for Ashchurch Rural Parish Council to list all infrastructure that will be required for the garden town.  The made neighbourhood plan contains a number of development principles and these should be the starting point for discussions and planning for new infrastructure.  It is important that the IDP, when prepared, uses evidence from the ARNDP.","This question should be addressed in a separate piece of professional assessment of future growth and necessary infrastructure.  It is unhelpful and disingenuous to ask a question of this complexity in a consultation of this sort.","This question is not appropriate for Ashchurch Rural parish since it will be transformed from a rural area into a garden town.  The area will require all the normal services for a very large urban extension.  The made ARNDP provides significant evidence on what is required and the review of the ARNP will provide further evidence on local nature recovery; buffers around existing community settlements to protect their amenity and possibly a housing allocation.","Yes","","It might be useful to consider strategic settlements around 2000-3000 homes similar to that at Alderton.  This size would be sufficient to justify the provision of a new primary school and small village centre.","","The pros and cons are seemingly deliberately framed in favour of a large settlements, i.e. the garden town on the basis that infrastructure can be included. North Gloucestershire consists of a number of villages and small towns, each with a variety of homes and their own primary schools, local shops/post offices & village pubs. Examples are Twyning, Alderton & Deerhurst where residents can feel part of a community with their own identity.  This approach might also allow smaller villages to grow and expand into places with more infrastructure and vibrancy. Small industrial estates can be created alongside these new villages. The pros and cons table should reflect this option and the others as well rather than trying to influence respondents to the GT solution.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","To the west of A38 south of Tewkesbury\n\nAround J10 M5 redevelopment \n\nAround J11M5 and towards J11A\n\nNorth of A4019 between A38 and M5","How far into the future should the Strategic and Local Plan cover?\n\nThe plan should provide cover over a period of 30 years with clear delivery expectations for each 5 year period.  The detail provided for years 1-5 and 6-10 of the plan should be provided in sufficient detail to allow local residents and applicants to understand the implications of the proposals on them.\n\nShould the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nYes, but targeted areas such as the garden town.\n\n\nShould the Strategic and Local Plan safeguard sites or routes for longer term infrastructure projects? \n\nYes.  The transport congestion is currently unsustainable and the functionality of the future garden town will be severely compromised without significant improvements to transport infrastructure.  The Parish Council appreciates that National Highways has not been forthcoming with solutions to local congestion issues and other long distance routes.  The parish council is eager to work with the SLP authorities and National Highways to identify and safeguard routes.\n\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nThe overall solution will be a combination of all the scenarios except for one large strategic solution, i.e. the Garden Town. The GT is the “easy” option in terms of solving a large problem with a single solution, and not one that is in keeping with the communities of North Gloucestershire.  Therefore, it may be easy to deal with in forward planning terms, but it introduces an alien approach to provision.  It would be preferable for new strategic developments to be framed smaller than then 10,000 and nearer 2000 to 3000 as this will provide sufficient scale to fund infrastructure requirements such as school/retail/entertainment/sports facilities etc., but not so big as to dwarf existing communities.\n\nIt might be appropriate to prioritise the options in combination:\n\nScenario 1 Urban Concentration, to utilise empty shops and brown field sites but retain some Green spaces (Parks) then…\nScenario 6 Sustainable transport and make use of infrastructure that already exists, then…\nScenario 3 Urban Extensions avoiding Green Belt and \nScenario 2 Urban extensions, then…\nScenario 4 New Strategic settlement, then…\nScenario 5 Rural dispersal."]
["Local Councillor","Ashchurch Rural Parish Council","","Yes, there is no mention of preserving the character and amenity of existing settlements as extensive strategic development affects them.  The Ashchurch Neighbourhood Development Plan  (ARNDP) Review will consider how buffer zones can be utilised to protect the amenity and character of existing settlements from the construction and development pressures of the garden town.\nThe strategy topics do not mention traffic.  Traffic pressures in Ashchurch Rural Parish are extensive and will become greater as development increases.  Since Gloucestershire County Council is now a party to the joint strategic plan, this is a matter that should be given a great deal of consideration.  Traffic impacts must be better managed in future than they have been in the past.\nThe busy roads and strategic road network create severance of communities.  This is particularly true in Ashchurch Rural Parish where the M5 and the A46 sever north from south and east from west in what is identified as the future garden town.  These blockages to movement by any mode other than private cars makes it difficult for residents to use greener types of transport such as rail (the station can only be safely reached by car) and walking and cycling which is dangerous.  Rat running between destinations through rural areas in Ashchurch is dangerous and damaging to local amenity.","Ashchurch Rural Parish neighbourhood plan sets out the key issues affecting the parish which will only be exacerbated as the plans for the garden town are progressed.  The SLP should consider the full NDP in drawing up matters of importance.  To date, the Parish Council considers that the content of the NDP has been, regrettably, overlooked by officers.\nKey matters of importance can be summarised as:\n•\tThe NDP sets out clear policies for managing transport and other impacts including during construction.  These policies are part of the development plan for the parish (and therefore for the garden town).  The Reg. 18 consultation draft indicates that replication of policies will be avoided.  On this basis, the NDP policies should be a starting point for the garden town transport and other policies.\n•\tTo date, there are no standards for the provision of play, open space and sport.  The new plan should set out clear standards and requirements for new residential development.  This must include provision of community open space and meeting places such as community halls and sports facilities.  Without clear standards of provision (for instance “xx metres of open space/play area will be provided for each XX bedrooms”) then there will be no ability for viability and provision to be reconciled in S106 agreements.\n•\tThere must be recognition that Ashchurch Rural parish currently provides extensive recreational opportunities (for instance walking and cycling for recreation and equestrian activities).  These must be replaced  elsewhere when the garden town is developed.  Their extent and coverage is detailed in the neighbourhood plan.\n•\tExisting communities’ character and amenity must be respected in the future plans for the garden town.  The joint plan must not consider that the garden town is being placed in an areas where no-one is affected.  The garden town will take decades to deliver.  People will be living there in the meantime and this must not be forgotten.\n","","","No","The Vision and Objectives do not include matters raised as of importance in the Ashchurch Rural Neighbourhood Development plan, namely:\n•\tOvercoming severance caused by major roads\n•\tReducing rat running\n•\tManaging impacts during construction\n•\tReplacing recreational opportunities that will be lost through development such as rural walking and cycling and equestrian activities\n•\tProvision of sufficient burial space.","The SLP should address the following:\n•\tHow land can be identified in Ashchurch Rual Parish that serves multiple purposes of natural flood management, nature recovery and healthy lifestyles to offset development pressure arising from the garden town.\n•\tSet out compelling mechanisms for off-site BNG to be delivered in the garden town (and Ashchurch Rural Parish) in a comprehensive nature recovery and flood management strategy in the parish.  Off-site BNG credit generated within the SLP area should be focused on the garden town as a priority.\n•\t No BNG should be allowed to “escape” to other LPA areas.  This will require the councils to develop an internal BNG credit system (with Gloucestershire Wildlife Trust and other partners) that captures all BNG benefits.","All new buildings (including commercial) should be either carbon- neutral in construction, generating their own energy and conserving as much as possible, or the SLP should make provision for energy generation in the area to allow the area as a whole to be more self-sufficient.","Listed buildings are difficult to make more energy efficient, particularly with internal walls and windows where there are significant restrictions from Historic England on what can be achieved.  The policies should seek to allow the owners of listed buildings and buildings in conservation areas to improve their energy performance.  A specialist design guide on this topic be useful, or perhaps a supplementary planning document on energy efficiency in existing buildings (of all types).","Yes","Yes","The Ashchurch Neighbourhood Development Plan (ARNDP) Review process will work closely with Gloucestershire Wildlife Trust to identify opportunities for local nature recovery.  It is hoped that these results will be incorporated into the Gloucestershire Local Nature Recovery Strategy.  The LNRS and the ARNDP are planned to be mutually supportive.  It is hoped that the SLP would also be part of this process if officers are willing to work with the parish council.","•\tLocal Nature Recovery that keeps people separate from species but allows for pleasant and fulling recreation (finding a balance between humans and nature so that all benefit).\n•\tProtected water feature that manage flooding.\n•\tLong distance recreational opportunities with many access points in linear routes that run in parallel with linear habitats (without causing harm or encroachment).","Yes","All new homes should generate as much renewable energy as possible to meet their own need.  All buildings with large rooves including existing buildings should have PV cells to maximise electricity generation.","No","The standard method remains appropriate in Tewkesbury but perhaps is not so in Cheltenham and Gloucester City where there are more constraints to development and less land available.","No","","","","","","","•\tFull fibre broadband\n•\tSmall industrial estates scattered across the borough with access to M5 and/or trunk roads","•\tImproved public transport to rural communities.\n•\tStrategic employment zones (this can be a combination of retail and manufacturing, within sustainable travelling distances).","•\tStart up grants and/or loans for new/small businesses.\n•\tBusiness rates holidays for a min of 3 years.\n•\tTake some small industrial units into TBC ownership to rent out to start up’s with attractive rents.\n•\tTraining programmes and apprenticeships in skills such as engineering, health and beauty, construction, vehicle mechanics, electronics, hospitality.\n•\tLease terms to be easy in and out, e.g. not long leases with large deposits.\n•\tEase planning rules for farms wanting to diversify.\n•\tDiscourage development of farm buildings for housing.\n•\t'Local' smaller training facilities.","The supporting text does not address the main development programme that the new plan will deliver:  the garden town.  To date, none of the supporting documents for the garden town have provided a reasoned and evidenced statement of what the garden town will require in terms of retail, support serves, community services, public services, banking and post offices, etc.  There are no standards of provision (how much each development should deliver as it’s proportion of a total) and there have been no indicative garden town centre locations that have been firmly identified with landowner agreement.\nInstead of asking questions about protecting and expanding existing centres, the Reg.18 consultation should have asked how new development should be served.  It appears that the Retail Study only considered existing centres and did not look to future needs.  This is a very regrettable omission.\nAs a matter of urgency, the SLP should commission work on the needs for new town centre activities with a separate vision for what they will require.  Only with a firm understanding of what new development will require in terms of supporting infrastructure will it be possible to leverage developer contributions to provide proportionate contributions","It is difficult for Ashchurch Rural parish to respond to this since it is probably the preferred location for the garden town.  Investment in rural businesses will be made immediately redundant as wider development progresses.","This is an unhelpful question and it is not possible for Ashchurch Rural Parish Council to list all infrastructure that will be required for the garden town.  The made neighbourhood plan contains a number of development principles and these should be the starting point for discussions and planning for new infrastructure.  It is important that the IDP, when prepared, uses evidence from the ARNDP.","This question should be addressed in a separate piece of professional assessment of future growth and necessary infrastructure.  It is unhelpful and disingenuous to ask a question of this complexity in a consultation of this sort.","This question is not appropriate for Ashchurch Rural parish since it will be transformed from a rural area into a garden town.  The area will require all the normal services for a very large urban extension.  The made ARNDP provides significant evidence on what is required and the review of the ARNP will provide further evidence on local nature recovery; buffers around existing community settlements to protect their amenity and possibly a housing allocation.","Yes","Yes","It might be useful to consider strategic settlements around 2000-3000 homes similar to that at Alderton.  This size would be sufficient to justify the provision of a new primary school and small village centre.","No","The pros and cons are seemingly deliberately framed in favour of a large settlements, i.e. the garden town on the basis that infrastructure can be included. North Gloucestershire consists of a number of villages and small towns, each with a variety of homes and their own primary schools, local shops/post offices & village pubs. Examples are Twyning, Alderton & Deerhurst where residents can feel part of a community with their own identity.  This approach might also allow smaller villages to grow and expand into places with more infrastructure and vibrancy. Small industrial estates can be created alongside these new villages. The pros and cons table should reflect this option and the others as well rather than trying to influence respondents to the GT solution.","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","Yes","•\tTo the west of A38 south of Tewkesbury\n•\tAround J10 M5 redevelopment \n•\tAround J11M5 and towards J11A\n•\tNorth of A4019 between A38 and M5\n","Further comment:\n\nQuestion: Should the Strategic and Local Plan safeguard sites or routes for longer term infrastructure projects?\n\nFurther Comment from ARPC: The transport congestion is currently unsustainable and the functionality of the future garden town will be severely compromised without significant improvements to transport infrastructure.  The Parish Council appreciates that National Highways has not been forthcoming with solutions to local congestion issues and other long distance routes.  The parish council is eager to work with the SLP authorities and National Highways to identify and safeguard routes.\n\n\nQuestion:  Which of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nFurther Comment from ARPC: The overall solution will be a combination of all the scenarios except for one large strategic solution, i.e. the Garden Town. The GT is the “easy” option in terms of solving a large problem with a single solution, and not one that is in keeping with the communities of North Gloucestershire.  Therefore, it may be easy to deal with in forward planning terms, but it introduces an alien approach to provision.  It would be preferable for new strategic developments to be framed smaller than then 10,000 and nearer 2000 to 3000 as this will provide sufficient scale to fund infrastructure requirements such as  school/retail/entertainment/sports facilities etc., but not so big as to dwarf existing communities.\nIt might be appropriate to prioritise the options in combination:\n•\tScenario 1 Urban Concentration, to utilise empty shops and brown field sites but retain some Green spaces (Parks) then…\n•\tScenario 6 Sustainable transport and make use of infrastructure that already exists, then…\n•\tScenario 3 Urban Extensions avoiding Green Belt and Scenario 2 Urban extensions, then…\n•\tScenario 4 New Strategic settlement, then…\n•\tScenario 5 Rural dispersal."]
["Planning agent or developer","SF Planning","","","","Yes","Yes in general – particularly those which recognise the need for town centres to evolve and adapt, and the need for flexibility in the approach taken. ","","The vision should go further, and as well as supporting a ‘thriving cultural offer’, it should seek to achieve a thriving hospitality sector and evening economy and\nvibrant local centres. \n\nLikewise, with the strategic objectives it should be made clear that cultural offering (in terms of tourism) extends to leisure and hospitality opportunities. ","","","","","","","","","","","","","","","","","","","","","","Whilst there are multiple ways to achieve this, adopting the hospitality policy as proposed would undoubtedly assist. Flexibility more generally in terms of uses (utilising temporary permissions as appropriate) would also go some way towards achieving this aim. Incentivising mixed use and flexible conversion and mixed use policies would potentially assist, combining residential use(s) as\nappropriate. Policies which promote active frontages (recognising that this isn’t necessarily restricted to retail) should also be adopted.","","","","","","","","","","","","","[Q1 - Although it can be helpful to have a local plan which covers a longer period of time, a great deal of change is expected over the next 10-15 years such that a local plan going beyond 15 years risks becoming irrelevant.]\n\nIntroduction and scope of representation\n\n1.\tWe act for more than 50 independent hospitality businesses in the Gloucester, Cheltenham and Tewkesbury area. This representation outlines the ways in which the emerging local plan should be drafted to support the hospitality sector, the businesses within it and the vital role they have to play for the communities they serve, the vitality of the settlements in which they operate and the local and wider economy generally.\n\n2.\tThis is a particularly challenging time for businesses, the high street generally and specifically the hospitality sector. This is as a result of the COVID-19 pandemic, subsequently exacerbated by escalating costs related to the energy crisis, rising inflation and the challenges associated with the cost of living crisis generally – whereby people have been forced to make difficult decisions about how and where to spend any remaining disposable income; with an ‘evening out’ or even a coffee being the things more likely to be given up for other more essential spends.\n\n3.\tThe SLP represents an excellent opportunity to support local, often independent hospitality businesses and in turn the economy generally, as well as the night time economy specifically, by allowing them to be more flexible about the use of their associated spaces, beyond current permitted development rights.\n\n4.\tWe propose a permissive policy, as outlined below, which seeks to support planning applications for the more effective use of space including the provision of canopies, awnings, gazebos and/or marquees (which would ordinarily require planning permission) to facilitate the viable retention and sustainable expansion of hospitality premises; unless there are overriding other planning reasons not to do so. The policy requirements would manage any potential negative impacts.\n\n5.\tIn addition to a suggested policy, and justification for inclusion of that policy in the local plan, this representation includes responses to specific questions in the SLP consultation document.\n\nSuggested hospitality policy wording\n\n6.\tMoveable structures for hospitality buildings;\n\nPlanning permission will be granted for the erection of fabric marquees, gazebos, awnings and/or canopies outside of, adjacent to, or near the hospitality premises or business with which it is associated provided that;\n\na)\tthe marquee, gazebo, canopy or awnings are an appropriate design and colour for the context;\nb)\tthe layout does not conflict with or impede the safe passage of pedestrians including the partially sighted or those using wheelchairs or mobility scooters;\nc)\tthe development is entirely connected with, ancillary or incidental to, and managed by the hospitality business within the main premises with which it is associated;\nd)\tthe structures would not cause unacceptable harm to the amenity of any adjoining residential property and the area generally, taking into account the size and type of the proposal, the hours of use proposed and the nature and character of the area;\n \ne)\tthe number, size and scale of the structures are proportionate to the size of the building with which it is situated; and\nf)\tthe structure is not fixed to any heritage assets.\n\n\nProposals for external covered food and drink areas should be accompanied by a management plan, including mitigation measures where necessary for any potential negative impacts arising from their use (including but not limited to waste management, noise and light pollution).\n\nConsideration will be given to the operational requirements of neighbouring premises and their views will be sought on any applications made.\n\nWhere impacts cannot easily be quantified or understood at the initial application stage, a temporary permission for up to 36 months may first be granted, at the end of which the temporary use must cease unless the impacts have been considered to be acceptable and planning permission is subsequently granted to retain the structures permanently.\n\nHospitality policy justification\n\n7.\tThe proposed policy is not without restriction. The Council are not automatically permitting each and every structure for an unspecified period. Specific planning considerations would still need to be weighed up and each site would be considered on its merits. One of the suggested requirements of the policy, a management plan, will enable full assessment of potential impact on amenity and users of the highway, and how that would be managed. There may be additional licensing considerations and/or other consents which need to be obtained before the structures can be used. Planning though should not duplicate those controls.\n\n8.\tThe proposed policy would create a more favourable environment for such development to come forward, with a greater prospect of receiving approval in a straightforward manner and providing some comfort for applicants entering that process. Adopting such a policy demonstrates the councils are willing to support hospitality businesses, especially independents, and ensure the local plan works for them, the local economy and the community in the best way\n \npossible.\n\n9.\tAs well as facilitating greater customer numbers across the less clement months of the year for individual businesses, the year-round external seating ultimately encourages more people to visit and remain in town centres and the other attractions/facilities within it, for longer; in turn increasing spend to the benefit of the local economy generally. This includes helping to sustain the evening and nighttime economies as set out in the draft objectives for the SLP.\n\n10.\tIncreased dining and drinking space has the potential to attract customers over an extended period, and therefore the ability to create more jobs in the following industries (not an exhaustive list);\n\n•\tFood suppliers\n•\tBeverage suppliers\n•\tBin collection suppliers\n•\tLinen/laundry companies\n•\tMaintenance teams\n\n11.\tThere are additional health and safety benefits too. Although everyday life has returned to a degree of normality, COVID-19, which originally sparked the idea for local hospitality businesses to better utilise their outdoor spaces, has by no means gone away and is likely to affect people and lifestyles for years to come. Many people remain nervous of being in crowded, indoor spaces, and prefer to socialise in well-ventilated, larger spaces where greater distancing can be achieved.\n\n12.\tCurrent adopted policy confirms that development should contribute to a healthy population and reduce social exclusion. Well-ventilated and spaced-out seating options will help to secure this and the isolation of those who feel less safe following the COVID-19 pandemic can be reduced.\n\n13.\tCOVID-19 aside, the spaces provided by this policy approach offer health benefits in themselves. This is one of the reasons the NPPF advocates ensuring access to the outdoors and to open spaces. A permissive policy which facilitates the use of these spaces for eating and drinking provides an alternative (and arguably healthier) experience for visitors to towns and other places across the SLP area.\n \n14.\tAn additional benefit is improving/increasing active frontages within town and local centres. This contributes to a feeling of vitality and vibrancy which again has a positive effect on spending and the local economy. Many local authorities, particularly in London recognise that commerce which is within and visible from the public realm can add to the diversity and vibrancy of city life and support economic development. It creates a welcome ‘feel good’ factor, the associated benefits of which can be many and wide reaching.\n\n15.\tPolicies in a similar vein exist to specifically support Cheltenham Racecourse and Gloucestershire Airport (both under JCS policy SD5), recognising the importance of these facilities to the local economy. The policies acknowledge that development in the green belt, as an exception to the general approach of development restraint in these locations, is necessary to support the businesses at these sites, as defined on the JCS policies map. The same\n‘zoning’ approach is not appropriate for the proposed hospitality policy because of the geographical range and diversity of the businesses involved. As many businesses as possible should have the right to benefit from the policy, and defining specific areas where the policy applies risks undermining what the policy is seeking to achieve.\n\nComments on the SLP Consultation Document\n\n16.\tPart of the draft vision in the SLP consultation document is to “create beautiful, thriving, energy efficient, resilient and healthy places”. Also, “the vital role of the area’s city centre, town centres and high streets will have been improved through careful management of development and land uses”. The suggested policy will greatly assist these aspects of the vision for the reasons stated throughout this submission.\n\n17.\tIn terms of the draft strategic objectives, also outlined in the consultation document, the following are relevant;\n\ni)\t“making the most of previously developed land, including higher density development in city and town centres and other locations well served by public transport” – this should apply to all types of development not just residential development.\nii)\t“providing the right conditions and sufficient land in the right locations to support existing and new businesses”\n \niii)\t“developing the area’s role as a tourist destination, building on the unique and varied cultural offer that already exists”.\niv)\t“Ensuring a network of city and town centres that meet the needs of communities…and that are able to respond and evolve as the role and function of centres change”.\nv)\t“Support the provision of a wide range of different uses appropriate to city and town centres…to create activity at different times of day and build an active city and town centre community.”\nvi)\t“ensure new developments…prioritise health and wellbeing”.\n\n18.\tThe emerging strategy identifies several key propositions to support the strategic objectives, one of which is to ensure business support, providing an offer “to enable businesses of all sizes and types to innovate, create jobs and positively contribute to the transition to a low carbon economy”. For reasons stated within this submission, the proposed policy is designed to do just that.\n\n19.\tAt paragraph 5.44, the consultation document acknowledges that people now look to town centres “for shopping and leisure experiences, and good quality and varied hospitality”. At 5.45 “there is now a need to re-think the role of our city and town centres and establish a long term strategy that allows them to be flexible, adapt, evolve and thrive”. The proposed policy is drafted with this exact purpose in mind.\n\n20.\tIn respect of our work for hospitality businesses across the SLP area, we have the following responses to questions in the SLP consultation document;\n\n21.\tPlease contact me should you find it helpful to discuss the information included in this submission."]
["","","","","Cheltenham have very little land to expand so this council needs to look at town centre for their development.  But once Cheltenham have developed all their possible area it is full.  You can’t keep building and building without detriment to the existing town and the standard of life residents should be able to expect.  However Cheltenham do have some room for expansion, there is a certain car park that for over ten years was going to be for housing and still nothing.  There are plenty of empty shops/offices that could be developed for housing.  If Tewkesbury still wants to market itself as a small market town then keep it as a small market town. Gloucester needs to look to the south to expand, not towards Cheltenham.","No","Too generic and fine words, could be anywhere","No","There are items that the SLP cannot have a direct impact on so unsure why they are in?  Anything which require government spending or private companies investment.\n\nDo not agree with point 3 under Building strong, competitive and sustainable urban and rural economies- why encourage farm diversification?  Should be encouraging farms to farm not encourage them to make more money from using their existing buildings for non farming activities, what does rural business use mean?  Does it mean sheep shearing or does it mean any business but in a rural setting??","By not building on green field sites, by providing free public transport and free train travel, by insisting all new developments have solar panels fitted as standard, by helping existing business and homes to fit solar panels by providing interest free loans/grants.\n","Solar panels mandatory","","Yes","Yes","Chargrove Lane, the small nature reserve on Chargrove Lane, and surrounding area towards Hatherley and Shurdington. Regeneration of the perry orchard and mixed fruit orchard at both ends of Chargrove Lane which needs to be protected and for wildlife/biodiversity and the foot paths and lane is already widely used for recreation and should be protected from development.. \nBadgeworth village the centre is relatively un- developed with plenty of footpaths so could be used of wildlife/biodiversity net gain and recreation especially with the SSSI for the buttercup, Cold Pool Lane should be protected from development and additional traffic movements, polluted run off from Up Hatherley and Cold Pool Lane has to be avoided.","All, doctors, hospitals, shops, libraries, schools ","No","","","","Yes","constraints of greenbelt, AONB, damage to or degrading areas close to SSSI or habits of protected species, removal or building near ancient/veteran trees.  It is not houses trumps all","Yes","This is obvious and not sure why it is a question, there are too many large luxury houses built, more bungalows for people with mobility issues but then even if this happens when applications are made to change these to dormers the councils should not allow this because if the design and mix of housing was decided when any development was originally planned this is lost. More council houses that can not then be sold off to private buyers, so lost to those who really cannot afford to buy their own home or commercial rental.  ","","","","","Not sure how this can be achieved by the councils as this is driven by private companies. ","By encouraging farms to be farms, by protecting greenfield areas and greenbelt land from development to ensure there is sufficient land available for real rural employment so real rural business are not forced out of the land because it is more profitable to build houses.","","By not allowing rural properties to be holiday homes, AIRBNB, second homes and having real communities live in real villages. ","","Roads, proper sewers not pumping waste into watercourses.","Rural settlements are not going to be suitable for new homes if you want to address climate change, because of the rural nature and the lack of reliable and frequent public transport the car will be king.  No bus company is going to lay on a good bus service for one or two passengers a day.  Most development in rural areas ends up being luxury homes so the residents would not use the bus anyway.","No","","","No","I don’t think so, too weighted to development.","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement","","","[Q1] No more than 10 years from 2031 to 2041, who knows what is going to happen any further into the future, otherwise you are locked in to a plan that is no longer relevant\n\n[Q8] Of course we require more than 10%, there are years of not paying any attention to or providing for biodiversity when deve;opment has happened to catch up on.\n\n[Q11] No this is still a developing sector so there should be flexibility. Generation should be coming from all and business rooftops through solar power, no great big solar farms please\n \n[Q.29] Only \n1.\tUrban concentration\n2.\tUrban extensions, avoiding the Green Belt\n3.\tNew strategic settlements\n4.\t\nNo - to urban extensions into the greenbelt, The greenbelt is already small, there should not be any coalescent of Cheltenham and Gloucester, the greenbelt should not be eroded every ten years when a “new “ plan is produced to fit in houses, if it becomes any smaller it will not do the job it is meant to do by stopping Cheltenham and Gloucester from joining up.  Greenbelt boundaries are meant to be permanent. \nNo -  to rural dispersal, this would go against your climate change policies with reliance on car travel, could swamp existing villages/communities with no facilities, are more likely to be luxury houses rather than farm worker cottages or social houses. Could also further erode the greenbelt, no more development between Churchdown, Badgeworth, Shurdington and Hatherley\nNo – to sustainable travel route development, this would lead to ribbon development and would also erode greenbelt.]\n\n[Q31] Not clear why the SLP is not just looking at development from 2031 when JCS plan has come to an end, it appears from your plans that the SLP will replace the JCS rather than follow on from.  Considering the time, effort and expense of the JCS why is this not being followed through.\nThe JCS was meant to be a way of planning where development was taking place and the size and design of developments.  However, this has not happened at Leckhampton because the developers have done their own thing, what confidence can we have that SLP will be any better?\nMention is made of the greenbelt review but no details at what stage this is likely to happen and whether the public will have any say in this.  It is my understanding that the greenbelt should only be changed in exceptional circumstances, and I believe the government have recently proposed that LPA’s are not required to review and alter the greenbelt boundaries if building on greenbelt is the sole way of meeting housing needs.  I understand that changes to greenbelt boundaries are only allowed in exceptional circumstances.  What exceptional circumstances do Cheltenham, Tewkesbury and Gloucester borough councils think forces a greenbelt review.\nThe JCS quite rightly was Gloucester housing needs should be met on Gloucester land, Cheltenham on Cheltenham land and Tewkesbury on Tewkesbury land.  As the JCS went through all the legal stages and this was agreed why is the SLP without public consultation seemingly changing this agreement?\nOnce any plan is in place, JCS/SLP, then the no 5 year availability of land cannot and should not be allowed by councils to allow developers to develop where they want, as currently happens.\nThe SLP website and the multiple ways of responding is an absolute nightmare, unless you have two screens so you can view the Reg 18 doc as you can respond to questions.  The SLP has not been widely advertised, evidenced by the low numbers reported at in person events, most people I have spoken knew nothing of the public consultation, nothing in the local press and only very recently on local radio.  Anyone who does not have access to internet or is not familiar with using websites has basically not been given a fair opportunity to have their say on the SLP.  Really not inclusive.  The SLP team needs to do more to engage with the public, make the website and ways to respond more user friendly and easier to navigate.  "]
["Statutory/Specific Consultee","CPRE Gloucestershire","","No. The list in paragraph 20 of the NPPF is sufficient.","Any such topics should be dealt with by the local element of the SLP for the three constituent authorities.","Yes","Insofar as such visions have value, this is satisfactory.","Yes","These are satisfactory. We would like to see at subsequent stages of plan preparation adequate integration of objectives and policies.","We think there are four main issues here. The first three are the most directly connected to planning. First, CPREG accepts that a significant amount of development will need to be provided for in the SLP, whatever the duration of the new Plan period. We also recognise that if as we think likely the capacity for new development in Gloucester and Cheltenham is even less than when the JCS was prepared, a greater proportion of it will necessarily take place in Tewkesbury Borough. The three councils should consider the extent to which a proportion of the requirement might be accommodated more satisfactorily in adjacent authority areas. For the avoidance of doubt, we mean specifically the possible revival of the scheme at Mitton (in Wychavon District) and the extent to which the proposal at Whaddon (in Stroud District) can be regarded as helping to meet the needs arising from Gloucester. We do not mean Forest of Dean District – or Cotswold District, for that matter. Please also see our response to Question 29 in this context. The issue of the total amount of development in the Plan area cannot usefully be addressed at this stage because the end date for the new Plan has not been set. However, the distribution of new development in Tewkesbury Borough is a crucial issue, in terms of access to jobs, services and facilities, and the extent to which the use of the private car can be avoided or discouraged. Important areas in terms of landscape, biodiversity and the cultural heritage need to be safeguarded from development, together with land at risk from flooding. A significant part of Tewkesbury Borough is within the Cotswolds National Landscape. We say more about the now limited degree of strategic choice in Tewkesbury Borough below in respect of the six development scenarios. Secondly, the retention, adaptation and reuse of existing buildings will we think in most cases be a more sustainable option than redevelopment. However, we recognise that this will not always be possible. Thirdly, new homes need to be at least carbon neutral and built with solar panels, heat pumps and the best available insulation. We note (and are encouraged by) a recent appeal decision on a site in Leckhampton in which such factors played a significant part. Fourthly, there are a number of ways in which the natural environment can be managed in order to mitigate the effects of climate change. We encourage the three councils to attach significant weight to the representations made by the Local Nature Partnership and nature conservation organisations such as the Gloucestershire Wildlife Trust.","As noted also in response to Question 6, the retention, adaptation and reuse of existing buildings will in most cases be a more sustainable option than redevelopment. If the three councils consider that going beyond relevant national standards is desirable (which we consider they should), then full justification and appropriate policies should be included.","As noted also in response to Question 6, the retention, adaptation and reuse of existing buildings will in most cases be a more sustainable option than redevelopment. If the three councils consider that going beyond relevant national standards is desirable (which we consider they should), then full justification and appropriate policies should be included.","","","Since most land is privately owned, we think that any such land could be identified by means of an equivalent of a call for sites for housing and commercial development. However, since such uses are unlikely to return a profit, any approach along these lines should be accompanied by appropriate policies and references to potential sources of funding. The Gloucestershire Local Nature Recovery Strategy currently in preparation will inform where off-site biodiversity net gain receipts might effectively be invested. Ideally off-site net gain receipts should be invested locally. The Gloucestershire Nature and Climate Fund has been set up to help facilitate this and should be referenced in the Plan. There are potential conflicts between the first five of the considerations in the question and the last. We are not sure what is meant by “identifying” land for food production. Much of the land in Tewkesbury Borough which is not urban or woodland is already in food production. Some measures which bring about wildlife and biodiversity net gain, for example leaving a five-metre uncultivated margin on the edge of an arable field, reduce the potential for food production and in any case are outside the control of the planning system. The three councils should give appropriate weight to footnote 62 attached to paragraph 181 of the revised (2023) NPPF which says that ‘the availability of agricultural land used for food production should be considered, alongside other policies in this Framework, when deciding which sites are most appropriate for development.’ The higher the agricultural land quality, determined under the Government’s ALC, then the greater the potential for contributing to food production.  Therefore, agricultural land quality should be a particularly important factor to be considered in deciding where significant new development should be sited where greenfield land is involved. \nIn respect of the Green Belt, the three councils have as far as we are aware done nothing to promote what in earlier guidance were called the objectives of the Green Belt, but which have been retained in the form of paragraph 150 of the NPPF and are reinforced by the last sentence of paragraph 147. Paragraph 150 states: “once Green Belts have been defined, local planning authorities should plan positively to enhance their beneficial use, such as looking for opportunities to provide access; to provide opportunities for outdoor sport and recreation; to retain and enhance landscapes, visual amenity and biodiversity; or to improve damaged and derelict land”. We would expect policies to be on the whole even handed in their spatial application but recognise that the Green Belt is the nearest countryside to a large proportion of the Plan area’s population and where greatest enhancement is needed.","Much depends on how “easy reach” is defined, both in terms of distance and ease of access by sustainable means of transport. The decline in services in rural areas has been going on for decades and may even be accelerating. The existence or otherwise of many services depends on commercial decisions over which the planning system has little if any control, and not much influence either. Not all attempts at the community takeover of (for example) shops and public houses have succeeded. Having said that, we regard the following as the most important: primary school, regular and reliable public transport, community hall, small supermarket or convenience store, Post Office and public house.\nIn addition, in the context of this group of questions, we consider that easily accessible green space is very important. The planning system has control over this only in new developments; we note for example the varying proportions of land for green infrastructure within the boundaries of the indicative site layouts for the JCS strategic allocations. Elsewhere, the three councils along with the County Council as public rights of way authority should explore ways in which connectivity to the wider countryside could be improved, particularly on the edges of built-up areas.","","We think that such developments should mainly be dealt with by means of criterion-based policies. Energy generation is in our view a national issue. The scope for renewable energy generation locally by any means varies considerably and the councils should avoid setting local targets. The councils might usefully give thought to identifying additional areas outside those covered by national landscape designations where they consider such schemes, especially extensive solar farms, should not be developed.  The currently deployed technology results in field based solar arrays effectively precluding significant agricultural production on the land for the life of the contract, even though the land quality itself may not be permanently damaged.  That long term loss (30-to-40-year contracts) of capacity for food production is especially substantial where the land is of ‘best and most versatile’ quality. The time frame is well beyond the likely end date of the SLP; food production and security will become even more important in that time frame. The three councils should promote the installation of solar panels on the roofs of new large commercial buildings and encourage their use on existing buildings, and over large outdoor car parks in appropriate locations.","No","Paragraph 61 of the revised (2023) NPPF makes it clear that the outcome of the standard method is an advisory starting-point for establishing a housing requirement for the area. This is not a change in guidance. The current Practice Guidance states that the use of the Standard Method is not mandatory and enables Councils to consider an alternative approach if they consider circumstances exist.\nWe think that the Councils should consider an alternative approach, for three main reasons.\nFirst, such an approach should take fully into account what we have long regarded as significant overprovision for the current JCS period. The total housing requirement for the period 2011 to 2031 was set in JCS Policy SP1 at 35,175 dwellings, or 1,759 a year. One significant element was the level of anticipated economic growth and therefore labour demand (Table SP1b), which would be matched by an increased level of housing provision. As far as we are aware, the actual growth in the County’s economy has been significantly less than the 4.8% annual growth of GVA projected by the GFirstLEP and accepted by the councils and the Inspector.\nSecondly, there is the question of realism. As far as we can tell from the available figures, which are very poorly presented, total housing completions in the Plan area from 2011 to 2023 fell significantly short of the cumulative requirement for that period. This means that completions for the remaining eight years of the Plan period would need to increase by an amount which we think is unrealistic. In particular, although good progress has been made on some of the strategic allocations designed to meet Gloucester’s needs, the same is not true of those serving Cheltenham.\nThirdly, it is a question of capacity to accommodate development in parts of the County. Unconstrained capacity no longer exists, in our opinion, anywhere in Gloucestershire. In the SLP area, it is considered likely that the capacity of Gloucester and Cheltenham to accommodate more development will be found to be even less than when the JCS was prepared, increasing the pressures for further development in Tewkesbury Borough.\nThe three councils should take full account of the seventh Report of Session 2022-23 of the House of Commons Levelling Up, Housing and Communities Committee on reforms to national planning policy. In it, serious reservations are expressed about the fitness for purpose of the Standard Method.\nFor these reasons we conclude that circumstances exist to justify an alternative approach.","Yes","CPREG considers that a significant change took place around 2011. This was the year that the last Structure Plan expired; the County Council had by then already lost any significant strategic planning powers. More importantly, it also marked the point where most of the need arising from Gloucester and Cheltenham as settlements could no longer be met within their administrative boundaries. Since the JCS area did not include Stroud District, it meant that much more development would have to be accommodated in Tewkesbury Borough, and this was reflected in the adopted JCS which included the six strategic allocations. At the time, CPREG recognised that some land would have to be released from the Green Belt, and objected in principle only to strategic allocation A2 on the grounds that it would result in the near coalescence of Gloucester and Churchdown. However, the degree of strategic choice for major new development in Tewkesbury Borough is now even less. Significant further releases from the Green Belt would almost certainly be inimical to the purposes of Green Belt. About 40% of the Borough lies in the Cotswold National Landscape, in which national policy provides that major development should not take place. Tewkesbury Borough also includes both sides of the River Severn between Tewkesbury and Gloucester. Major development should not take place here for reasons of flood risk, other environmental issues, and accessibility.","Yes","The three councils should take full account of paragraph 63 of the revised NPPF and then devise effective policies so that those varied needs can be adequately met. That paragraph states: “These groups should include (but are not limited to) those who require affordable housing; families with children; older people (including those who require retirement housing, housing-with-care and care homes); students; people with disabilities; service families; travellers; people who rent their homes and people wishing to commission or build their own homes.”","","","","The three councils should first of all take a clear (and realistic) view of the prospects for the economy in the Plan area. Neither the SLP area nor the County as a whole is a self-contained system; the smaller an area, the greater the extent of cross boundary journeys to work. The SLP should strike a balance between job and housing growth which recognises the concentration of the County’s jobs within it and the extent of interaction between (for example) south Worcestershire and the Tewkesbury area. For decades there has been a difference between planning for housing and planning for employment. Land allocated for housing is almost always developed and its output is fairly predictable. Land allocated for employment uses on the other hand is often slow to come forward and may in some cases not be developed at all. The link between the amount of land allocated for employment uses and the number of jobs arising is much less predictable, and a high proportion of jobs are not located on land allocated for the purpose. Nowhere in the consultation document is there any indication of the number of jobs likely to come forward in the plan period (however long that is) and the number likely to be lost in existing sectors, and the balance between them. It is very important to get this right. The excessive housing numbers in the JCS were a consequence of unrealistic growth figures from GFirstLEP which would have required significant in-migration, or increased in-commuting, to fill all the jobs.","The three councils should first of all take a clear (and realistic) view of the prospects for the economy in the Plan area. Neither the SLP area nor the County as a whole is a self-contained system; the smaller an area, the greater the extent of cross boundary journeys to work. The SLP should strike a balance between job and housing growth which recognises the concentration of the County’s jobs within it and the extent of interaction between (for example) south Worcestershire and the Tewkesbury area. For decades there has been a difference between planning for housing and planning for employment. Land allocated for housing is almost always developed and its output is fairly predictable. Land allocated for employment uses on the other hand is often slow to come forward and may in some cases not be developed at all. The link between the amount of land allocated for employment uses and the number of jobs arising is much less predictable, and a high proportion of jobs are not located on land allocated for the purpose. Nowhere in the consultation document is there any indication of the number of jobs likely to come forward in the plan period (however long that is) and the number likely to be lost in existing sectors, and the balance between them. It is very important to get this right. The excessive housing numbers in the JCS were a consequence of unrealistic growth figures from GFirstLEP which would have required significant in-migration, or increased in-commuting, to fill all the jobs.","The SLP must do nothing to discourage existing rural activities, notably farming. Particularly where these cannot of themselves be made profitable, the SLP should encourage rural employment by facilitating the reuse of farm and other buildings for small enterprises. However, it should also include policies which cover the type of enterprises appropriate in rural areas and include appropriate criteria to deal with impacts.","CPREG is not certain how this could be achieved. However, we recognise that thriving town centres are important. Despite the decentralisation of retailing in the last forty years and the more recent impact of online shopping, town centres remain important for their shops and other services, and for cultural and entertainment activities. Importantly, they are accessible to many by sustainable means, and there may be greater opportunities for people to live in or near town centres which would enhance their viability and aid regeneration.","Please see the answer to Question 10.\n\nMuch depends on how “easy reach” is defined, both in terms of distance and ease of access by sustainable means of transport. The decline in services in rural areas has been going on for decades and may even be accelerating. The existence or otherwise of many services depends on commercial decisions over which the planning system has little if any control, and not much influence either. Not all attempts at the community takeover of (for example) shops and public houses have succeeded. Having said that, we regard the following as the most important: primary school, regular and reliable public transport, community hall, small supermarket or convenience store, Post Office and public house.\nIn addition, in the context of this group of questions, we consider that easily accessible green space is very important. The planning system has control over this only in new developments; we note for example the varying proportions of land for green infrastructure within the boundaries of the indicative site layouts for the JCS strategic allocations. Elsewhere, the three councils along with the County Council as public rights of way authority should explore ways in which connectivity to the wider countryside could be improved, particularly on the edges of built-up areas.","Major development must be accompanied, and if necessary preceded, by all of the following: roads, including sustainable transport infrastructure, green infrastructure, appropriate provision for all utilities including water, energy and telecommunications, primary and if necessary secondary education, primary healthcare services and other community facilities including meeting places.","Please see the answer to Question 23. Major development must be accompanied, and if necessary preceded, by all of the following: roads, including sustainable transport infrastructure, green infrastructure, appropriate provision for all utilities including water, energy and telecommunications, primary and if necessary secondary education, primary healthcare services and other community facilities including meeting places.","We consider that the most important single facility is a primary school. However, the existence of a primary school does not in itself justify a level of development or any at all. The existence of otherwise of particular services is not the only criterion of suitability. Proximity to services and facilities in nearby larger settlements may justify development in rural settlements which do not themselves possess them. In both instances the continued existence of a bus link is very important.","Yes","No","As we have observed elsewhere, the scope for strategic choice for major development in Tewkesbury Borough is very limited. Not all the scenarios individually would provide for sufficient development, even at the lower levels we consider appropriate. Nor are the scenarios sufficiently different (or differentiated) to allow for any plausible additional scenarios.","Yes","The assessment is in our view reasonably fair and accurate. However, the important issue is whether the three councils can evaluate the advantages and disadvantages of each scenario effectively. We have in the past been concerned about the very crude scoring systems in sustainability appraisals which have not necessarily led to the best outcomes.","","Yes","As far as CPREG can tell, the rural settlement hierarchy is not actually set out in the consultation document. We consider that significant mistakes were made in the definition of the service villages in the JCS (why, for example, Woodmancote was treated separately from Bishop’s Cleeve, and why Minsterworth was identified at all, which has led to the proliferation of ribbon development along the A48). We think that if the category “service village” is to be carried forward from the JCS to the SLP, there should be fewer of such settlements. Too many were defined on the basis of a really quite limited range of services. Not all of them had a primary school, or in the case of Minsterworth, one with a viable future. We think that a primary school should be a necessary but not sufficient condition for a service village. We also think that the ability of primary school age children to attend school in their own community (subject to the exercise of parental choice) is a very important criterion of sustainable development and social cohesion.",{"$cut":{"chars":19070,"head":"[Introduction] CPRE Gloucestershire (CPREG) welcomes the opportunity to comment on the first stage of preparing a successor to the Joint Core Strategy. However, we consider that the consultation, and in particular this document, have serious shortcomings. The background to the JCS is not adequately explained. Little information is provided which would help elicit an informed and constructive response from any interested party. Cross referencing to the evidence base is wholly unsatisfactory. All these shortcomings are especially disappointing in the light of the failure of the three Councils to take appropriate action to remedy the shortfall in housing provision which originated from the lack of availability of the MOD Ashchurch site, on which the JCS had relied for over 2,000 dwellings in the Plan period to 2031. That remedial action was committed to in JCS Policy REV1 - an immediate review to address the shortfall, but which never took place.\n\n[Q.1] First of all, we think that the three councils should have taken a decision on this issue before consultation started. Even at an issues and options stage, CPREG is not aware of any other consultation exercise in which the duration of the plan period had not already been decided upon. This has the effect of creating greater uncertainty than is necessary and significantly reduces the value of any responses to many of the other questions. Current guidance states that development plans should have a life of fifteen years after adoption. As far as we are aware, it had been earlier suggested that the review of the JCS should run to 2041. However, this would mean that the SLP would need to be adopted by 2026, which is long before the date of adoption set out in the latest Local Development Scheme. We nevertheless consider that no useful purpose would be served by extending the Plan period beyond 2041. The councils should concentrate on getting the SLP adopted as quickly as possible to provide certainty in the planning process and then embark on an immediate review to roll the plan further forward. \n\n[Q.8] The three councils should concentrate first on securing the mandatory minimum 10%. We think it would be difficult, subject to the opinion of specialist environmental organisations, to justify a higher percentage at this point in time.\n\n[Q.9] Since most land is privately owned, we think that any such land could be identified by means of an equivalent of a call for sites for housing and commercial development. However, since such uses are unlikely to return a profit, any approach along these lines should be accompanied by appropriate policies and references to potential sources of funding. The Gloucestershire Local Nature Recovery Strategy currently in preparation will inform where off-site biodiversity net gain receipts might effectively be invested. Ideally off-site net gain receipts should be invested locally. The Gloucestershire Nature and Climate Fund has been set up to help facilitate this and should be referenced in the Plan.\nThere are potential conflicts between the first five of the considerations in the question and the last. We are not sure what is meant by “identifying” land for food production. Much of the land in Tewkesbury Borough which is not urban or woodland is already in food production. Some measures which bring about wildlife and biodiversity net gain, for example leaving a five-metre uncultivated margin on the edge of an arable field, reduce the potential for food production and in any case are outside the control of the planning system. The three councils should give appropriate weight to footnote 62 attached to paragraph 181 of the revised (2023) NPPF which says that ‘the availability of agricultural land used for food production should be considered, alongside other policies in this Framework, when deciding which sites are most appropriate for development.’ The higher the agricultural land quality, determined under the Government’s ALC, then the greater the potential for contributing to food production.  Therefore, agricultural land quality should be a part"}}]
["Resident",null,20,"","","No","Do not see how it will succeed with the current transportation system and proposed transport options either will not succeed or lack finance.","No","Think in regard to housing and some employment options re-using closed retail buildings will provide higher density housing, like possibly Cavendish House. In Gloucester Debenhams becoming the university which in turn brings people into the centre.","","","","","","","","","","Yes","","No","","","","No","","","","","","","","effective, usable, deliverable transport : facilities and amenities that mean travel is not necessary","on-site facilities to remove the need to travel - so the obvious schooling, shop, food, community and place to meet. However employment needs to accessible","again school, shop, food, community, meeting places - new development needs to be supporting the future of the settlement not over whelming it","Yes","Yes","revitalising the centres of Cheltenham and Gloucester, which is already happening in Gloucester","No","generally yes, but think there needs to be a mix of all 6 scenarios","Scenario 5: Rural dispersal; Scenario 4: New strategic settlement","No","",""]
["","Conault Design",20,"","There is still a fundamental issue, in that that much if not the majority of the suburbs of Cheltenham and Gloucester are in Tewkesbury Borough or indeed in the case of Gloucester, Cotswold District Council, so while most of us may have Cheltenham or Gloucester postcodes or an old landline with a Cheltenham and Gloucester code we pay rates to Tewkesbury and have no representation in the town or city we are closest to and relate to and where most the facilities we use are located. Although I much prefer Tewkesbury’s  bin collection and recycling system.\n","No","I believe at a fundamental level growth and increase in population is not compatible with net zero biodiversity or protecting natural habitats. I consider the policies Green Washing and putting “Green” in front of “Growth” or “Cyber” Infront of “Park” is no different to when we renamed Industrial Estates , “Technology Parks”. You can mitigate the impact but it is still development on green field sites to the detriment of the environment. ","No","To date new infrastructure such as the Arle Court Transport Hub and the implementation of the cycle route between Cheltenham and Gloucester  has led to the destruction of marginal but valuable natural habitat, used masses of concrete and steel, resulting in the urbanisation of areas formally semi-rural in character and all to facilitate new expansion of the interchange with the M5 and urban expansion on green field sites.   \n\nI don’t see how the statements about brown field land is compatible with the existing JCS and removal of larger areas of agricultural land from the green belt. ","Resist the pressure to build new housing and increase population growth which is incompatible with the Climate Change Agenda and is creating a more urban environment changing the Character of Cheltenham and Tewkesbury.\nEncourage in the Centre of Gloucester the reuse brown field sites and  accommodation over shops bring back a more wealth population to the City Centre. But this is not straight forward, it is limited by Building Regulation restrictions which are required. We need to find a way to subside this rather than so called “low cost “ housing and to reinvigorate the City Centre. Currently Planning, Building Regulation, Parking and Environmental concerns make the regeneration of the City Centre outside of the very large projects unfeasible, you can see from Cheltenham that living in an urban centre can be very desirable and for your leisure, shopping and often work, transport free, but this has to be a choice and from the point of view of someone frequently working on projects in Cheltenham town centre, keeping our town vibrant, the ability to park, accept deliveries around the clock and for tradesman to park there vehicle outside the property they are working on makes and enormous difference.","","It should require all commercial buildings with medium to large roof areas to incorporate the maximum amount of PV solar panels to reduce the use of farming land. In addition industrial and larger scale commercial generally has a significant power requirement and where there is excess they are normally close to substations and other infrastructure required to transfer power to the grid.","","Yes","You could return the hideous Arle Court Transport Hub back to the green fields that was there before the park and ride ","Shops, chemists, dentists, doctors surgeries and pubs with extended food offer, open green space.","Yes","You should use industrial and warehouse roof space for PV Solar before coving agricultural land.","","","Yes","I do not agree that economic and population growth is compatible with the green agenda, I consider the mitigation “Greenwash” and it is changing the character of three semi-rural communities into a more urban metropolitan feel.","Yes","I think it should avoid so called “low cost” and shared ownership schemes which is Community Infrastructure Levey exempt, often developed on subsidised land and land not otherwise deemed suitable for house building in green belt or flood zones,  offering restrictive or lease hold tenure for 90% of the market price which offers poor value to the tenant/owners and taxpayer. \n\nWhat has happened to the billions of pounds of housing stock and land transferred to Housing Associations?","No","","Semi-rural with good transport links, ideally on traditional routes.","Upgrading and improvement of Gloucester City Centre to match that of Cheltenham with limited and convenient free parking whilst developing a city centre population and facilities within walking distance and reverse the trend to move supermarkets and other retail out of the town centres due to the cost of parking and a hostile environment to road transport including deliveries and workmen. \nWhereas I used to use the Quays, since the privately provided free parking has gone I haven’t visited or purchased anything, which actually is the same reason I stopped spending at House of Fraser in Cheltenham. You no longer have congestion in the City centre only dereliction. \nWe have by and large moved to more environmentally friendly cars , even though the Government has changed the date, my next car will most likely be electric. Congestion outside the centres is caused by displacement and population growth .","","","Need to encourage good quality housing in the town centre but also reverse the policy of increased parking charges and restrictions on private vehicles. When the alternative is online shopping or free parking at out of town shopping people vote with their feet, its simply too difficult and makes no economic sense to shop in a city centre shop when it costs more to park than the cost of postage to your door. A client viewing one of the many empty historic listed building in Gloucester said, “parking makes a massive difference to the viability of a restaurant”.","Resist change of use of rural shops and pubs to housing otherwise without social hub rural villages are just a dormitory for adjacent towns., but again resist parking charges which makes it more attractive to drive to a supermarket with a free carpark and cheaper prices on the outskirts of an adjacent town and at the end of the day what the council gains in parking revenue it looses in business rates and ultimately there is not enough shops to draw visitors so ultimately you lose parking revenue.","Shops, Schools, dentists, doctors, supermarkets and pubs with extended food offer","Shops, Schools, dentists, doctors, supermarkets and pubs with extended food offer. ","Shops, pub with extended food offer. ","","Yes","The SLP, bringing’s together Cheltenham, Gloucester and Tewkesbury and gives an opportunity to rebalance end level up areas with the most potential.\nWhilst limited consolidation and improvements in Cheltenham should be welcomed, other than with some noticeable exceptions such as the future of Cavendish House, the value and return on property means that sites rarely remain undeveloped and are self-funding and deliver their economic potential. \nGloucester as a City is small and whilst it once had a wealthy professional and merchant class living in the City Centre, in a similar way to large properties in Cheltenham, they crudely subdivided into bedsits. As town centre living has become more desirable, in Cheltenham most of these properties have been converted back to single dwellings or larger flats and whilst on the face of it this is a loss of housing units, the quality of the bedsits was very poor as was the condition of the historic buildings which resulted in a population with any disposable wealth moving out into the surrounding countryside. However this shows a model for the regeneration of Gloucester City Centre, encouraging wealth back into the City to support retail and the nighttime  economy and generate a more conducive atmosphere to live and invest, resulting in the better utilisation of Buildings and vacant brown field sites, ultimately compensation for the loss of very high density low quality dwellings which in turn will encourage businesses to locate in and around Gloucester. \nGloucester is a City because it was the lowest crossing point on the Severn for thousands of years. At one time businesses located next to natural resources or crossing points where market opportunities existed and labour followed, now labour is the natural resource and businesses move to an area which is considered desirable to live where they can attract the best labour. \nTewkesbury has a different set of issues, not so much hollowing out of the core but a change in retail meant that the smaller units were not suitable for modern retail especially as the wider population grew, however given the historic nature of the Abbey, Town and Battlefield you can see an opportunity for small artisan niche businesses and this ties in nicely with the Cathedral in Gloucester, its historic Buildings and Cheltenham as a tourist destination. \nThere is s strong argument that the development and increase in size of Cheltenham and the residential expansion into Green Belt around Cheltenham and Tewkesbury is at the expense of Gloucester and Cheltenham risks overtaking Gloucester ultimately to the detriment of both as large infrastructure projects in and around Cheltenham inevitably changes the character and it is no longer a regional town and becomes far more urbanised, where as Gloucester as City perhaps lack the urban character that City Status would suggest.","","I think the illustrative diagrams are misleading and needs further detail unless you have managed to locate and download the JCS maps.","","","","[Q8.] It should require all commercial buildings with medium to large roof areas to incorporate the maximum amount of PV solar panels to reduce the use of farming land. In addition industrial and larger scale commercial generally has a significant power requirement and where there is excess they are normally close to substations and other infrastructure required to transfer power to the grid.\n[Q12.] I do not agree that economic and population growth is compatible with the green agenda.\n[Q15.] I am not a traveller and live in a semi-rural location and get on well with the traveller community when I come into contact with them, whilst trying not to stereotype anyone, I cant see that very formal structured sites, inevitably limited in area, with possibly unsympathetic neighbours  seems compatible to the traditions and lifestyle for many. \n[Q29.] If we accept the housing targets and I still believe at a fundamental level growth and increase in population is not compatible with net zero, biodiversity or protecting natural habitats. Scenario 2, 3, 4, 5 and 6 would not fulfil the commitment to develop brown field sites and It makes far more sense to have hybrid solution which would deliver a wider range of benefits and range of properties. \nScenario 1 for Cheltenham does not make any sense. Cheltenham shows that green space and diversity of good quality housing makes living in a town centre very desirable and supports local restaurants, independent and chain shops as well as music events, churches and many community activities, all within walking distance. \nOvertime, sites such as St. James and the Old Police station have been developed to a high standard and relatively high density and the model of a Regency terrace at three, four or five storeys is currently being suggested as a blueprint for high density living. Whilst there will always be some opportunities for development the scope in Cheltenham is very limited having already in the main been developed and having achieved a good mix and equilibrium.\nOn the other hand, whilst Gloucester docks, after a slow start has developed into a thriving mixed community with a good mix of retail, leisure and residential space, the City centre despite a wealth of Historic Buildings and fantastic Cathedral requires serious determination to develop the link between the City Centre and the docks and new quality housing in the city centre, on redundant sites in redundant buildings as well as the development of the former prison site and rehabilitation of the properties in Montpellier and in and around the Park ideally to bring back into the town centre professional people and families to support a better mix of  businesses and higher level of sustainability. Gloucester has great potential which needs unlocking and as a city would lend itself to high density living. The only way to do this is to ensure the easy options on green field sites are limited, however this in itself would not be enough if we accept the housing targets and a version of Scenario 2 or 3 would be required.\n[Q31.] It should be noted that CO2 emissions from all domestic transport dropped 22% between 1991 and 2020  and PM10 Particulate has fell 65%, PM2.5, 74%, NOx 78%, Co2 96%, Benzene 87%, Buadiene 98%, Lead 98%, Sox95% (table ENV0301). Which indicates that the money spent on ULEZ implementation in London and Bristol and other measures elsewhere would have been better spent on  electric charging infrastructure, the control of dirty vehicles through the MOT process and maintaining the earlier date for the phasing out of new petrol vehicles rather than draconian and oppressive restrictions which are damaging our town and city centre economies."]
[null,null,10,"No","","No","The vision is trying to be everything to everyone with many aims that are going to conflict with one-another.","No","Too many objectives with many that conflict with one another. There needs to be some difficult prioritisation work undertaken, and ultimately some groups will not be happy. What is fundamentally most important to ensuring strong and self-sustaining communities? Can we pick three things? Just stating ‘mitigating climate change’ isn’t an enough as an aim.","Investment in public transport infrastructure is key. But fundamentally without jobs that are nearby those transport hubs a majority of people will continue to use cars.","","","","No","","Schools, dentist and GP","Yes","Solar","","","","","","","No","","","How do we encourage high tech industry including cyber and precision engineering firms to invest in the area?","Look at how Manchester has encourage private investment, is there something to learn here?","","","","Schools, dentist, GP. Roads that support increase in traffic.","Schools, dentist, GP. Roads that support increase in traffic.","","","No","","Yes","","Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","No","",""]
["Planning agent or developer","Evan Jones","","Given the considerable amount of Green Belt across the SLP area, this will have a direct  bearing on the location of new development, The purpose and suitability of the Green Belt designation should be considered as strategic policy topic in the plan.","Future of Staverton Airport and how development on or close to the airport could support the future economic growth of Cheltenham, Tewkesbury, and Gloucester.","Yes","","No","Too much emphasis is placed upon the degree to which brownfield development can contribute to the strategic objectives. The development plan area has in practice very little brownfield land capable of delivering upon the strategic objectives. The only sustainable alternative to brownfield development is a root and branch review of the Green Belt, to ensure that new development required to meet the area’s strategic needs is sustainably located. The strategic objectives can best be delivered via appropriate and proportionate redrafting of the Green Belt and Local Green Space boundaries. ","","","It is considered that this should be dealt with through the National Building Regulations and not through the SLP. Seeking to address climate change via local policies creates uncertainty with differing policy requirements promoted by neighbouring authorities. Developers are not opposed to delivering upon the governments climate change agenda, however this should be based on unified regulation or a national policy (via Building Regulations or via National Development Management Policies), in preference to ad-hoc, piecemeal policies promoted through the Development Plan creating uncertainty and a lack of uniform policies across a regional area.","No","No","","","No","No. Whilst in principle allocating land for renewable energy generation is laudable, it may have the opposite effect and hinder the delivery of renewable energy. The delivery of renewable energy generation, especially via solar PV, will be largely governed by national government policy, land availability and connection to the grid. Hypothetically, if land is allocated for energy generation, there would be no guarantee that a connection to the grid could be secured, especially where connections to the grid are dealt with on a first come first served basis. Moreover, allocating land may serve to frustrate other unallocated sitescoming forward, which may be perfectly acceptable from a planning perspective. It is therefore recommended that a policy which supports the principle of renewable energy generation would be more appropriate than allocating sites.","Yes","Yes. The introduction of a standard method for assessing housing needs for planning purposes was intended to shift time, resources, and debate at examination away from the ‘numbers’ question and towards the ‘how’ and ‘where’ of building new homes. To deviate from the standard method may have serious implications for the delivery of the SLP and in any event, there are no exceptional circumstances to justify an alternative approach.\n","","Whilst the SLP area contains significant constraints, such as the Cotswold National Landscape, Green Belt, and areas at a high risk from flooding, these are not unique. Furthermore, given the geographical extent of the SLP area, it is considered that through sensible choices, review of green belt boundaries and careful planning, there are no reasons why the full housing need for all Authorities cannot be delivered.","","","","","","Both Local and National policy have failed to plan appropriately for new economic \ndevelopment. Cheltenham Borough Council investment at Golden Valley and its partnership\nwith Henry Boot Developments is a good local example of public money ‘pump priming’ a \ndevelopment site. The delivery of large employment led sites such as ‘Golden Valley’ will\ntake years to come to fruition. In the interim, the promotion of policies which have sought \nto protect buildings and land within the town/city centres for employment uses have been \nan abject failure, in most instances delaying redevelopment and regeneration. Cheltenham \nlacks smaller employment sites which can be developed quickly and economically for an end \nuser or developed speculatively to meet users demands. Cheltenham’s employment land \noffering (in comparison with Gloucester and Tewkesbury) is particularly poor. This is clarified \nin the letter prepared by Bruton Knowles, attached at Appendix A.","Application for uses which have the potential to generate employment opportunities should be fast tracked. Under the planning performance agreement (PPG) regime, the LPA should \nestablish a standard PPG which can be adopted by developers promoting employment generating uses (and pay for) as an ‘off the shelf ‘agreement to speed up decision making for the good of the local economy. This also has the benefit of increasing funding for the planning functions with the Local Authority. Deriving policies encouraging inwardinvestment is acknowledged to be difficult, however creating a regime which offers maximum flexibility coupled with speedy decisions will all help to encourage investment.","There needs to be an acceptance that many rural areas will be reliant on the use of the private motor vehicle and therefore policies that support rural employment should recognise this. Furthermore, policies that support the reuse of buildings in rural areas should be more flexible.","Repurposing our town and city centres is I believe beyond the remit of a development plan. The current national policy framework and GPDO already supports a wide range of town centre uses and it is difficult to conceive how a development plan could assist further in encouraging investment. \nGreater flexibility is required from decision makers when considering the re-use of listed buildings to ensure that upper floors can be accessed independently of the ground floor.","Support the growth of villages within rural areas with proportionate new residential development.","","","","","No","","Yes","Generally, yes. However, for the development scenarios that rely on brownfield land (i.e. urban concentration/densification) any remediation works associated with brownfield land \ndevelopment may severely impact on the viability of schemes. \nExperience demonstrates that brownfield development does not deliver an appropriate level of affordable housing (due to high cost of development and viability issues). The current requirements and application of CIL and affordable housing triggers currently favour greenfield development. Whilst brownfield development prior to greenfield development should be the preferred development scenario, policies which seek the same level of CIL/Affordable housing/BNG etc all act as a disincentive to bringing forward brownfield sites. \nIf it is accepted that brownfield sites do not deliver policy compliant affordable housing, then policies should be brought forward which deliver a higher proportion of affordable housing on sites which may otherwise be deemed non-compliant with policy (i.e sites constrained by the green belt designation) \nRegarding the delivery of new strategic settlements, consideration needs to be given to thedifficulties surrounding land assembly, which will have implications for masterplanning, and \nthe time taken for development to be delivered on site. Furthermore, a new settlement will not be delivered within the anticipated plan period, which will have implications for housing \nland supply.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","[Q1.] The Framework advises that strategic policies should look ahead over a minimum 15 period  from adoption to anticipate and respond to long-term requirements and opportunities, such  as those arising from major improvements in infrastructure. The SLP states that, once \nagreed, the SLP will set out a vision for at least 15-20 years. In this regard, the anticipated  plan period would align with this requirement. \nHowever, based on the most recently published LDS for Cheltenham, Gloucester and Tewkesbury, submission of the SLP to the Secretary of State (Regulation 22) is not anticipated until April 2026 at the earliest. Even if this ambitious timetable is met, it is likely \nthat the SLP would not be adopted until 2027 at the earliest. Based on the current stated plan period of the SLP until 2041, this would not meet the minimum 15-year period required by the Framework.\nFurther to the timetable set out in the constituent Council’s LDS, it is noted that it has already slipped with this current consultation behind schedule by nearly 4 months. \nFurthermore, when the Joint Core Strategy (JCS) was at the same stage as the SLP in now(i.e. Regulation 18 – ‘Issues and Key Questions’ stage), the JCS was not adopted for a further 8 years. Bearing in mind that the SLP is also intending to replace the current Local Plans of  each Authority, the current timetable for adoption appears unrealistic.\nThe Framework also states that where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), totake into account the likely timescale for delivery. Whilst the SLP is consulting on different development scenarios, it is clear that Tewkesbury Borough Council have been progressing with plans for a new strategic settlement at Ashchurch. Indeed, the Tewkesbury Garden Town was awarded Garden Town status by the Government in 2019. The delivery of housing through large urban extensions also represents the existing strategy of the JCS. \n If, as expected, a new strategic settlement and large urban extension do become the preferred strategy for the SLP going forward, a plan period to 2041 would clearly be insufficient. \n\nINTRODUCTION \n1.1 Evans Jones Ltd have been instructed by VRL Applications Ltd to prepare and submit \nrepresentations in respect of the Cheltenham, Gloucester and Tewkesbury Strategic and \nLocal Plan (SLP) Issues and Options Consultation (Regulation 18: Spatial Options and Key \nPolicy Areas), which runs until 12th March 2024. \n1.2 By way of background, Evans Jones Ltd, on behalf of VRL Applications Ltd, are promoting \ncirca 4.33 hectares of land at Badgeworth Road, Cheltenham for either residential or \nemployment uses. The site is in sole ownership and has previously been submitted to the \nCouncil’s Call for Sites. The most recent submission was in 2023. The site has the reference \nS049b.\n1.3 These representations are made with reference to the relevant consultation questions set \nout in the SLP Issues and Options Consultation document and in the context of the previous \nCall for Sites submission. The representations have regard to the NPPF, including the \napplication of the tests of soundness for the Local Plan to be positively prepared, justified, \neffective and consistent with national policy. \n[Q8} No. Developers are already under many pressures when it comes to delivering commercially viable schemes. Delivering BNG in excess of the statutory 10% requirement will add to that \npressure. If more than 10% BNG is required, it could render some schemes unviable. This could further frustrate housing land supply and/or reduce the delivery of affordable housing.\nFor most planning applications, it will be difficult to achieve even the minimum 10% BNG on site, especially in the more urban areas. This will necessitate the purchasing of BNG credits. However, at this stage, it is not clear what schemes will be available. Furthermore, there are serious concerns that Local Authorities do not have sufficient in-house ecological support to ensure that the new BNG regime runs smoothly.\n There is a widespread misunderstanding of what 10% BNG on site looks like on the ground and the extent to which on site provision will significantly reduce the developable area of \nindividual sites. The land required to accommodate even 10% BNG can be significant. It is assumed that the statutory 10% requirement as set out within the Environment Act was \nestablished based on an evidence base. To arbitrarily set a higher percentage with no evidence base to support has no place in planning policy."]
[null,null,15,"Development should be on brownfield sites first.","","No","What is Green Growth other than Green washing? Growth is not environmentally good, unless it is plants.","No","Town centres will not be desirable unless parking charges abolished. Why is the council not protecting our heritage e.g. demolition of Lansdown Industrial Estate.","Re-use existing buildings. Plant tall street trees (not green walls). Install solar panels on industrial estate roofs. Gardens large enough to plant trees and plant fruit and vegetables.","Increase space standards for dwellings, so there is space to work from home. Plots should be large enough to allow extensions as families expand.","Financial incentives to develop brownfield sites and restore existing buildings to counteract the VAT burden compared with new build.","No","No","","","Yes","Local communities should have dedicated wind turbine to supply energy to their houses. Solar panels fitted to all roofs of new houses.","No","There are plenty of planning consents which have not been developed.","Yes","Why are students of UWE and Hartbury being housed in Cheltenham? Where are refugees going to live?","No","All housing should be suitable for people to live in throughout their life i.e. totally accessible for all.","No","Existing sites should be sufficient as they travel around the country.","They need space for recycling scrap metal etc.","The emphasis on tech jobs does not need offices because most people work from home in a bedroom. Need larger houses.","More space.","Discourage people from commuting long distances by having space to run a business from home.","Abolish parking charges.","Leave it to the retail market to decide if premises are financially viable. People buy everything online now.","Schools, doctors surgery, sewage treatment","","Support schools to prevent closure","No","No","","","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt","No","",""]
["Resident","",20,"Climate change and the emerging emergency in our natural environment need to be a primary consideration in all strategic objectives. Food and agriculture do not appear in the strategic wording and I feel this is an omission.","Local issues may include conservation policies, streetscape design, education provision and health, social care provision for local communities.","","The draft vision features the right themes but is rather generic and could be improved by having stronger references to the individual and collective attributes and qualities that are unique to Gloucester, Cheltenham, and Tewksbury.  There should be narrative around both capital and revenue funding.","","Transport should have its own strategic theme.","","The sustainability and quality of new buildings, both residential and commercial, needs to be completely and fundamentally improved.","It is often environmentally advantageous to reuse and repurpose building to reduce the carbon cost. ","Yes","","Its almost impossible to answer this question as a large proportion of all the land in Gloucestershire could benefit from improvements in the above areas.","If its residential development then sports/recreation/health/education/access to fresh food/community spaces and facilities.","","All forms of sustainable energy should be used including increased solar and wind. Both strategic sites and local sites should be considered. Local storage of power also has much potential. Wind power is quick to install and underutilised due to national policies and often supported by local communities who have a stake in locally produced power.","","The councils have looked at this and concluded its probably about right for, planning purposes.","","","","Investment in local rented sector/social housing. Rents are at record high levels and some public intervention in the market is needed.","Yes","If appropriate for those communities needs and other communities living on those developments.","","","Environments which attract investment and skilled employment are those which offer and high quality and sustainable places to live and work, with access to quality education, health and recreation, as well as varied and exciting arts and cultural opportunities, often anchored by excellent local/ transport networks and good connectivity.","The SLP could look at sector specific plans over time and match these to different geographic focus’s including the rural environment. Digital connectivity and transport connectivity are crucial and sadly lacking in many rural areas which has led to falls in rural employment.","The plan needs to be ‘live’ and subject to regular reviews so that that it can adapt to changing needs.","Clear links to Local planning policies. Stop building edge of town retail parks","High quality-built environments with biodiversity fundamental to design. Sustainable transport links aimed at low car use","As described in the plan","Local education/health/recreation and sustainable transport links. Provision of affordable housing.","","","I think the SLP captures the conceptual options and acknowledges that a combination of these will be necessary to","","I think there is a very strong case for using the Staverton site as a base for housing and employment expansion using a natural transport corridor with developing sustainable transport links – which will be an ideal strategic fit with the planned technology/cyber centre planned around GCHQ and the Tewksbury Road side of Cheltenham. Housing provision has already expanded around this corridor and there has been organic business growth has well. The pros have been somewhat understated.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 6: Sustainable transport scenario","","","[Q29] Sustainable Transport and Urban concentration primarily with Urban extension where brownfield sites can be used.   \n\nCurrent development both residential and commercial is still very car based and often of a low quality, with no ambition on sustainability or biodiversity unless absolutely demanded locally. As a strategic document this is an opportunity to highlight the huge shift needed in approach. The investment needed in the national rail network will need to feature more prominently as both capacity and connectivity will need massive improvements just not currently planned."]
["Statutory/Specific Consultee","Hucclecote Parish Council","","We feel the Plan should address the topic of public access to green spaces.  The Plan shouldn’t just state that, for example, new sports facilities or wildlife areas are to be provided; it should also ensure that the public has access to these spaces. This should include access for less abled people too. Green spaces, natural areas and wildlife habitats are good for the health and well-being of residents, so public access to them must be guaranteed.\n\nWe also feel that, at present, there is not enough emphasis placed on the provision of sports and leisure facilities or healthcare infrastructure. Here in Hucclecote Parish, over the last 30 years, we have had several large housing developments built, and the sports facilities have been the very last element that has been delivered. \n\nThe impact of huge new housing schemes on local GP practices has also been something of an afterthought, and our local community has suffered as a result with many local residents being unable to register with a nearby practice. A good example is the proposed new surgery serving the huge Perrybrook development in nearby\nBrockworth – many Hucclecote Parish residents use this surgery, but the construction of the new facility has been delayed by several years and is now looking increasingly uncertain. The delayed development of the new Hucclecote Surgery, which will be in Barnwood, has exacerbated the situation.\n\nThe new Plan needs to anticipate the impact on healthcare provision and ensure that extra capacity is provided much earlier in the development programme, not at the end.","Areas like Hucclecote Parish, on the edge of the city of Gloucester, do not relate naturally to Tewkesbury, 12 miles to the North of us – here we have a much more logical connection to Gloucester City, which has the greater population of the settlement of Hucclecote within it. \n\nWe would therefore like to see more thought put into how our area integrates with the plans for the City. The same probably applies to other parishes on the periphery of Gloucester (eg Churchdown, Brockworth, Longford, Innsworth, etc).\n","No","The draft Vision does not talk much about education. We would like to see targets set for this – for example, could the Plan have the goal of steadily improving the quality of education, perhaps by monitoring examination results, or employing other measures of education ‘value-added’?\n\nBoosting education standards has a huge knock-on effect. Studies have shown direct links between education and factors such as health and life expectancy rates. Similarly, research suggests that higher education attainment is associated with positive public safety outcomes and lower crime rates. Education is also commonly considered to be an investment in human capital – the more our area invests in its education systems, the greater its economic performance overall.\n\nWe also feel there should be a goal of reducing crime/making the area safer for its residents.","","Under the heading of ‘building strong, competitive and sustainable urban and rural economies’ we feel that there is not enough emphasis on the importance and role of the voluntary/community sector. Organisations like local charities, social enterprises and voluntary groups deliver essential services and can contribute a lot to economic growth. The ‘third sector’ plays a vital role in supporting communities at a local level, and we believe you should focus more on this in the Plan.","One of the Plan’s priorities for tackling Climate Change should be to halt all new housebuilding in the Green Belt – the Plan should seek to protect the remaining green spaces between our communities. \n\nOver the last three decades in Hucclecote Parish thousands of new homes have been built – and there is now very little protected green space available for wildlife or our residents to enjoy.","There should be a real push to regenerate and improve existing housing, rather than to just build new homes on green fields. The demolition of existing homes (where most of the materials – eg bricks - required a huge amount of energy to create them in the first place) makes no sense. We believe the refurbishment of existing homes should be undertaken first, with a real emphasis on making them much more energy efficient for the future.\n\nWhen it comes to new buildings the emphasis should be on ‘fabric first’ – ie ensuring the fabric of the building is really highly insulated, triple glazed etc. \n\nIn the past we have enjoyed relatively cheap energy. This is no longer the case, so we now need to produce buildings that require hardly any energy to power them. Another benefit of the ‘fabric first’ approach would be that there would be little need for expensive, high maintenance (and energy guzzling) technologies like heat pumps. \n\nPeople on low incomes really struggle with the proportion of their income that is now being spent on energy; this approach would mean that residents would end up in more comfortable homes and have significantly lower energy bills.","","","","There are four spaces in or close to Hucclecote Parish that we believe could help with wildlife protections/biodiversity net gain, recreation etc. These are listed below:\n\n•\tThe land around the new sports facilities on Coopers Edge – this includes recently adopted Public Open Space, the area known as ‘The Mound’, and the bunds alongside the M5. Our view is that there is scope to significantly boost BNG in this area.\n•\tChosen Hill (also known an Churchdown Hill) – this area extends to more than 100 acres and much of it is wooded, or overgrown. Part of the Hill is managed by the Woodland Trust, another area was looked after by the Gloucestershire Wildlife Trust on behalf of Severn Trent. Some small areas are also privately owned. The land is designated as Public Open Access land and the Hill is rich with wildlife – badgers, deer, foxes etc. Scores of bird species also nest on the Hill – from buzzards and owls to red and green woodpeckers. There is scope to manage and develop this area for wildlife and environmental purposes.\n•\tHorsbere Brook Nature Reserve – this 50-acre site close to the A417 has become an excellent wetland habitat, and has attracted rare birds including kingfishers, sparrow hawks and penduline tits. It is also a very popular local walking area and thousands of young trees have recently been planted there as part of the Queen’s ‘Green Canopy’ initiative.\n•\tHucclecote Meadows SSSI – this six-acre site is nationally recognised for its species-rich ancient pasture. This habitat is perfect for butterflies - meadow brown, marbled white, common blue, grizzled skipper and the small heath butterfly have all been recorded.\n\nWe would also like to make the point that existing trees and hedgerows should be retained, wherever possible, when new developments are being planned.","While the Plan currently lists a range of services and facilities, we feel that some are still treated as more important than others. We don’t think this should be the case – all are vital.\n\nFor example, we believe connectivity to proper cycleways should be given more importance in the future, along with the provision of suitable recreation/leisure facilities and access to public green spaces. \n\nWe also feel that the provision of a local convenience store on big housing sites needs to be given more weight, alongside additional healthcare and school provision.","Yes","We believe that solar farms could be appropriate, provided the land they are built on continues to be used for agricultural purposes (eg grazing underneath, or crops). If solar farms are proposed, we feel there should be a Planning Condition attached to this effect.\n\nWe also feel that all new large buildings – such as warehouses, schools, offices etc – should be required to have solar panels installed on them. Car ports and car parks could also be fitted with shade structures, with PV’s installed above. This is already standard practice in several European countries.\n\n","","","","","Yes","We feel there should be more in the Plan to encourage community-led (not for profit housing), and self-build homes. Compared to most other European countries we currently build a very low proportion of our homes this way.","","","","Part of the Perrybrook site is currently zoned for industrial and/or business use. We think this makes sense as it is next to the M5 and surrounded on all sides by dual carriageways. \n\nWe would not support this site being put to other uses – and we would object strongly to the land being re-designated as residential.\n\nOur parish already suffers disproportionately from unacceptable noise from the M5, surrounding roads and industrial development. Any future residential and industrial development should be required to protect our residents far better from such intrusive noise.\n","","","","","We don’t believe any form of infrastructure is more or less critical – it is all essential. In particular, we feel that integrating new developments with the county’s growing cycling infrastructure should be vital on all major new developments. \n\nWe also feel there is potential for the reopening of the railway station at Churchdown midway between Cheltenham and Gloucester. This would serve the growing community of Churchdown and make it easier for commuters, shoppers and others to use the rail network to get to and from the town and city.","","","Yes","","","","","","Yes","Our council believes that no single scenario will deliver all the growth that’s needed. \n\nWe strongly believe that there should be no further encroachments into the Green Belt, so we don’t support Option 2. \n\nOur view is that the Plan should suggest a combination of 6 ,1, 4, 5, and 3 (in this order of priority).\n\n","Over the last 30 years the communities on the edge of Gloucester have carried more than their fair share of the burden when it comes to accommodating growth – with many thousands of new homes, and lots of new industrial/office space built. As a result, there are relatively few green spaces left, and those remaining natural areas now need to be protected from any future development. \n\nOur residents have already signalled their concerns over some of the sites that have been listed in the HELAA report. On behalf of our residents and the precious natural green spaces in and around the parish of Hucclecote we would urge you to focus any major new developments on the many much better suited sites across the Tewkesbury Borough area.\n\nWe would also like to make a general point about those developers that seem to only deliver the bare minimum requirements set out in the Building Regulations or in Section106 agreements. In our view the S&LP needs to address this by either raising the minimum requirements, or much stronger enforcement.\n"]
["Statutory/Specific Consultee","Hucclecote Parish Council","","We feel the Plan should address the topic of public access to green spaces.  The Plan shouldn’t just state that, for example, new sports facilities or wildlife areas are to be provided; it should also ensure that the public has access to these spaces. This should include access for less abled people too. Green spaces, natural areas and wildlife habitats are good for the health and well-being of residents, so public access to them must be guaranteed. We also feel that, at present, there is not enough emphasis placed on the provision of sports and leisure facilities or healthcare infrastructure. Here in Hucclecote Parish, over the last 30 years, we have had several large housing developments built, and the sports facilities have been the very last element that has been delivered. The impact of huge new housing schemes on local GP practices has also been something of an afterthought, and our local community has suffered as a result with many local residents being unable to register with a nearby practice. A good example is the proposed new surgery serving the huge Perrybrook development in nearby Brockworth – many Hucclecote Parish residents use this surgery, but the construction of the new facility has been delayed by several years and is now looking increasingly uncertain. The delayed development of the new Hucclecote Surgery, which will be in Barnwood, has exacerbated the situation. The new Plan needs to anticipate the impact on healthcare provision and ensure that extra capacity is provided much earlier in the development programme, not at the end.","Areas like Hucclecote Parish, on the edge of the city of Gloucester, do not relate naturally to Tewkesbury, 12 miles to the North of us – here we have a much more logical connection to Gloucester City, which has the greater population of the settlement of Hucclecote within it. We would therefore like to see more thought put into how our area integrates with the plans for the City. The same probably applies to other parishes on the periphery of Gloucester (eg Churchdown, Brockworth, Longford, Innsworth, etc).","","The draft Vision does not talk much about education. We would like to see targets set for this – for example, could the Plan have the goal of steadily improving the quality of education, perhaps by monitoring examination results, or employing other measures of education ‘value-added’? Boosting education standards has a huge knock-on effect. Studies have shown direct links between education and factors such as health and life expectancy rates. Similarly, research suggests that higher education attainment is associated with positive public safety outcomes and lower crime rates. Education is also commonly considered to be an investment in human capital – the more our area invests in its education systems, the greater its economic performance overall. We also feel there should be a goal of reducing crime/making the area safer for its residents.","","Under the heading of ‘building strong, competitive and sustainable urban and rural economies’ we feel that there is not enough emphasis on the importance and role of the voluntary/community sector. Organisations like local charities, social enterprises and voluntary groups deliver essential services and can contribute a lot to economic growth. The ‘third sector’ plays a vital role in supporting communities at a local level, and we believe you should focus more on this in the Plan.","One of the Plan’s priorities for tackling Climate Change should be to halt all new housebuilding in the Green Belt – the Plan should seek to protect the remaining green spaces between our communities. Over the last three decades in Hucclecote Parish thousands of new homes have been built – and there is now very little protected green space available for wildlife or our residents to enjoy.","When it comes to new buildings the emphasis should be on ‘fabric first’ – ie ensuring the fabric of the building is really highly insulated, triple glazed etc. In the past we have enjoyed relatively cheap energy. This is no longer the case, so we now need to produce buildings that require hardly any energy to power them. Another benefit of the ‘fabric first’ approach would be that there would be little need for expensive, high maintenance (and energy guzzling) technologies like heat pumps. People on low incomes really struggle with the proportion of their income that is now being spent on energy; this approach would mean that residents would end up in more comfortable homes and have significantly lower energy bills.","There should be a real push to regenerate and improve existing housing, rather than to just build new homes on green fields. The demolition of existing homes (where most of the materials – eg bricks - required a huge amount of energy to create them in the first place) makes no sense. We believe the refurbishment of existing homes should be undertaken first, with a real emphasis on making them much more energy efficient for the future.","","Yes","There are four spaces in or close to Hucclecote Parish that we believe could help with wildlife protections/biodiversity net gain, recreation etc. These are listed below: \n•\tThe land around the new sports facilities on Coopers Edge – this includes recently adopted Public Open Space, the area known as ‘The Mound’, and the bunds alongside the M5. Our view is that there is scope to significantly boost BNG in this area. \n•\tChosen Hill (also known an Churchdown Hill) – this area extends to more than 100 acres and much of it is wooded, or overgrown. Part of the Hill is managed by the Woodland Trust, another area was looked after by the Gloucestershire Wildlife Trust on behalf of Severn Trent. Some small areas are also privately owned. The land is designated as Public Open Access land and the Hill is rich with wildlife – badgers, deer, foxes etc. Scores of bird species also nest on the Hill – from buzzards and owls to red and green woodpeckers. There is scope to manage and develop this area for wildlife and environmental purposes. \n•\tHorsbere Brook Nature Reserve – this 50-acre site close to the A417 has become an excellent wetland habitat, and has attracted rare birds including kingfishers, sparrow hawks and penduline tits. It is also a very popular local walking area and thousands of young trees have recently been planted there as part of the Queen’s ‘Green Canopy’ initiative. \n•\tHucclecote Meadows SSSI – this six-acre site is nationally recognised for its species-rich ancient pasture. This habitat is perfect for butterflies - meadow brown, marbled white, common blue, grizzled skipper and the small heath butterfly have all been recorded. We would also like to make the point that existing trees and hedgerows should be retained, wherever possible, when new developments are being planned.","While the Plan currently lists a range of services and facilities, we feel that some are still treated as more important than others. We don’t think this should be the case – all are vital. For example, we believe connectivity to proper cycleways should be given more importance in the future, along with the provision of suitable recreation/leisure facilities and access to public green spaces. We also feel that the provision of a local convenience store on big housing sites needs to be given more weight, alongside additional healthcare and school provision.","","We believe that solar farms could be appropriate, provided the land they are built on continues to be used for agricultural purposes (eg grazing underneath, or crops). If solar farms are proposed, we feel there should be a Planning Condition attached to this effect. We also feel that all new large buildings – such as warehouses, schools, offices etc – should be required to have solar panels installed on them. Car ports and car parks could also be fitted with shade structures, with PV’s installed above. This is already standard practice in several European countries.","","","","","Yes","We feel there should be more in the Plan to encourage community-led (not for profit housing), and self-build homes. Compared to most other European countries we currently build a very low proportion of our homes this way.","","","","Part of the Perrybrook site is currently zoned for industrial and/or business use. We think this makes sense as it is next to the M5 and surrounded on all sides by dual carriageways. We would not support this site being put to other uses – and we would object strongly to the land being re-designated as residential. Our parish already suffers disproportionately from unacceptable noise from the M5, surrounding roads and industrial development. Any future residential and industrial development should be required to protect our residents far better from such intrusive noise.","","","","","We don’t believe any form of infrastructure is more or less critical – it is all essential. In particular, we feel that integrating new developments with the county’s growing cycling infrastructure should be vital on all major new developments. We also feel there is potential for the reopening of the railway station at Churchdown midway between Cheltenham and Gloucester. This would serve the growing community of Churchdown and make it easier for commuters, shoppers and others to use the rail network to get to and from the town and city. ","","","Yes","","","","","Scenario 1: Urban concentration; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","","[Q29] Our council believes that no single scenario will deliver all the growth that’s needed. We strongly believe that there should be no further encroachments into the Green Belt, so we don’t support Option 2. Our view is that the Plan should suggest a combination of 6 ,1, 4, 5, and 3 (in this order of priority). Over the last 30 years the communities on the edge of Gloucester have carried more than their fair share of the burden when it comes to accommodating growth – with many thousands of new homes, and lots of new industrial/office space built. As a result, there are relatively few green spaces left, and those remaining natural areas now need to be protected from any future development. Our residents have already signalled their concerns over some of the sites that have been listed in the HELAA report. On behalf of our residents and the precious natural green spaces in and around the parish of Hucclecote we would urge you to focus any major new developments on the many much better suited sites across the Tewkesbury Borough area. We would also like to make a general point about those developers that seem to only deliver the bare minimum requirements set out in the Building Regulations or in Section106 agreements. In our view the S&LP needs to address this by either raising the minimum requirements, or much stronger enforcement."]
["Statutory/Specific Consultee","National Trust","","The last point, (d), states: “conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure, and planning measures to address climate change and adaptation”. We would like to see reference to biodiversity or nature recovery added, e.g. “landscapes, biodiversity and green infrastructure”.\n\nIn addition, we note that point (b) refers to flood risk management, and we would like to see support for natural flood management and catchment management, including funding and delivery mechanisms – see comments under Climate Change and Nature Recovery.","","No","We believe there is room for improvement. \n\nThe Vision refers to “green growth” and henceforth to “growth” several times, including in key sectors and sustainable locations. We acknowledge that additional homes and employment are needed, yet we are concerned about the singular focus on growth. For a 15-year+ vision, we would like to see greater attention paid to the protection and enhancement of green and natural spaces in this area, including in the Cotswold National Landscape, which provides a green setting for Gloucester and Cheltenham. These green and natural spaces are valued by local residents, visitors and businesses alike. CHANGE REQUESTED: We would like to see greater emphasis on protecting and enhancing the green and natural spaces in the area; and an elucidation of how further growth can be ‘green’ and appropriately managed and mitigated. \n\nThere is reference to “improvements in biodiversity”, however we feel that greater ambition is needed given the decline of nature in the UK. CHANGES REQUESTED: Add reference to “a flourishing nature recovery network” (or similar wording) to the existing statement of “improvements to biodiversity”. Add reference to “fully mitigating the impacts of new development on existing sites of nature conservation importance”.\n\nThere is reference to “a network of interconnected green spaces and waterways”, but less sense of growing green infrastructure alongside (and supported by) the proposed housing and economic growth.  CHANGE REQUESTED: Green infrastructure: In addition to “a network of interconnected green spaces and waterways will have been secured”, add reference to “and existing green spaces will be supported to respond to increased visitor pressures”.\n\nLastly, we support a positive reference to “active and sustainable travel”. CHANGE REQUESTED: Either retain “promotion of active or sustainable travel” or provide added emphasis to supporting and facilitating its growth.","No","We agree with some elements and would like to see changes to others as follows: \n\nWe have a particular in interest in – and are broadly supportive of – the numbered points related to ‘Meeting the challenges of climate change’. \n\nWe also support “ensuring developments support green infrastructure and improve existing green infrastructure within urban and rural areas to provide movement corridors for people and wildlife”. \n\nHowever, in addition to the reference to “conserving, managing and enhancing the area’s unique natural environment and biodiversity”, we would like to see reference to the Nature Recovery Network. Growing the NRN is “central to the government’s ‘apex role’ of improving nature” according to the DEFRA policy paper on The Nature Recovery Network (Updated 16 Feb 2024). CHANGE REQUESTED: Add a positive reference to the Nature Recovery Network. ","In respect of climate change, we are broadly supportive of the Strategic Objectives, and many of the ideas in section 4. The following will be key components of tackling climate change: the detailed policy requirements, having the right level of ambition, ensuring the future-proofing of new developments, and ensuring appropriate funding and delivery mechanisms.\n\nWe would also like to emphasise the importance of woodland creation in mitigating climate change, working with Cotswolds National Landscape and others. \n\nIn respect of nature recovery, there is reference to biodiversity net gain and SANGs. We would strongly support and advocate for the identification of recreational pressures on existing greenspaces and designated nature conservation sites, and the need for SANGs and mitigation strategies, along with the correct distribution of mitigation funds. \n\nWe would like to see reference to Nature Recovery Networks and clear alignment with and support for the emerging Local Nature Recovery Strategy, including how new development can support nature recovery on the ground. \n\nThe SLP should offer support for specific landscape-scale partnerships and initiatives that deliver for people and nature; and example being the Stroud Landscape Project, which operates across an area of 21000+ hectares from Leckhampton southwards. \n\nWe would also like to see support for natural flood management (and catchment flood risk management), including maximising opportunities to manage land to manage flood water. We would advocate for a plan or funding framework on the ‘how’ to deliver flood risk management higher up the catchment, potentially delivering on BNG and nature recovery too. \n\nIn addition, we would like to flag the need for improved functioning wetlands – both for flood risk management and biodiversity purposes.","","","Yes","Yes","From a National Trust perspective, we aren’t proposing any land to be allocated for environmental purposes as such, however, for the record… the Trust manages land for wildlife (and public access) purposes at Crickley Hill country park, the northernmost part of which lies within Tewkesbury borough. Also in Tewkesbury borough, the Trust is the custodian of Snowshill Manor and Garden, which provides culture and recreation for its visitors. The priorities at Snowshill Manor include successional planting of the pasture and orchard trees, and planting and establishment of connective hedgerow.  \n\nBeyond the C/G/T boundaries, the Trust is focused on partnership working and landscape-scale delivery, including the Stroud Landscape Project; as well as projects supporting public access to green spaces, including at Woodchester Park.","","","The National Trust is supportive of renewable energy as a matter of principle and believes that appropriate development can play an important role. (We are also aware that the grid network may need upgrading to facilitate renewable energy, including small scale PV development, and that locally improvements are needed to support EV charging). \n\nThe Trust also cares for places of natural or historic significance. In light of this, should the Councils move in the direction of allocating sites for renewable energy development, we would recommend landscape sensitivity studies are undertaken, and that designated heritage assets and their settings are taken into account.","","","","","","","","","","","","We would like to see the SLP support and encourage employment in the areas identified under question 9, namely: “environmental purposes, such as wildlife / biodiversity net gain, recreation, flood risk mitigation, cooling and shading, carbon storage and food production”, including support for a sustainable food system. We would like to see acknowledgement of and support for tourism and day trips to special places for wellbeing – an example being Crickley Hill (part of which lies within the Tewkesbury borough). There should also be support for active and sustainable travel in rural areas, including the development of appropriate green transport infrastructure, to support jobs and wellbeing.","","","We consider the following to be critical alongside new development:\n\nGreen infrastructure, including on-site green spaces and support for the wider growth of green infrastructure, and improvement of existing green spaces. \n\nSustainable Drainage Systems (SuDS) and natural flood management infrastructure to manage flood risk and drainage, in the face of climate change. Also, the new or improved wetland areas to help both flood risk management and biodiversity.\n\nIn addition, electrical networks need to be upgraded where necessary, to enable small-scale renewable energy generation and electric vehicle charging.","The comprehensive provision of high quality green infrastructure.","The availability of (or prospects for) access by active or sustainable travel.","","Yes","Not so much a scenario, but we wanted to emphasise the amazing views currently experienced from Crickley Hill (and more broadly along the Cotswold escarpment) across the Severn Vale, including towards Gloucester and Cheltenham. We would value the maintenance of a green gap between the settlements. We would also want to avoid urban sprawl at motorway junctions and large scale development that adversely affects these views and the setting of Cotwolds National Landscape. (This is particularly pertinent, given that the A417 will soon be fully dualled).","","","Scenario 3: Urban extensions, avoiding the Green Belt","","","We recommend collaboration and partnership working between the three councils preparing the SLP and organisations such as the National Trust, Gloucestershire Wildlife Trust and Cotswold National Landscape, as well as the Local Nature Partnership."]
["Planning agent or developer","Avison Young","","Paragraph 2.4 reiterates the policy guidance from Paragraph 20 of the NPPF and states that strategic policies should set out an overall strategy for the pattern, scale and design quality of places, and make sufficient provision for:\n(a)\thousing (including affordable housing), employment, retail, leisure and other commercial development;\n(b)\tinfrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat);\n(c)\tcommunity facilities (such as health, education and cultural infrastructure; and\n(d)\tconservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure, and planning measures to address climate change and adaptation.’\n\nWe agree that these policy topics should be covered as a minimum. In doing so, national policies and infrastructure investment should be considered hand‐in‐hand with emerging strategic policies to coordinate infrastructure delivery with the spatial strategy.\n\nIn considering these topic areas, the evidence base should be robust, relevant and up‐to‐date in line with Paragraph 31 of the NPPF. Paragraph 145 of the NPPF is clear that strategic policies should establish the need for any changes to Green Belt boundaries. Given that housing needs should be met in full across the three authority areas, with potential consideration to unmet needs from adjoining authorities, the time frame for the Plan, and the strategic cross‐boundary nature of the Green Belt designation, we consider the Plan will need to be supported by a Green Belt review and consider Green Belt releases of land for housing. Any Green Belt review will need to take full account of existing and emerging development proposals as well as planned infrastructure investment when considering how different parts of the Green Belt perform against the NPPF criteria.","As set out within the consultation document, the complex, interrelated nature of the Gloucester, Tewkesbury and Cheltenham area means that strategic policy topics related to development (employment land, housing needs, environmental change etc) are not confined to one particular authority area. Clearly there are locations within the area that will have specific needs and the Plan must consider how needs differ across the three authorities, and reflect this within the spatial strategy.\n\nWe would note that the M5 Junction 10 improvements scheme is a significant piece of infrastructure investment that will change strategic vehicle accessibility and capacity to the west of Cheltenham. Additionally, planned growth at Golden Valley and northwest Cheltenham will transform this edge of the town and create a significant destination with additional growth potential. The implications and change that the developments and infrastructure will bring should be recognised and considered in developing the spatial strategy.","","We largely agree with the draft Vision but make the following comments:\n•\tThe Plan Period should be extended to 2046 (noting our comments at Q1);\n•\tInvestment in Junction 10 of the M5 as a strategic piece of infrastructure should be acknowledged and the benefits this brings in terms of unlocking growth potential north and west of Cheltenham.","","We agree with the majority of the strategic objectives but consider that meeting housing needs in full for the area on a range of sites to secure a consistent, deliverable supply of housing land should be a core strategic objective of the Plan, including review of Green Belt where this is necessary to meet local needs.","The NPPF encourages Plans to take a proactive approach to mitigating and adapting to climate change, taking into account the long‐term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures. In this regard, policies should support appropriate measures to ensure the future resilience of communities and infrastructure. \n\nIt is also important to acknowledge that new development provides opportunities for climate change adaptation and delivery of biodiversity gains through well‐considered soft landscaping and sustainable drainage solutions that can help to support a wider community area. We agree with Paragraph 4.17 of the consultation document and would highlight that the viability of policy measures that go beyond mandatory requirements (i.e. 10% biodiversity net gain or Building Regulations energy efficiency standards‐new PPG referred to below) needs to be fully considered and acknowledged when drafting policies for future development.","As set out in our response to Q6, we would be concerned if policies are introduced that duplicate or seek to address matters that are already adequately managed through Building Regulations, other consenting regimes and other regulations. Introducing such policies leads to delay in housing delivery through extended negotiations at planning application stage, potential for protracted viability discussions and often compromises on other parts of development that are critical to achieving well‐designed development and affordable housing at a local level.","As set out in our response to Q6, we would be concerned if policies are introduced that duplicate or seek to address matters that are already adequately managed through Building Regulations, other consenting regimes and other regulations. Introducing such policies leads to delay in housing delivery through extended negotiations at planning application stage, potential for protracted viability discussions and often compromises on other parts of development that are critical to achieving well‐designed development and affordable housing at a local level.","","","We are not aware of any specific sites that could be identified for environmental purposes, however, these representations are submitted to support and promote residential development on land north of Old Gloucester Road, west of Cheltenham. Environmental mitigation would be built into any future masterplan through the delivery of multi‐functional green spaces that will be comprehensively considered to address biodiversity net gain and public open space policies as well as sustainable drainage and water management alongside delivery of housing and affordable housing.","New development will need to consider how it specifically knits‐in and provides for services and facilities of existing and future residents. Additionally, this should be considered in the context of infrastructure to be provided within planned development, such as the new primary schools and the transport interchange within the West Cheltenham allocation.\n\nParagraph 20 of the NPPF recognises that the overall strategy for an area should make provision for community facilities including health, education and cultural infrastructure alongside green infrastructure. Local services will also be important such as local shops, meeting places and sports venues. In allocating sites and preparing the spatial strategy, we urge the Council’s to consider how new site allocations and growth of settlements could deliver for the needs of a local area.","","","","The NPPF (paragraph 61) directs that, to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance and that an alternative approach may be applied in exceptional circumstances.\n\nWe consider the standard method should therefore be used as the starting point for considering the housing requirement for the area. In line with Paragraph 67 of the NPPF, the housing requirement that is established should meet the identified housing need over the plan period. Paragraph 67 also states that the requirement “may be higher than the identified housing need if, for example, it includes provision for neighbouring areas, or reflects growth ambitions linked to economic development or infrastructure investment”.\n\nThe Cheltenham, Gloucester and Tewkesbury area is a desirable location to live and work in terms of lifestyle and its proximity to major road and rail corridors that can assist in continued economic growth (as set out within the consultation document). In particular, the Golden Valley Development in combination with proposals at Northwest Cheltenham and M5 Junction 10 improvements will deliver significant change to the north and west of the town, creating and defining Cheltenham as a significant focus for growth and investment. The impact of this spatial change and planned growth needs to be considered and built on in the next Plan Period. In this context, we strongly support the need for more housing at this boundary between the Cheltenham and Tewkesbury Boroughs. There are exceptional circumstances that justify the reassessment of the housing requirement in order to support economic growth i.e. sufficient levels of housing are required to avoid and seek to avoid and/or reverse unsustainable levels of commuting into Cheltenham and Gloucester.\n\nWe note from GFirst LEP’s Strategic Economic Plan that although Gloucestershire has improved its economic performance over recent years, it considers that relatively high house prices and rents could well be linked to the failure to attract and retain talented young people. We request that the Councils consider how housing needs can be met through a range and choice of sites and\nthrough extensions to existing areas of planned growth to maximise the growth opportunities from investment. This will also ensure that homes and employment uses are co‐located to deliver successful places that are sustainable into the future.","","As set out in our response to Q12, we do not consider there are constraints to the number of houses that should be planned for, but we would support and argue that the housing requirement should be higher. There is no need to artificially suppress the housing requirement. For the reasons set out in question 12, an economic led and ambitious housing target should be planned for.","","We support NPPF policies that seek for allocation of a sufficient supply of sites that will deliver a range of homes to meet housing needs (Paragraph 69). The SLP should therefore consider a range of deliverable and developable sites that will maximise housing delivery and secure a range of housing types, sizes and tenures. In this regard, we urge the Councils to consider both brownfield and greenfield sites as different types of sites deliver different requirements when considering policies for higher density development on brownfield, urban sites. This can often result in apartment‐led developments that suit city centre and urban locations but, due to viability and land constraints, cannot deliver a significant proportion of family houses with associated private gardens and amenity. It will therefore be important to allocate a variety of development opportunities to ensure there is sufficient supply of housing for all groups in the community.","","","","","The Cheltenham, Gloucester and Tewkesbury area is a desirable location to live and work in terms of lifestyle and its proximity to major road and rail corridors that can assist in continued economic growth.\n\nEmployment needs to ensure the continued success of the SLP area should be considered and accommodated as part of the overall spatial strategy. This could also include elements of employment within mixed use developments to deliver a range of employment opportunities. Embracing the opportunity to address both requirements simultaneously is paramount to the creation of sustainable communities.","","","","Infrastructure delivery should be coordinated across an area so that it is delivered alongside planned growth within a spatial strategy. The delivery of such infrastructure and investment should be managed at a strategic level as individual development proposals should only deliver infrastructure that is required to mitigate the impact of its own development in line with local policy. It should not be required to address existing under‐provision or issues in a particular location. Where there is planned and coordinated investment coming forward in the area, the growth potential and opportunities created should be maximised. For example, investment in Junction 10 of the M5 should be fully considered as part of the spatial strategy within the SLP to maximise the opportunity to deliver growth alongside infrastructure investment.","","","","","We agree with the settlement hierarchy in the existing strategy; Cheltenham and Gloucester have a role as principal settlements for economic growth and housing in the area, and more widely at a regional and national level, whilst Tewkesbury town has a role at a more local level together with the network of rural service centres and villages. We consider that any spatial strategy should be founded in an approach to growth that is in proximity to existing settlements and locations where there is existing and planned infrastructure that can support new housing.\n\nThe NPPF is clear that planning policies should promote sustainable development with three overarching objectives: an economic objective, a social objective and an environmental objective (Paragraph 8). These objectives are overlapping and need to be pursued in mutually supportive ways and any preferred development scenario should be grounded in these objectives. The delivery of a sufficient number and range of homes is core to the social objective, whilst ensuring sufficient land in available in the right places and coordinating the provision of infrastructure is within the economic objective. It is acknowledged within the consultation document at 6.8 that none of the six development scenarios would deliver sustainable development on their own. We agree that a combination of scenarios will be required for the final strategy.\n\nWe do not suggest any additional spatial options that should be tested, however, given that the final strategy will be a combination of the development scenarios, various alternative combinations should be tested. We would also urge the Councils to ensure that any testing is based on a scenario where growth and investment that is already planned has been delivered along with any associated infrastructure, for example, new bus links or public transport services.","","Scenario 1 – Urban concentration\nThe NPPF encourages effective use of land and promotes higher density development in urban areas. However, the NPPF also clarifies that area‐based character assessments, design guides and codes can be used to test how efficiently land can be used. In seeking for higher density development, the NPPF also states that significant uplifts in density may be inappropriate if it results in built development that would be wholly out of character with the existing area. The capacity of urban sites therefore needs to be thoroughly tested, and we believe this needs to be inform by city/town‐wide design guidance, to ensure that any housing and economic needs met through a high density ‘urban concentration’ approach could be appropriately achieved. In addition, the viability of maximised densities also needs to be tested and considered. Urban, brownfield sites are often complex and can have high costs and abnormals that challenge development viability. Additionally, the requirements of the Building Safety Act also have potential to increase costs for higher density development with the need to include additional stair cores etc for development above 18m. This would impact upon potential site capacity and delivery timescales and needs to be tested. We suggest that an additional ‘con’ is included as follows: “Potential for protracted delivery timescales through challenging development viability to achieve high density development”. Further, brownfield development often delivers less affordable housing and infrastructure.\n\nScenario 2 – Urban extensions\nWe believe that urban extensions should form an important element of the final strategy to meet housing and economic needs through the SLP. When considering this scenario, accessibility and sustainability should be considered in the context of a future point where current planned development has been completed. Paragraph 74 of the NPPF highlights that the supply of large numbers of new homes can often be best achieved through planning for larger scale development such as significant extensions to existing towns. In the case of Cheltenham, Golden Valley and North-west Cheltenham have and will continue to change this edge of the town, including giving it more focus as a destination and creating opportunities for greater sustainable transport connectivity. In addition, improvements to M5 Junction 10 will also increase connectivity. The future spatial strategy should look to capitalise on this growth and investment and maximise any opportunities to deliver sustainable development that contributes to this future thriving edge of the town. We largely agree with the pros and cons listed but would add the following ‘pro’: “Opportunity to grow innovative strategic allocations to support their long‐term success”.\n\nWe would note that the key diagram title describes this scenario as “Delivering development as urban extensions to Cheltenham, Gloucester and Tewkesbury Town, avoiding the Green Belt”. This description is inaccurate as this scenario does not including urban extensions to Cheltenham (as shown on the key diagram). The text should be amended on this basis.\n\nScenario 3 – Urban extensions, avoiding the Green Belt\nLand to the east and south of Cheltenham has high landscape and biodiversity sensitivity due to the Cotswolds AONB. This development scenario makes no provision for larger scale development at Cheltenham, other than within the town limits. As noted under Scenario 1 above, we believe that increasing density within the town has challenges in relation to design and viability. Cheltenham is a focus for investment and economic growth, particularly related to the development at Golden Valley, which is proposed to integrate hi-tech business and be a destination of global significance (as stated within the consultation document). The lack of large-scale development opportunities at Cheltenham under scenario 3 is a significant weakness. We suggest an additional ‘con’ is included as follows: “On its own, would not deliver significant new homes at Cheltenham where there is significant investment and growth already planned”. The ability of Scenario 3 to sustainably meet Cheltenham’s needs during the plan period is therefore questionable.\n\nScenario 4 – New strategic settlement\nWhilst Scenario 4 could form part of a spatial strategy (noting the Tewkesbury Garden Communities initiative), new settlements are notoriously hard to deliver successfully and have a significant lead‐in time as well as often relying on the delivery of new strategic transport infrastructure, with limited control over delivery timescales. We agree with the consultation document that the lead-in times are a significant ‘con’ and in the case of the SLP, we believe that any planned settlement would not come forward until, at the earliest, the very end of the Plan Period. If this option is pursued as part of an overall spatial strategy, we would encourage the Councils to forecast a realistic timeline to delivery of new homes and consider a sufficient, appropriate range of sites that will deliver homes to meet needs within the first 10-15 years of the plan period.\n\nScenario 5 – Rural dispersal\nThe NPPF supports the development of strong, healthy and vibrant communities. It encourages the planning system to manage patterns of growth in support of transport objectives. This includes consideration of the environmental impacts of traffic and transport infrastructure and the potential impacts of development on transport networks. This scenario considers the distribution of growth across the area, at a wide range of settlements and locations. We do not consider this will deliver the scale of growth needed to meet objectively assessed needs, nor will it move towards a reduction in carbon emissions from transport (in line with the Gloucestershire Statement of Shared Intent). Furthermore, growth planned in this way will neither meet needs in the right locations, nor will it deliver a pattern of growth that is supported by sustainable transport (without significant dispersed investment in sustainable transport modes). We agree with the pros and cons identified.\n\nScenario 6 – Sustainable transport scenario\nWe agree that the sustainable transport scenario has a range of ‘pros’ that mean it should form part of a final strategy. Under this scenario, planned sustainable transport investment should be factored into testing development options. We agree with the pros and cons identified.\n\n","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","","",{"$cut":{"chars":31587,"head":"[Q1 - The National Planning Policy Framework (NPPF) sets out at Paragraph 22 that strategic policies should look ahead over a minimum of 15 years from adoption. It goes on to state that where larger scale developments form part of the strategy, policies should be set within a vision that looks further ahead by at least 30 years.\n\nThe Strategic and Local Plan should therefore cover a period of at least 15 years post‐adoption of the Plan. The current Local Development Schemes suggest that the SLP will be submitted in April 2026 with Examination to follow prior to adoption. It can take a long time for Plans to progress from Regulation 18 stage through Regulation 19 and Examination to formal adoption. In this vein, we note that there has already been slippage in the timetable by 3 months.\nA realistic timetable to adoption must be devised and we suggest that there should be contingency in this timeline when considering the overall Plan Period. This should then be reflected in the timescales adopted within the evidence base.\n\nOn this basis, we consider that the SLP is unlikely to be adopted before at least Q1 2027. Therefore, a sensible approach would be to use a plan period to 2046 but acknowledge that the vision may need to look beyond if considering larger scale developments.]\n\n[Q8] - We do not believe the Council’s should deviate from the Government’s mandatory requirements for 10% biodiversity net gain. The delivery of biodiversity net gain has significant implications for new development in terms of housing density considerations (through additional land take required), potential off‐site costs (for offsetting habitat units) and the long‐term management requirements of enhanced on‐site landscaping/biodiversity areas. This means that there is more allocated land required for residential and employment sites to deliver development and meet BNG targets.\n\nThe PPG states that plan‐makers “should not seek a higher percentage than the statutory objective of ten per cent biodiversity net gain, either on an area‐wide basis or for specific allocations for development unless justified”. It adds: “To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.”\n\nShould the Councils seek to go beyond the 10% mandatory requirement, in line with the PPG there should be robust evidence to demonstrate this is viable when considering the delivery of allocated sites and the housing trajectory within the Plan. The same applies for commercial and employment sites. This should be considered as part of the whole plan viability assessment and should be factored in as a specific item, rather than any planning obligation cost.]\n\n[Q.29] Given the hierarchy and role of Gloucester and Cheltenham, the spatial strategy should focus on meeting the needs of these settlements within their boundaries or adjoining them (and functionally linked). This would be an approach that supports sustainable development by locating housing and employment growth in areas where infrastructure, services and facilities are already available.\n\nA combination of Scenarios 1, 2 and 6 should therefore be taken forward as the most appropriate strategy for the SLP. As set out in our response to Q28, the urban capacity of sites in a higher‐ density scenario needs to be fully understood in relation to design constraints and viability. This will ensure that the needs to be met outside of the limits of towns and cities are realistic.\n\nScenarios 2 and 6 will need to form a key part of the strategy due to the need to plan for the requirements of Cheltenham and Gloucester in as close a proximity to the urban boundaries as possible. This should also align growth with infrastructure and sustainable transport opportunities.\n\n[Q.31]\n1.\tExecutive Summary & Introduction\n1.1\tThis document and accompanying contextual plans have been prepared in response to the current Gloucester, Tew"}}]
["","Land Owner","","We are strongly of the view that the Green Belt policy must be considered as a strategic policy topic, this goes beyond individual local authority boundaries and must be considered at the strategic plan level. Given the NPPF requirement for strategic policies to look to a minimum 30 year timeframe, it is inevitable that there will be changes required to the Green Belt which will require a thorough Green Belt review to take place.\n\nIndeed, NPPF 145 states “Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period. Where a need for changes to Green Belt boundaries has been established through strategic policies, detailed amendments to those boundaries may be made through non- strategic policies, including neighbourhood plans”\n\nThe protection or loss of the Green Belt will be inevitable in the most likely growth scenarios and as such, we believe that a full review is required in order to aid delivery of sufficient land for growth over the 30 year period as well as protecting the most valuable parts of the Green Belt. This ought to include smaller scale locations that could provide between 10 and 250 dwellings in sustainable locations that do not make a valuable contribution towards the purposes of the Green Belt.","It is anticipated that local policy topics would include matters such as:\n\n-\tDetailed development management policies;\n-\tTown and local centre policies;\n-\tLocal facilities provision and open space standards;\n-\tIndividual settlement specific policies;\n-\tHistoric environment policies. ","No","Allied to our consideration of the plan period and looking forward a minimum of 30 years for strategic policies in line with NPPF, we are of the view that the Vision ought to consider this much longer term view. We note that the vision ought to include smaller scale extensions to existing settlements rather than just large scale extensions, indeed, allocations of between 10 and 250 dwellings on the edge of settlements can provide a significant source of additional land for growth and contribute towards meeting needs. Indeed, there are numerous locations where this level of growth can contribute towards sustainable development patterns particularly where they are well placed in terms of existing public transport routes and in close proximity to existing facilities (such as shops and schools). Indeed, such provision can help to sustain and reinforce local sustainability.","No","We are broadly in agreement, however believe that a green belt policy should be included that is accompanied by a review of the existing green belt allied to exploring opportunities for sustainable smaller scale housing sites (between 10 and 250 dwellings) that could help meet overall need alongside larger scale extensions in a sustainable manner. Such locations would round off a settlement, integrate with it and help create a walkable neighbourhood.","We are strongly of the view that by exploring all opportunities for sustainable locations for growth the plan can fundamentally help to shape sustainable patterns of development that aid walkability, reinforce facilities and ultimately help with the overall impacts of climate change.","It is important to note that NPPF requires that Local Plan policies are consistent with national policy and legislation. As set out in the NPPF, the planning system should support the transition to a low carbon future in a changing climate. However, any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.\n\nPPG confirms that:\n\n“The National Planning Policy Framework expects local planning authorities when setting any local requirement for a building’s sustainability to do so in a way consistent with the government’s zero carbon buildings policy and adopt nationally described standards. Local requirements should form part of a Local Plan following engagement with appropriate partners, and will need to be based on robust and credible evidence and pay careful attention to viability.\n\nIn this respect, planning authorities will need to take account of government decisions on the Housing Standards Review when considering a local requirement relating to new homes.” \n\nThe PPG also confirms that locally set energy performance standards should not exceed the equivalent of Level 4 of the Code for Sustainable Homes and for policies to impose reasonable requirements for a proportion of energy used in development to be from renewable and/or low carbon energy sources.\n\nThe Government has, for residential development, established a clear road map for achieving zero carbon ready homes. This is set out in the ‘Future Homes Standards’, which is due to be implemented in 2025. The Future Homes Standards will require carbon emissions produced by new homes to be 75-80% lower than those built to current standards. Any new homes built under these new Building Regulations standards will therefore need to be zero carbon ready, which means that they will immediately be able to benefit from the decarbonisation of the electricity grid.","It is important to note that NPPF requires that Local Plan policies are consistent with national policy and legislation. As set out in the NPPF, the planning system should support the transition to a low carbon future in a changing climate. However, any local requirements for the sustainability of buildings should reflect the Government’s policy for national technical standards.\n\nPPG confirms that:\n\n“The National Planning Policy Framework expects local planning authorities when setting any local requirement for a building’s sustainability to do so in a way consistent with the government’s zero carbon buildings policy and adopt nationally described standards. Local requirements should form part of a Local Plan following engagement with appropriate partners, and will need to be based on robust and credible evidence and pay careful attention to viability.\n\nIn this respect, planning authorities will need to take account of government decisions on the Housing Standards Review when considering a local requirement relating to new homes.” \n\nThe PPG also confirms that locally set energy performance standards should not exceed the equivalent of Level 4 of the Code for Sustainable Homes and for policies to impose reasonable requirements for a proportion of energy used in development to be from renewable and/or low carbon energy sources.\n\nThe Government has, for residential development, established a clear road map for achieving zero carbon ready homes. This is set out in the ‘Future Homes Standards’, which is due to be implemented in 2025. The Future Homes Standards will require carbon emissions produced by new homes to be 75-80% lower than those built to current standards. Any new homes built under these new Building Regulations standards will therefore need to be zero carbon ready, which means that they will immediately be able to benefit from the decarbonisation of the electricity grid.","","No","","It is clear that there are a number of services and facilities that are beneficial to be within easy reach of development such as retail and schools. However, given the sustainable transport based approach, it is clear that development in close proximity (ie 400m) to existing bus routes is perhaps the key consideration. This will ultimately help to sustain and enhance those services.","No","With National Grid advising that the Walham Substation is electrically and physically full it will be necessary to forward plan for future commercial and residential development to ensure connections are available.  Sites suitable for renewable energy generation and storage to support the grid should be identified in suitable locations and this may require changes to the Green Belt in order to facilitate delivery.  New development should be encouraged to generate power where possible.","No","Para. 11(b) of the NPPF confirms that as a minimum, strategic policies within emerging Plans should provide for the objectively assessed needs for housing and other uses. Para. 61 of the NPPF confirms that when calculating the minimum number of new homes required, strategic policies should be informed by a local housing needs assessment conducted using the standard method, unless exceptional circumstances justify an alternative approach. Once this local housing need is confirmed in an updated needs assessment, para. 23 of the NPPF states that strategic policies should then provide a clear strategy for bringing sufficient land forward, at a sufficient rate to address needs over the plan period.\n\nAs confirmed by para. 61 of the NPPF, the standard method is employed to determine the minimum number of homes needed. Indeed, the Planning Practice Guidance (PPG) states that the standard method does not attempt to predict the impact of, amongst other things, changing economic circumstances or other factors including demographic behaviour. In such circumstances, the national guidance suggests that there will be the need to consider whether the actual housing need is higher than the standard method indicates. A number of examples are provided within the national guidance of circumstances where a higher requirement than the standard method of calculation of local housing need should be considered, however, these include deliverable growth strategies for the area.\n\nIndeed, the standard method derived local housing need provides “a minimum starting point in determining the number of new homes needed in an area” whether a higher figure is utilised will depend upon the evidence in respect of:\n\n•\tGrowth strategies;\n•\tDemographics and growth;\n•\tEconomic and employment growth previous and forecast;\n•\tRatio between jobs and homes;\n•\tPrevious delivery and residential need;\n•\tAffordability and ratio to earnings;\n•\tHousing need.\t\n\nThe OAN will also need to consider the plan period and ensure that a minimum of 15 years from adoption is accounted for and for strategic policies this needs to consider a 30 year minimum period.","No","As noted in answer to question 12, the standard method derived local housing need provides “a minimum starting point in determining the number of new homes needed in an area” whether a higher figure is utilised will depend upon the evidence in respect of:\n\nGrowth strategies;\n•\tDemographics and growth;\n•\tEconomic and employment growth previous and forecast;\n•\tRatio between jobs and homes;\n•\tPrevious delivery and residential need;\n•\tAffordability and ratio to earnings;\n•\tHousing need.\t","Yes","The plan will need to provide a response to the demographic projections which underpin the future evidence base and take into consideration para. 62 of the NPPF, which states that the housing needs of differing groups of the community should be assessed and reflected in Policy, including older people and people with disabilities. The PPG also states that LPAs should plan to create safe, accessible environments and promote inclusion and community cohesion.\n\nThe Optional Housing Technical Standards section of the PPG also establishes that when considering what standards should be adopted, LPAs should draw on their housing needs assessment and other available evidence. Evidence could include:\n\nthe likely future need for housing for older and disabled people; \n•\tthe size, location, type and quality of dwellings needed to meet evidenced needs; \n•\tthe accessibility and adaptability of existing housing stock; \n•\thow needs vary across differing tenures; and\n•\tthe overall impact on viability.   ","","N/A","N/A","N/A","N/A","N/A","N/A","Importantly by identifying locations for smaller scale growth at such locations, local facilities can be sustained and enhanced.","Aside from essential infrastructure that is required as part of development, there is an opportunity to enhance existing sustainable transport infrastructure.","N/A","N/A","","Yes","There is a further scenario that ought to be considered, however, it is also the case that the urban extensions and urban concentration scenarios could be expanded upon to accommodate it. In particular this would comprise consideration of smaller scale extensions to existing communities in order to complement the urban concentration and larger scale extensions. Indeed, through this approach numerous sustainable locations within easy reach of existing facilities and services could be identified to serve as a further supply of sites.\n\nIn this regard, para 6.8 acknowledges that none of the scenarios would deliver what is needed on their own but whilst the various scenarios focus on specific solutions (ie brownfield sites or large scale sites) they ignore the potential for smaller sites of between 10 and 250 dwellings to make a valuable contribution. This has meant so far that some small sites within Cheltenham and Gloucester have not been brought forward because the numbers have been delivered by urban extensions in Tewkesbury rather than focussing on existing communities elsewhere.\n\nThere are smaller sites that are currently in the Green Belt which contribute little to Green Belt objectives but remain protected. These would simply round off development in parts of Cheltenham and Gloucester to help deliver much needed local/affordable/specialist housing in well located sustainable, safe locations within walkable neighbourhoods. \n\nIndividually they may not deliver large numbers of houses but collectively can make the best use of land to contribute to the overall housing target and ensure that development integrates with existing development.\n\nThis would tie in with the strategic objective of ‘ensuring growth takes place in sustainable locations that minimise the need to travel and provide genuine sustainable transport and active travel options.’\n\nThis additional scenario or extension to the existing, would complement the others and, with the addition of a Strategic Objective to review Green Belt boundaries, allow small scale housing development in sustainable locations where it would round off a settlement, integrate with it and help create a walkable neighbourhood.","","","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","","","[Q.1] How far into the future should the Strategic and Local Plan cover?\n\nWe believe that there must be clarity regarding the period of the plan. In the first instance NPPF indicates that plans should look forward a minimum of 15 years from the date of adoption. As such, a full 15 year period will be required from the date of adoption, given that it is currently anticipated during 2026, this may mean that the period should be extended to 2042 in order to allow a full 15 year monitoring period and to allow for slippage in the programme. It is important that the full OAN of this period is taken into consideration.\n\nWith regards to a longer period, NPPF para 30 says where larger scale developments such as new settlements or significant extensions to existing villages and towns form part of the strategy for the area, policies should be set within a vision that looks further ahead (at least 30 years), to take into account the likely timescale for delivery. Given the strategic nature of the plan we are of the view that the minimum 30 year timeframe would be the most appropriate starting point.\n\n[Q.8] Should the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nAgain, it is important that Local Plan policies are consistent with national policy and legislation as required by the NPPF. Any higher requirement than the minimum 10% would be in conflict with the Environment Act, which seeks a 10% biodiversity net gain. Should a higher level be advocated, it would lead to a situation where planning applications could be refused on the grounds of the local policy framework, despite according with national legislation.\n\nIt should also be noted that the mandatory net gain requirement within the Environment Act is expressed as a minimum. Accordingly the mandatory minimum should be used, with discretion for proposals to provide more subject to local circumstances and viability.\n\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nWe are supportive of a combination of scenarios which includes Urban concentration, Urban extensions and sustainable transport.\n\nIt is unarguable that as a starting point consideration should be given to development potential within existing urban areas. However it is likely that such sources will be small scale and constrained in nature and will form a small component of future housing supply as has historically been the case. \n\nAs part of the urban concentration consideration should be given to logical smaller scale greenfield sites that are in close proximity to services and main sustainable transport routes that can be developed through minor tweaks to settlement boundaries. Indeed, this should be linked to a green belt review and would form part of an urban concentration approach as it would allow housing development in sustainable locations where it would round off a settlement, integrate with it and help create a walkable neighbourhood.\n\nIt is clear that urban extensions at sustainable locations will form a significant component of the strategy. This should be linked to a Green Belt review to allow housing development in sustainable locations where it would round off a settlement, integrate with it and help create a walkable neighbourhood. There are vacant, redundant farms on the edge of the urban areas that lie in the Green Belt which are constrained and could make early valuable contributions to housing numbers.\n\nWe consider that in line with NPPF the approach taken ought to focus on sustainable transport routes, in locations that are well placed with regards to existing corridors and facilities. It is inevitable that Cheltenham will form the focus for that with appropriate locations for growth identified immediately adjoining the settlement boundaries."]
["I work for a charity or volunteer in the area","Gloucestershire Wildlife Trust","","","","No","We are pleased to see nature recovery at the top of the list of key issues. It should also be mentioned up front in the first paragraph of the draft vision, as it’s a key priority and is fundamental to meeting many of the other ambitions. \n\nFirst paragraph suggested text: Growth will have afforded the highest possible quality of life for all, in a manner which achieves carbon reductions, addresses the causes and effects of climate change and supports natures recovery. Third paragraph: No mention of new housing developments including green spaces. \n\nThird paragraph suggested text: \n\nPeople’s housing needs will have been met through the provision of sustainable, high-quality market, affordable and other specialist homes. These will be set in beautiful, safe, nature supporting places and conforming to sustainable standards of design and construction. The focus will have been on making best possible use of brownfield sites in built up areas and large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved. The vital role of the area’s city centre, town centres and high streets will have been improved through careful management of development and land uses. \n\nSuggested new text for fifth paragraph, as it was a bit confusing to read. Hopefully this flows better and makes flood management and biodiversity improvements read as less of a tag on to the end of the paragraph. \n\nFifth paragraph suggested text: Growth will have been supported by the provision of a range of essential digital, transport, community and other infrastructure. Active flood risk management and enhancements to biodiversity will be integral to decisions around growth and development. Alongside conserving the area’s special landscapes and its attractiveness as a place to visit, an expanding network of interconnected, multifunctional green spaces and waterways will have secured a high-quality environment for people and nature. Existing sports and leisure facilities will have been managed and retained, with growth unlocking new opportunities for healthy lifestyles and inclusive access to sport and recreation. \n\nThe draft vision/objectives are quite inward looking, without acknowledging the importance of working with neighbouring authorities. A point should be made in the vision (and objectives) around this to ensure optimal outcomes, including for climate and nature, but also other issues such as transport. An example is the need to identify land to develop large suitable alternative green spaces (SANGs) to help manage and mitigate recreational pressure at popular designated sites.","No","We are pleased to see that ‘Meeting the challenges of climate change’ is at the top of the list of strategic priorities but are disappointed that a strategic objective to enhance biodiversity and support nature recovery has not been included. Biodiversity is necessary for our survival so let us be clear about that and not let it become an afterthought. \n\nIn the current format, the two issues (climate challenges and nature recovery) are conflated under the ‘challenges of climate change’ objective, with some objectives for nature recovery also included under the ‘Making as much use as possible of brownfield land and conserving and enhancing the natural and historic environments’ objective. \n\nThis could give rise to decision makers or developers, who are using the SLP, being unclear on what is required in terms of demonstrating clear evidence for both climate challenges and supporting nature recovery. For example, developers may think that because they have demonstrated evidence for energy conservation, that they have met the needs of strategic objective. These are two separate policy issues (of course they are linked but that could be said for most of the objectives) and should be set out as so. \n\nAn additional biodiversity and nature recovery objective should set out the need to protect, manage and enhance the area’s unique natural environment and biodiversity, BNG requirements and there should be an explicit point in here about supporting nature recovery, through maximising opportunities to create and extend new habitat in nature recovery network priority zones, as per the future local nature recovery strategy (LNRS). This is by no means an infinite list and we would like to see other points that relate to nature recovery/ GI interwoven into other objectives. We are happy to have further discussions to help shape this objective. \n\nIn addition to a separate strategic objective for biodiversity and nature recovery, we would like to see the development of an SLP that is green at its core, essentially making climate and nature fundamental and essential themes, woven throughout the whole of the document. This prevents climate and nature policy areas becoming siloed and creating potential tensions with other policy areas. We can see some good evidence of this in the regulation 18 consultation, however, there are some missed opportunities. These are set out below, with suggestions and proposed text that we would like to see incorporated. Some of these suggestions may need amending if a new biodiversity/ nature recovery objective is added to avoid repetition. \n\nMeeting the challenges of climate change \n\nPoint 1. The ‘achievement of biodiversity gains’ is weak and out of date. This should be amended to read ‘The achievement of ambitious biodiversity gains, of at least XX%’ (depending on outcome of consultation on BNG%). \n\nReference needs to be made here to the LNRS and nature recovery maps. The need to align with these should be explicit in the SLP strategy (as part of a new strategic objective as above). Suggested text: Growth and development should support the achievement of ambitious biodiversity gains of at least XX% and should align with the local nature recovery strategy and nature recovery network maps. Growth should not cut off ecological networks and should enhance connections between those networks. \n\nPoint 3. Make it clear that developing Brownfield land needs to be seen as an opportunity for big enhancements for nature. Suggested text: Making the most effective use of previously developed land, including higher density development in city and town centres and other locations well served by public transport, and seeking out opportunities to add high-quality green infrastructure to support climate resilience, well-being and enhance nature networks. \n\nPoint 4. Not clear what the climate aspect is here. Make clearer that the ability to get to facilities through walking, cycling or public transport is what this is about. \n\nPoint 5. Need to be careful that there isn’t massive land takes for solar farms (already seeing this). Need to integrate as much solar energy collection into infrastructure as possible (see question 11 response), including both new development and retrofitting. Statement could be stronger. \n\nPoint 6. Strengthen the language here around sustainable drainage. Sustainable and natural methods should be prioritised. The NPPF states that development should make as much use as possible of natural flood management techniques. We have suggested text to be more in line with this. Natural flood attenuation also provides multifunctional benefits (climate adaptation, biodiversity benefits). The opportunity for this is missed when it is not used. Suggested text: Ensure development is located in areas that are not liable to flooding, considering the implications of climate change, making as much use as possible of sustainable drainage systems and natural attenuation techniques, which will provide multifunctional benefits including biodiversity enhancements. Ensure that existing infrastructure is adequately protected from the threat of flooding, and that existing flood defences are protected and enhanced, including utilising natural flood management. \n\nThere should also be something in this section about creating places that connect people with nature and inspire people to want to live more sustainable lifestyles that help to reduce the impacts of climate change and support biodiversity. This should be through both new development and regeneration. \n\nBuilding strong, competitive and sustainable urban and rural economies \n\nThe need to incorporate high-quality GI on land used for business and commerce should be mentioned in this objective. This will support health and well-being when people are at work, nature recovery and provide additional natural capital. Not setting this expectation would be a huge, missed opportunity. \n\nPoint 4. We acknowledge that home working is increasing, and that people are looking for homes which have space for this, but this objective is in danger of promoting even bigger housing footprints and the grab of greenfield land. This shouldn’t lead to homes with a bigger footprint, at the cost of green space. It would be better focussing on more efficient public transport to work locations, so that commutes are quicker and easier and removal of this point. Larger development could also incorporate more flexible working hubs, for example, to support people who wish to work very locally to where they live. \n\nPoint 5. Something could be added here around managing recreational pressure. Suggested text: Developing the area’s role as a tourist destination, building on the unique and varied cultural offer that already exists, whilst acknowledging the need to manage and protect special sites that are vulnerable to recreational pressure. \n\nEnsuring strong, vibrant, city and town centres \n\nAdd the word ‘sustainable’ into the title of the objective, so it reads Ensuring strong, vibrant, sustainable city and town centres \n\n• There should be something in here about the important role of GI in meeting this objective. Something should be added about ensuring green and attractive places are incorporated into regeneration and development schemes in urban areas, to deliver multiple benefits for people and nature (ie places for people to gather and socialise, relax, connect with nature, for urban cooling, provide urban gardening opportunities, rain gardens and green space for natural flood attenuation). GI also adds identity and character to city and town centres.\n• Incorporate something about flexibility in change of use, as the needs of city/town centres change. \n• Ensuring accessibility of centres so that business and retail is not continuously moved to greenfield development on the outskirts, leaving the centres empty. \n\nDelivering well designed, beautiful and safe places \n\n• We would like to see mention of using a green infrastructure framework to support this, such as Building with Nature. \n\nMaking as much use as possible of brownfield land and conserving and enhancing the natural and historic environments \n\nAs above, some of the points we raise here would be better suited in a dedicated strategic objective for biodiversity and nature recovery. \n\n• The combining of natural and historic environments is a very broad policy range in effect and again, as mentioned above in relation to biodiversity and climate change, refers to two very different & specific policy areas. Again, this leads to the need for a separate heading under the Draft Strategic Objectives for nature recovery. \n• There should be an explicit point in here about supporting nature recovery, through maximising opportunities to create and extend new habitat in nature recovery network priority zones. \n• Point two. Could be slightly amended to reference the extension of the nature network and to make specific reference to local sites. Suggested text: Conserving, managing, extending and enhancing the area’s unique natural environment and biodiversity. This includes its waterways, Sites of Special Scientific Interest (SSSI), the Cotswolds National Landscape, and areas of landscape and biodiversity importance, including locally designated sites, and maximising the opportunities to use land to manage flood water. \n• Point 3. Could be re-worded. GI supports sustainable development, not the other way round which is how it reads. Would suggest a change to something like: ‘Ensuring the delivery of high-quality green (and blue) infrastructure to support sustainable, future proof developments in both rural and urban areas, which provide movement corridors for both people and wildlife’. • An additional point would be helpful here to reference the need to protect the area’s most precious (but popular) sites, by providing alternative, attractive areas of green space (SANGs) for recreation. Also need to acknowledge that larger SANGs can’t be developed by districts alone and need to be designed at county or regional level. \n\nPromoting healthy and resilient communities \n• Point 3. Suggested text: Delivering new developments that are fully integrated into the GI network, adhering to the local nature recovery strategy, to allow people access to nature and green spaces, to maximise wellbeing and active travel opportunities. \n• Point 4. Suggested text: Ensure new developments create high quality living environments, both inside and out, and prioritise health and mental wellbeing. \n• A point could be added here about addressing inequalities. Enhancing and increasing green spaces near to where people live can be a huge contributor to improving health and wellbeing and helping to address inequality.","The latest state of nature report published in 2023 shows that since 1970, UK species have declined by about 19% on average, and nearly 1 in 6 species (16.1%) are now threatened with extinction (State of Nature, 2023). This means that despite efforts to protect and enhance biodiversity, wildlife is still declining. It also stated that most of the important habitats for the UK’s nature are in poor condition. Action needs to be taken now, or this decline will continue. This is why GWT, along with around 420 members of the public who have joined our campaign, are asking all three SLP councils to declare an ecological (nature) emergency. \n\nDeclaring a nature emergency \n\nClimate change is driving nature’s decline, and the loss of wildlife and reducing biodiversity leaves us ill-equipped to reduce carbon emissions and adapt to change. All three councils have declared a climate emergency whereas only one (Tewkesbury) has declared an ecological emergency. The two are inextricably linked and one cannot be addressed without the other. Now is the right time for all three councils to be making the declaration, because the policies needed to put the declaration into action can be developed and introduced into the new SLP. This should include making sure nature recovery and enhancement (not just protection) is a true priority and at the forefront of the new SLP, ensuring that all development in the districts supports nature connectivity, enabling more people to access and connect with nature and promoting naturebased solutions. \n\nOn a wider note, nature recovery also needs to be embedded into the three councils’ other plans and policies, not just the SLP. For example, other councils, such as Bath and Northeast Somerset have developed action plans to deliver against their ecological emergency declarations. \n\nImproving connectivity of habitats \n\nImproving connectivity of habitats is key to addressing the impacts of climate change on nature’s ability to adapt and thrive. Wildlife needs to be able to move around to adapt to a changing climate, and providing the space for this through additional, high-quality habitat will help to reverse declines and prevent even bigger declines as a result of climate change. In turn, this will also help to enhance ecosystem services and provide natural mitigation to climate impacts. The SLP should also make reference to improving connectivity at a landscape scale and working with/ supporting other councils/ partners on cross border initiatives. Encouraging ambitious biodiversity net gain (see question 8) and making sure that the right habitats are delivered in the right places, in line with the nature recovery network, will support this. \n\nPrioritising ecosystem services \n\nEcosystem services have a huge role to play in addressing both the climate and ecological crisis. Nature-based solutions, focused on enhancing natural habitats, are also one of the cheapest and most effective tools in helping to address climate impacts and meet local, national and global climate goals. The SLP should be ambitious in this regard. For example, requiring that water management on development sites must include natural flood attenuation methods. We are still seeing examples of developments where this is not being designed into developments when it could be and the multiple benefits that can be achieved are missed. The Gloucestershire Ecosystem services maps can support this, demonstrating where opportunities are, and should be given reference in the SLP. \n\nRequiring the use of Green Infrastructure frameworks \n\nA mechanism that can help to support and deliver the above for new development is the use of green infrastructure (GI) frameworks, such as Building with Nature (BwN) and Natural England’s GI framework. As BwN includes an assessment and accreditation process, to ensure the quality of GI on development sites is high, this would be our preference, especially for larger developments. We would also like to see a requirement in the SLP for regeneration projects to do all they can to provide climate resilience by using effective GI, including green rooves, green walls, wildlife boxes, water re-use and capture, alongside renewable energy solutions. Though there will be some locations where sites are just not suitable because of the biodiversity sensitivities, even if the best GI in the world was designed into them. \n\nImproving the connection between people and nature \n\nWe would like to see policies in the SLP that encourage the connection between people and nature across the three districts. There are many well-known benefits of spending more time in nature for health and well-being, but there is also evidence that connecting people with nature and raising awareness of the importance of protecting the environment can support sustainability and pro-environmental attitudes and behaviour more widely.1 Easy access and good connections to nature, especially for young people who will be the change makers of tomorrow, will be vital for addressing the climate and biodiversity challenges of the future. \n\nAnother way to help connect people with nature is to address some of what the public perceive as ‘issues’ relating to nature which can lead to negative attitudes towards pro-environmental behaviour. For example, maintaining the upkeep of green spaces (ie by clearing leaf debris that leads to drain blockages or by maintaining trees) so that people learn to appreciate and take pride in these areas rather than feeling frustrated by them. \n\nUpdates in line with national policy \n\nFinally, it goes without saying that the SLP will require a lot of updating to reflect recent government policy updates that relate to climate, since the last JCS was published. This includes the 25 Year Environment Plan and the recent EIP, the Environment Act 2021, the NPPF, NPPG etc. Part of this will be the added emphasis on the importance of the nature recovery network in plan making, as currently outlined on Gloucestershire Local Nature Partnerships website and as part of the upcoming local nature recovery strategy (LNRS). We also note that the habitat regulations are not mentioned in the document, or under the policy framework for climate and nature recovery and they should be referenced in relation to legislation around protecting European sites.","It is important that appropriate GI is incorporated into buildings (ie bird boxes, planters, green walls, green rooves, raingardens). If all buildings incorporated all or even some of these features then connectivity, especially in urban areas, would be improved. Opportunities to retrofit effective, multifunctional GI onto existing buildings should also be highlighted in the SLP. \n\nNew buildings should be designed and positioned sympathetically, so as not to interfere with wildlife (ie not to close to woodland edges that bats use for feeding). Impacts on biodiversity from the construction and operation of buildings, especially close to core nature recovery network, including designated sites, must be avoided. The SLP should make it clear that the council would not support development that will impact these sites (in line with the NPPF). \n\nAll new buildings should include renewable energy sources for electricity and heating. An enormous amount of energy is lost because of poorly insulated housing and commercial buildings. High-quality insulation for buildings which are being re-used/ retrofitted should be a priority. Tackling energy efficiency across the SLP area would help address the cost-of-living crisis whilst reducing the demand for energy and helping to address the nature and climate crisis.","It is important that appropriate GI is incorporated into buildings (ie bird boxes, planters, green walls, green rooves, raingardens). If all buildings incorporated all or even some of these features then connectivity, especially in urban areas, would be improved. Opportunities to retrofit effective, multifunctional GI onto existing buildings should also be highlighted in the SLP. \n\nNew buildings should be designed and positioned sympathetically, so as not to interfere with wildlife (ie not to close to woodland edges that bats use for feeding). Impacts on biodiversity from the construction and operation of buildings, especially close to core nature recovery network, including designated sites, must be avoided. The SLP should make it clear that the council would not support development that will impact these sites (in line with the NPPF). \n\nAll new buildings should include renewable energy sources for electricity and heating. An enormous amount of energy is lost because of poorly insulated housing and commercial buildings. High-quality insulation for buildings which are being re-used/ retrofitted should be a priority. Tackling energy efficiency across the SLP area would help address the cost-of-living crisis whilst reducing the demand for energy and helping to address the nature and climate crisis.","Yes","No","An expectation should be set out for the Nature Recovery Network and Ecosystem Services mapping (which will be integrated into the LNRS) to be taken into account in development plans. The maps establish existing core habitat and priority opportunity habitats for different area across the county. As in our above BNG response, ensuring that development in the districts integrates this will be essential in addressing nature recovery needs. It will also be key for the councils in furthering their biodiversity objective. \n\nThe core, high and medium priority Nature Recovery Network zones (in relation to paragraph 4.12 of the consultation document) should be prioritised as areas that must be protected from development and enhanced where the opportunity arises. The Ecosystem Services mapping highlights opportunities for water flow regulation, local climate regulation, air pollutant removal, recreation, education, interaction with nature; and baselines for carbon storage and food production. Again, opportunities should be sought. \n\nThe Gloucestershire Nature and Climate Fund (GNCF) should be referenced as the preferred way for developers to identify land for off-site BNG, to try and keep biodiversity gains as a result of development within the county. \n\nPrivate gardens that are part of new developments could collectively make a large contribution to good quality green space and connectivity. One of the issues is that developers/councils have no control over is what people do with their gardens once they move into their homes. One of the big issues is the replacement of turf with astro-turf. We are aware that some other councils are reviewing the policy mechanisms available to them through the planning system, that will reduce the prevalence of astro-turfing and we would like to see the three SLP councils do the same. \n\nWe would also like to see reference in the SLP to developers working with new communities (and ideally existing communities but we acknowledge that this will be more of a challenge) to inspire them to create and maintain nature friendly gardens. This is also relevant to question 6, as astroturfing prevents carbon storage and contributes to climate change.","Over 90% of adults report that time spent outdoors is good for their physical and mental health. Currently, 38% of people do not have green or blue space within 15 minutes’ walk of their home (Defra, 2023). GWT believe it is vital that people have easy access to varied green space, including for recreational and well-being benefits and to provide opportunities to connect with nature. We would support that the following is taken on board in the SLP in regard to this: \n\no Natural England established an Accessible Natural Greenspace Standard (ANGSt) around 30 years ago, which was based on research into minimum distances people should travel to access nature. ANGSt recommends that everyone, wherever they live, should have an accessible natural greenspace as per the following guidelines: \n• of at least 2 hectares in size, no more than 300 metres (5 minutes’ walk) from home; \n• at least one accessible 20-hectare site within two kilometres of home; \n• one accessible 100-hectare site within five kilometres of home; and \n• one accessible 500-hectare site within ten kilometres of home; plus \n• a minimum of one hectare of statutory Local Nature Reserves per thousand population. \n\no More recently, Defra have put additional emphasis on the importance of good access to green space in the Environmental Improvement Plan (EIP, 2023). This states that the public should be able to access green space or water, such as woodlands, wetlands, parks and rivers, within a 15-minute walk of their home. The plan also has a goal to ‘Create more green and blue spaces and enhance existing ones and support responsible access and behaviour’. We would like to see a similar policy in the SLP. \n\no In relation to the above and in taking an approach to support responsible access and behaviour, we strongly support the development of new Suitable Alternative Green Spaces (SANGs) where the level of development is going to bring with it increased recreational pressure on some sites. For example, Coombe Hill, due to the levels of development in northwest Cheltenham (see more on SANGs in response to question 31). We would support a call for sites to highlight opportunities for these around the area. \n\no In 2022, Natural England also championed green social prescribing (GSP), which is ‘the practice of supporting people to engage with nature-based interventions and activities to improve their mental health’. We would like to see the councils support this at a local level, potentially looking for opportunities to partner with other organisations. It would help to demonstrate that the councils are not only aware of the well-evidenced link between access to nature and mental health, but also want to take action for the communities within the SLP area. Natural England have published a wealth of information around GSP for further reference.","No","The Wildlife Trusts actively support effective and suitable onshore wind and solar energy generation projects, to avoid delay in the delivery of low carbon energy and meet net zero by 2050. They must be designed, operated and built in the right location and in the right way, to contribute to nature’s recovery. In particular: \n\n• Onshore wind and solar developments should be planned with the grid network as part of a national spatial strategy and their specific location informed by the local nature recovery strategy (LNRS). \n• All developments must be designed to provide ambitious net gains for nature. \n• Onshore solar and wind farms and their associated infrastructure must not be sited directly on areas of existing high value wildlife habitat, within designated nature conservation sites or areas identified as high priority for restoration or where harm is likely to be caused to populations of vulnerable, threatened and endangered species. \n\nCollectively, onshore wind and solar energy infrastructure have potential to make a major contribution to tackling climate change and its impact on wildlife. But as with any development, it must be thoughtfully located and designed, to avoid adverse impacts on wildlife. \n\nWe would like to see more prioritisation of small-scale wind and solar installations on buildings or within built/fabricated structures (e.g solar panels in pavements on cycle paths), especially where they can produce and distribute electricity supplies to help meet local demand. This is providing they can be developed with no additional land-take and their installation and operation avoids damage and disturbance to wildlife, particularly birds, bats, their roosts and nests.","No","","No","","No","","","","","","","The councils could help to support a more local, sustainable supply of food from local farmers. At present, it’s easier to buy from one large supplier of all food products than to buy locally, for example, for schools and other local businesses. Local drop off points for food products could help, where farmers could drop off produce at local collection centres. We would recommend discussing opportunities for this with the farming community.","","","If development across the districts is going to be resilient to climate change and support nature recovery, then high-quality, multifunctional, well-connected green (including blue) infrastructure (GI) must be a fundamental element of all development. This should be regardless of whether that’s in higher density urban areas (ie through effective GI on buildings themselves), or in lower density areas. \n\nEffective GI alongside other infrastructure delivers many benefits. This includes biodiversity benefits, flood attenuation, urban cooling and water storage as well as acting as a carbon sink to help tackle the impacts of climate change. It also helps to reduce pollution in urban areas and improve air quality. \n\nWe want the councils to be pushing developers to be creative in how they deliver GI. It should not be acceptable to avoid delivering effective GI in urban areas because of a ‘lack of space’. The same applies to regeneration/ retrofit projects. These should be seen as an opportunity to integrate more GI into existing infrastructure. \n\nDevelopment with high-quality GI can also significantly benefit health and well-being for people that use the space, as referenced throughout the response to this consultation. Green spaces and well-designed GI can also improve the attractiveness and character of towns and cities, helping to attract new businesses and investment and people, who chose to move to the area and call it home, helping the boost the local economy (in response to question 21). \n\nWe acknowledge that the provision of high-quality GI often comes down to cost of maintenance for the council. We are confident that the benefits that trees and natural surfaces etc provide, including economic benefits over the long-term and cost savings from de-risking climate related impacts such as flooding and urban cooling, will present benefits that far outweigh costs.","If development across the districts is going to be resilient to climate change and support nature recovery, then high-quality, multifunctional, well-connected green (including blue) infrastructure (GI) must be a fundamental element of all development. This should be regardless of whether that’s in higher density urban areas (ie through effective GI on buildings themselves), or in lower density areas. \n\nEffective GI alongside other infrastructure delivers many benefits. This includes biodiversity benefits, flood attenuation, urban cooling and water storage as well as acting as a carbon sink to help tackle the impacts of climate change. It also helps to reduce pollution in urban areas and improve air quality. \n\nWe want the councils to be pushing developers to be creative in how they deliver GI. It should not be acceptable to avoid delivering effective GI in urban areas because of a ‘lack of space’. The same applies to regeneration/ retrofit projects. These should be seen as an opportunity to integrate more GI into existing infrastructure. \n\nDevelopment with high-quality GI can also significantly benefit health and well-being for people that use the space, as referenced throughout the response to this consultation. Green spaces and well-designed GI can also improve the attractiveness and character of towns and cities, helping to attract new businesses and investment and people, who chose to move to the area and call it home, helping the boost the local economy (in response to question 21). \n\nWe acknowledge that the provision of high-quality GI often comes down to cost of maintenance for the council. We are confident that the benefits that trees and natural surfaces etc provide, including economic benefits over the long-term and cost savings from de-risking climate related impacts such as flooding and urban cooling, will present benefits that far outweigh costs.","","","","","","","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","",{"$cut":{"chars":17378,"head":"Not enough emphasis on enhancement in certain parts of the consultation document \n\nIn paragraph 4.19 there is an over-emphasis on mitigation, rather than enhancement. Referring to mitigation is not up to date with policy. Right from the outset (i.e. para 180), the NPPF refers to a requirement for enhancement, not just mitigation in planning policies and decision-making, and not just for priority species, protected habitats, etc. \n\nSuitable Alternative Green Space (SANGs) \n\nWe have mentioned these throughout our response but would like to reiterate their importance here. The consultation document outlines that the population is forecast to grow significantly, with an additional 23,000 families moving into the area. As a result of this, there will be a substantial amount of recreational pressure added to some of the areas most special and unique places, which are core to nature recovery. It is vital that new sustainable alternative green spaces (SANGs) are identified in the area, potentially through a call or sites, to address this issue and ensure that SANGs can be delivered before people move into the area, as they will take time to mature and become attractive sites that people will choose to visit over other, popular, more vulnerable sites. \n\nSupplementary Planning Document for nature recovery \n\nWe would support the development of SPDs for biodiversity/ nature recovery across the three council areas, prior to the SLP being published, to ensure there is no gap where clarity is needed. We would be more than happy to discuss this separately. \n\nA dedicated Green Infrastructure Strategy \n\nWe are aware that an updated GI strategy was going to be developed a couple of years ago, to sit alongside the new JCS/SLP. This could help to ensure the level of detail around GI requirements in the area is thorough and that clear actions are set out. We would be supportive of this and would be happy to support in its development, should it be taken forward. \n\nProtection for hedgerows and watercourses \n\nThere have been recent instances where development consent has been granted for hedgerow removal during nesting season, which is very concerning. This has been to facilitate projects which could have been carried out during more appropriate times of the year. There has been a lot of debate around the legal protection for hedgerows recently at a national level. As a vital part of the nature recovery network, we would like to see them given appropriate protection in the SLP, so that their removal is highly limited, (and does not happen during nesting season) and that there is an added emphasis on the need for their enhancement. \n\nThe same goes for watercourses. They are also a core part of the nature recovery network, which means they should be protected, and often development is happening within close proximity to them, interfering with the wildlife within them. We would like to see an SLP policy that requires development to leave appropriate buffer zones around watercourses and take measures to ensure watercourses are not negatively impacted by nearby development. \n\nA commitment to a % target for nature recovery \n\nThe Government have a target, for 30% of land to be supporting nature recovery by 2030. We would support the SLP having a similar target, acknowledging that this will likely need to be over a longer time period (ie 35% of land by 2035). We would be happy to discuss any of the above points further or provide support in their development.\n\nShould the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nWe are pleased to see this question asked in the consultation but feel the way in which it is presented demonstrates that there is already a negative outlook on going above the minimum BNG requirement of 10%, which is unnecessary at this stage of the SLP development process. \n\nBNG should now be accepted, in most cases, as a ‘new normal’ additional cost for developers, not a newly applied financial burden. The potential cost to developers is not weighted in the text against "}}]
["Planning agent or developer","Miller Homes","","No. We consider that the strategic policies set out in paragraph 2.4 of the consultation document identify the key strategic policies that the SLP should address.","As the SLP will cover three authorities, it is important that the SLP considers policies where a shared overarching policy approach may be appropriate as well as local-level policies for a specific authority, community or neighbourhood. By taking this approach, the SLP can ensure that the individual needs of the authorities and communities are accounted for as well as preventing duplication within the plan. Policies relating to housing delivery are not only specific to a Council area, neighbourhood and community but are also site specific. The affordable housing needs, including the requirement for certain types or tenures of property, are likely to vary significantly across the plan area and it would therefore be inappropriate, and lack robustness, if the SLP included a single overarching policy on affordable housing. The policy should instead be tailored to the needs of the administrative area and the development proposal.","No","We agree with parts of the draft Vision, such as those encouraging thriving, energy-efficient, resilient and healthy places that support a higher quality of life, however, there are parts of the draft Vision that we disagree with. \n\nWe do not support reference to ‘beautiful’, at paragraph 3: “People’s housing needs will have been met through the provision of sustainable, high quality market, affordable and other specialist homes set in beautiful [our emphasis], safe places and conforming to sustainable standards of design and construction.” \n\nThe term ‘beauty’ is subjective, i.e. what one individual considers beautiful, another may not. The subjective nature of ‘beauty’ could have significant implications on the determination of planning applications (i.e. prolonging the determination period whilst the subjective views of different statutory consultees are considered) and could ultimately, through the refusal of planning permission on grounds of ‘beauty’, result in more Section 78 planning appeals. Both examples would have significant implications on the ability of the SLP area to meet its housing needs. \n\nWe recommend that the opening sentence to paragraph 3 is amended as follows: “People’s housing needs will have been met through the provision of sustainable, high quality market, affordable and other specialist homes set in beautiful well designed, safe places and conforming to sustainable standards of design and construction.” \n\nWe strongly disagree that focus of new housing development should be limited to brownfield sites and large-scale new development, as set out in the draft Vision. To ensure the housing needs of the SLP area can met it is critical that a range of sites of different sizes and in different parts of the SLP area are identified for housing led development. Limiting housing development to brownfield land and large scale new developments will result in settlements which are allocated no growth stagnating and the closure of services and facilities if they cannot be sustained by the resident population, \n\nIt is accepted that the delivery of brownfield land is more challenging than the delivery of greenfield land, often due to the unknown nature of ground conditions which is likely to require remediation work. The challenging nature of brownfield land delivery means that these sites often take longer to come forward for development. The challenges faced in delivering viable brownfield redevelopment often means that limited or indeed no affordable housing is delivered. Further, given the often urban nature of brownfield land, development often come forward as apartment schemes and fails to provide a ranges of dwelling types and tenures that meet the needs of the population. Similarly, it is accepted that large-scale developments often need to be supported by large scale infrastructure which needs to be delivered before any new homes can be delivered. An over reliance on brownfield land and large scale new developments will make it more challenging for the Council to meet its housing growth aspirations and deliver its Vision. It is important that the SLP is resilient and flexible to housing delivery delays the Vision should therefore support the development of brownfield and greenfield land in equal measure alongside the delivery of large scale new developments and proportionate development at settlements across the SLP area.","Yes","We broadly agree with the draft Strategic Objectives. \n\nParagraph 3.5 of the consultation document sets out that: “ (…) some elements need updating or there is a need to reflect a new or stronger priority. This includes for example the need to address the implications of climate change, with each council making strong commitments over the coming years and importantly, through the SLP.” \n\nIt is important that the Strategic Objectives are kept under review and new priorities taken in consideration however we do not support the suggestion that one Strategic Objective should be prioritised ahead of another. It is accepted that there is a national housing crisis and the need to rectify this should be given equal weight as other Strategic Objectives such as those responding to climate change. \n\nIn line with our response to Question 5 we strongly disagree with the draft Strategic Objective “Delivering well designed, beautiful and safe places” and the use of ‘beautiful’ both in the title but also in the first response. The term ‘beautiful’ should be deleted from the draft Strategic Objective.","The SLP will be most effective in addressing the impacts of climate change if it focuses growth in sustainable locations and supports development proposals which deliver sustainable energy solutions. \n\nFocusing Growth in Sustainable Locations The SLP should encourage development which is in close proximity to the strategic highway network, sustainable modes of transport such as the rail network, employment opportunities and services and facilities such as schools, shops and medical care. Supporting development in locations which benefit from these uses will provide current and future residents of the SLP area with the means to choose a lifestyle which helps limit the impacts of climate change. Importantly, as stated in the SLP consultation document, proximity to open countryside can enable more people to access natural and green spaces, improving health and mental wellbeing and quality of life. \n\nDelivering Sustainable Energy Solutions New housing developments are designed to be energy efficient with well-insulated, high-quality homes that provide households with opportunities to reduce their carbon footprint. For example, all Miller Homes developments are built in-line with modern building regulations and are fitted with energy efficient appliances, water efficient sanitary ware and low energy or LED lighting.","The SLP should reflect existing national standards for the construction and operation of new buildings and should not introduce policies which go beyond national policy and legislation. The SLP should not repeat national policy.","The SLP should reflect existing national standards for the construction and operation of new buildings and should not introduce policies which go beyond national policy and legislation. The SLP should not repeat national policy.","No","No","","","No","","Yes","If the local planning authorities in the SLP area want to deliver the draft Vision and Strategic Objectives set out in the consultation document it will be critical that the housing needs of the area are understood, embraced and actively delivered against. Until the local annual housing need is understood and based on robust evidence it is not possible to determine which method should be used.","No","There are no constraints which would mean that the number of homes needed in the SLP area should not be planned for.","Yes","The NPPF (2023) is clear that within the context of establishing housing need, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies. It is considered that the SLP has identified the specific types, sizes and tenures of property which may be required within the SLP area. It should be noted however that not all uses can, or should, necessarily be met on each site. To ensure the SLP is effective it will be important to ensure the specific needs of the area are considered when determining planning applications. For example, it will not be suitable to require all housing allocations to deliver gypsy and traveller pitches or custom build plots. Similarly, whilst there may be a specific evidenced need for bungalows in a part of the SLP area there may not be a need for this type of property in other parts of the SLP area.","","","","","To provide an environment that is attractive to inward investment in employment development the SLP should encourage the delivery of new homes. Supporting housing growth and delivering new homes in the SLP area will encourage families to locate to the SLP by increasing the number of housing options available to them. Further, delivering a range of house types and tenures will provide individuals and families who may have been looking to move away from the SLP area, if they cannot identify a property to meet their needs, with the means they need to stay in the SLP area. Maintaining an economically active population in the SLP area will encourage employment developers and operators to invest in the SLP area.","Please refer to our response to Question 20. Providing a range of house types and tenures in the rural area will encourage employment uses to follow.","","To protect and encourage essential shops, services and facilities, the SLP should encourage the delivery of new homes within existing villages and rural areas. The delivery of new homes can, by increasing the population of an area, increase the number of people utilising essential shops, services and facilities. Furthermore if businesses in an area are seen to be thriving this can be the catalyst to encourage new services and facilities to locate to an area or existing services and facilities to invest and expand / improve their offer. \n\nNew residential development is often required to make financial contributions to services and facilities which would be impacted by the development e.g. financial contributions to education, health care and library services. Consequently supporting housing development in villages and rural areas will have a direct impact on the ability for existing services and facilities to thrive and expand.","The definition of critical infrastructure will vary between one site and the next and consequently it is difficult to define what the most critical infrastructure provided alongside new development is. Development proposals should be assessed against the individual merits of the scheme and whilst it may be critical to deliver highways infrastructure in one area it may be more critical in another area to deliver access to the countryside.","","When deciding if a rural settlement is a suitable location for new homes and other forms of development, the SLP should consider the proximity of the location to and relationship with a range of employment opportunities, strategic transport infrastructure and the countryside. \n\nAs stated in the consultation document, it is important that rural communities are able to capitalise on the potential for economic growth and that a flourishing circular economy is supported in both urban and rural areas. Therefore, by locating new housing development near thriving employment areas such as Ashchurch Business Centre, the rural circular economy can be supported, helping to support existing rural settlements, encourage greater inward investment, improve skills and retain a younger workforce. Furthermore, by strategically locating employment and homes together, the SLP can reduce the reliance on the private vehicle and encourage more active and sustainable transportation including walking and cycling. \n\nRural settlements connected to strategic transport infrastructure should be considered within the SLP as suitable locations for development. This includes settlements with good connectivity to the M5 Motorway and public transport hubs, especially train stations, as these enable faster and better connections and can promote sustainable and active travel in accordance with the draft Strategic Objectives. \n\nThe SLP should reflect the importance of accessibility to the open countryside especially in relation to unlocking opportunities for healthy lifestyles, inclusive access to sport and recreation and improvements to biodiversity, as committed to in the draft Vision. The draft Strategic Objectives are clear on the need to deliver new developments that are fully integrated with the green infrastructure network and that allow people to access nature and green spaces to maximise well-being and active travel opportunities. Consequently, it is important that the SLP supports locations where the countryside is easily accessible and is integrated within development proposals.","","No","No, it is not considered that any additional development scenarios should be considered. It is however important to note that the most appropriate strategy for the SLP area might be the delivery of a number of scenarios in tandem, e.g. new strategic settlement (4) alongside rural dispersal (5).","","The consultation document identifies potential pros and cons for the proposed six development scenarios and our comments on each of the scenarios are summarised below. \n\nScenario 1 is identified as urban concentration whereby development would be expected in Gloucester and Cheltenham at substantial densities, increased heights and through, potential conversion and rebuilding of city / town centre properties. We consider that the identified benefits of the scenario are fair however, we consider that this Scenario should be disregarded immediately on the basis of the acknowledged ‘con’ that it will not deliver sufficient new homes and jobs.’ \n\nScenario 2 is focused on urban extensions which means that development would be delivered as extensions to the existing settlements of Cheltenham and Gloucester, which could include some sites within the Green Belt. We consider that ’pros’ are a fair and accurate assessment of the scenario however given that a significant part of the SLP area is not within the Green Belt we consider that this Scenario should be disregarded and the focus of development be on land which is not within the Green Belt. The consultation document does not consider the long lead time and the significant associated infrastructure that is involved with delivering urban extensions and how the reliance of these large-scale developments can cause housing shortfalls if urban extensions are not delivered along the timelines envisaged. It is important that this is reflected as a ‘con’ of this Scenario. Furthermore, the key diagram for development scenario 2 shows that there are 3 larger-scale development options around Tewkesbury. If this scenario was chosen for the SLP, we consider that the already permitted developments east of the M5 in Ashchurch should be included as the preferred urban extension for Tewkesbury. \n\nScenario 3 focuses development at urban extensions, similar to scenario 2, however it proposes to avoid the Green Belt. We agree with the pros and cons identified for the scenario however, as with our comments regarding scenario 2, the longer lead time for urban extensions should be recognised by the SLP as a constraint to this Scenario.. \n\nScenario 4, proposes a new strategic settlement. We agree with the pros and cons identified within the SLP consultation document. If a new strategic settlement is the agreed scenario for the SLP, it is important that the new settlement is located close to an existing settlement, strategic transport connections and employment opportunities. For example, Ashchurch is the location of the Government’s Garden Town designation, the Tewkesbury Garden Town. As work developments are already being delivered in this location we consider that the SLP should continue to support the development of this part of the SLP area. \n\nScenario 5 is the option whereby growth is distributed widely across the rural area but encouraging development at existing settlements and other rural locations. We consider that the pros identified within the SLP consultation document are a fair and accurate assessment. However, we do not agree with some of the cons identified as the consultation documents assumes that most of the constraints cannot be mitigated. For example, harm on the character and setting of existing settlements can be minimised through careful and considered design. Also, the consultation document claims that this scenario would unlikely meet all housing and employment needs however this is dependent on the level of growth the SLP distributes across the area. Furthermore, the claim that this growth scenario will add pressure on existing rural services, facilities and other community infrastructure ignores the positive impact of increased infrastructure contributions on potentially stagnating settlements. Whilst the sustainability appraisal claims that development will be situated away from existing sustainable transport options, Fiddington is in close proximity of major strategic transport infrastructure including the M5 and the Ashchurch for Tewkesbury train station. \n\nScenario 6 which is focused on sustainable transport. We neither agree nor disagree with the pros and cons identified for Scenario 6 and we believe that the SLP should consider the importance of strategic transport connections including the M5 Motorway and train stations, such as Ashchurch for Tewkesbury, when identifying potential locations for growth to be delivered for this scenario.","Scenario 4: New strategic settlement; Scenario 5: Rural dispersal","","Fiddington should be included within the rural settlement hierarchy. The settlement is not within the Green Belt or the AONB and is not affected by any restrictive landscape policies illustrated on the Tewkesbury Borough Plan (2022) Proposals Map. In addition to the lack of development constraints at Fiddington it is within close proximity to a wide range of services and facilities currently available at Ashchurch. \n\nFiddington is located approx. 730km (measured at the southern boundary of Tewkesbury Garden Town) to the south of Tewkesbury Garden Town / Tewkesbury Garden Community which will deliver significant housing and employment growth, major built infrastructure such as schools, shops, services and green infrastructure such as new public open space and access to the surrounding countryside. Given the relationship (i.e. reliance on services and facilities) Fiddington already has with Ashchurch and the current development at Tewkesbury Garden Town it is entirely logical that Fiddington should be identified as a location which can support residential growth. \n\nAshchurch for Tewkesbury train station is located approx. 2.3km to the north of Fiddington and provides residents with easy access to sustainable transport modes. Junction 9 of the M5 Motorway is located approx. 2km to the north north west of Fiddington and provides easy access to the strategic highway network. The consultation document states that business leaders want to locate and invest in the area because of the good road and rail connections, therefore the SLP should promote settlements that have access to these connections, including Fiddington. \n\nThe Draft Vision set out in the SLP places great importance no interconnected green spaces and the ability to create high-quality environments for people and nature. Fiddington is set within the open countryside providing current and future residents of the settlement easy access to the countryside and the benefits this brings to an individual’s physical and mental wellbeing.","[Q.1] How far into the future should the Strategic and Local Plan cover?\n\nParagraph 22 of the NPPF (2023) requires strategic policies to “look ahead over a minimum 15-year period from adoption to anticipate and respond to long-term requirements and opportunities.” Further, the NPPF considers that where larger scale developments, such as significant extensions or new settlements, form part of the strategy, the policies should be set within a long-term vision of at least 30 years, to account for delivery timescales. In response to national planning guidance, set out in the NPPF, the SLP should cover a minimum period of 15 years from the point of adoption. It will be important to ensure that the plan period is kept under review as the preparation of the SLP progresses as any slippage in the timetable for adoption will mean that the SLP timeframe will need to be extended. Following adoption it will be important to keep the policies in the SLP under review to ensure that the SLP delivers the Vision and Objective detailed within it and that the policies remain in accordance with national planning policy\n\n[Q.8] Should the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nNo, the SLP should not require more than the mandatory minimum 10% Biodiversity Net Gain through development, \n\nParagraph 185b of the NPPF (December 2023) states that plans should ‘identify and pursue opportunities for securing measurable net gains for biodiversity’. More specifically, the 2021 Environment Act includes provision for the delivery of at least a 10% net gain in biodiversity over predevelopment levels on all sites. This came into force on 12 February 2024 for all major developments. \n\nThe importance of and requirement to provide net gains for biodiversity is therefore now clear within the 2021 Environment Act. When proposing to go beyond the national requirements, the local evidence base must provide the justification for these proposals. Indeed, recent updates to the PPG (Paragraph: 006 Reference ID: 74-006-20240214) advise that, ‘Plan-makers should not seek a higher percentage than the statutory objective of 10% biodiversity net gain, either on an area-wide basis or for specific allocations for development unless justified. To justify such policies they will need to be evidenced including as to local need for a higher percentage, local opportunities for a higher percentage and any impacts on viability for development. Consideration will also need to be given to how the policy will be implemented.’ \n\nParagraph 35 of the NPPF (December 2023) requires Local Plans to be appropriately evidenced and justified, having regard to the recent updates to the PPG, it is not clear that an evidence base document has been published to inform a potential BNG figure greater than 10%. \n\nIn the absence of this evidence, it is considered therefore that, in line with the provisions of NPPF paragraph 185b and the Environment Act 2021, the new Local Plan should support a requirement for a minimum of 10% net gain on all sites.\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nGiven the strategic nature of the SLP, and therefore the longer term Vision expressed in the SLP, the SLP should focus on a combination of development scenarios to ensure resilience and flexibility. Out of the six scenarios proposed, we consider that the SLP should focus on Scenario 4, new strategic settlement alongside Scenario 5, rural dispersal. Rural dispersal will ensure that more rural settlements in the SLP area will also benefit from investment to ensure that they can continue to thrive. A new strategic settlement will ensure that the longer-term needs of the SLP area delivered through major infrastructure investment and housing / economic development. By incorporating both scenarios, the SLP can plan for the long-term whilst ensuring that longer lead-in times do not prohibit the housing and employment needs of the SLP area being met now, when it is needed most.\n\nQuestion 31: Is there anything else you would like to raise – has anything been missed, or are \nthere any general comments you would like to make?\n\nMiller Homes is promoting 17.6 hectares at Monks Lane, Fiddington (refer to enclosed Site Location Plan). Fiddington is well-connected to strategic transport infrastructure, employment opportunities and the countryside. Tewkesbury Garden Town is located approx. 730km (measured at the southern boundary of Tewkesbury Garden Town) to the north of Fiddington and the current and planned future investment in this area make Fiddington a sustainable location for housing development. Land at Monks Lane, Fiddington is controlled by a national housebuilder with a proven track record of delivery. Miller Homes is committed to the provision of much-needed housing to assist in meeting local \nhousing need consistent with the principles of the NPPF and the draft Vision and Strategic Objectives set out in the consultation document. Furthermore, as the Council site assessment states, the Site has no constraints to development which cannot be suitably mitigated including; not being located within a flood zone and not being within a national or local landscape designation. Whilst the site is located in proximity to Grade II and II* listed buildings, the proposed scheme can easily be designed to ensure that any potential harm to the asset or setting is limited. The development of the site will respect and reflect the character of the area. The site has limited constraints and is in proximity to strategic \ninfrastructure and employment and on this basis we consider that the site is suitable for housing and should be identified as housing allocation in the SLP. "]
["Statutory/Specific Consultee","Natural England","","Local Nature Recovery Strategy\nPreparing Local Nature Recovery Strategies (LNRS) is a statutory requirement under the Environment Act 2021.The Local Plans prepared by Local Planning Authorities must be consistent with national policy, as set out in the National Planning Policy Framework (NPPF); LNRS should be used by plan-makers to inform the way they address the National Planning Policy Framework requirement for plans to protect and enhance biodiversity.\nLNRS have been designed to work closely alongside other measures in the Act including supporting the delivery of mandatory biodiversity net gain and providing a focus for a strengthened duty on all public authorities to conserve and enhance biodiversity. They will also underpin the Nature Recovery Network, alongside work to develop partnerships and to integrate nature into our incentives and land management activities.\nWhilst the Gloucestershire LNRS is currently work in progress, the SLP should be consistent with NPPF Paragraph 185 in terms of setting out local habitat priorities and identifying potential measures by which they can be achieved, alongside mapping areas that could become of particular importance in the future.\nThis is a good way of achieving nature recovery and preparing to deliver the LNRS alongside enabling the local authority and its partners to identify, map and safeguard site areas, including green and blue infrastructure opportunities and interlinkages. \nNPPF paragraph 185\nJoining up nature recovery and Green Infrastructure (GI) with health prioritiesNatural England’s People and Nature survey tells us that, for 82% of people ‘being in nature makes me happy’. With the cost-of-living crisis, ‘free’ places like local parks and greenspace, have become even more important. The value of these spaces for the economy is estimated at £28.7 billion per year.\nGreen infrastructure in towns and cities provides places to relax, exercise, and spend time outdoors; cools urban areas; reduces flooding by allowing water to permeate the ground rather than overwhelm our drains; increases biodiversity and helps to reduce inequalities in access to nature.\nOptions assessments for development sites and related green and blue Infrastructure within and between developments, green spaces and designated sites should; include soft transition and consider potential direct and indirect implications on sustainable use for example visitor pressure and transport / access options.\nMalvern Hills Site of Special Scientific Interest (SSSI)\nWe are aware that South Worcestershire Councils as part of their South Worcestershire Development Plan Review (SWDPR) have recognised that there are impacts from recreation on the Malvern Hills SSSI and that there may well be implications of further impacts for the site from new housing growth in a 25km zone of influence from the Malvern Hills SSSI. The reports presents \nvisitor survey results, details of the ecological impacts from recreation and discusses the implications in terms of access management and mitigation options. \n1. Visitor Surveys - Lake, S. et al. - 2021 - Recreation impacts on the Malvern Hills SSSI to in.pdf (footprint-ecology.org)\n2. Mitigation Strategy commissioned by SWDPR Malverns Mitigation Strategy 160822.pdf (swdevelopmentplan.org)\nThe West Midlands NE Area Team have already begun initiating conversations with affected Local Planning Authorities (LPAs) (Herefordshire Unitary Authority, Forest of Dean District Council, Tewkesbury Borough Council, Cheltenham Town Council, Gloucester City Council and South Worcestershire) that included the Cheltenham, Gloucester and Tewkesbury Councils with regard to \nthe above in order to begin to help guide them in next steps around what they may need from NE to take this forward so it can be later embedded in their emerging local plans. \nWe would thus like to again share with you our interest in supporting the Cheltenham, Gloucester and Tewkesbury Councils in joining with other LPAs who will also be affected by the Malvern Hills SSSI Zone of Influence NE would be willing to come and give a joint overview of the expectation of the work required to meet the outputs produced by Footprint Ecology to all affected LPA’s at a single collaborative LPA meeting. We now have a range of great collaborative examples from different parts of the country that all have known benefits of collaborating on strategic solutions such as this.","","Yes","We broadly support this plans vision and strategic objectives. In addition, Natural England advises that the Plan’s vision should address impacts upon, and opportunities for, the natural environment as a high priority. ‘An economy is built upon the environment’ - Economic growth and the environment - GOV.UK (www.gov.uk). It needs to clearly set out the environmental ambition and linked opportunities for the plan area. The plan should take a strategic approach to the protection and enhancement of the natural environment, including providing a net gain for biodiversity, considering opportunities to enhance and improve the quality of connectivity. Where relevant there \nshould be linkages with the Biodiversity Action Plan, Local Nature Partnership, National Park/Area of Outstanding Natural Beauty Management Plans, Rights of Way Improvement Plans and Green \nInfrastructure Strategies, Nature Recovery Network (amend as appropriate to the local area). We note that you make mention of the Climate emergency, however there is also a biodiversity emergency which must be held with equal status alongside climate change as it has the potential to contribute to addressing climate change. \nBiodiversity - our strongest natural defence against climate change | United Nations. \nThe inclusion, interaction and nature connectedness of people must also be considered as a priority in especially in terms of their wellbeing and developing love for the natural world. There should be an overarching strategy in the plan for the natural environment covering: \n• natural capital assets and ecosystem services \n• nature recovery linked to Local Nature Recovery Strategy \n• landscape, including designated landscapes \n• designated sites and local sites \n• ecological networks \n• irreplaceable habitats, priority habitats and species \n• protected species \n• impacts on invertebrates \n• geodiversity \n• soils and best and most versatile land \n• green infrastructure \n• biodiversity and wider environmental net gains \n• environmental enhancement \n• climate change adaptation","Yes","We broadly support this plans vision and strategic objectives. In addition, Natural England advises that the Plan’s vision should address impacts upon, and opportunities for, the natural environment as a high priority. ‘An economy is built upon the environment’ - Economic growth and the environment - GOV.UK (www.gov.uk). It needs to clearly set out the environmental ambition and linked opportunities for the plan area. The plan should take a strategic approach to the protection and enhancement of the natural environment, including providing a net gain for biodiversity, considering opportunities to enhance and improve the quality of connectivity. Where relevant there \nshould be linkages with the Biodiversity Action Plan, Local Nature Partnership, National Park/Area of Outstanding Natural Beauty Management Plans, Rights of Way Improvement Plans and Green \nInfrastructure Strategies, Nature Recovery Network (amend as appropriate to the local area). We note that you make mention of the Climate emergency, however there is also a biodiversity emergency which must be held with equal status alongside climate change as it has the potential to contribute to addressing climate change. \nBiodiversity - our strongest natural defence against climate change | United Nations. \nThe inclusion, interaction and nature connectedness of people must also be considered as a priority in especially in terms of their wellbeing and developing love for the natural world. There should be an overarching strategy in the plan for the natural environment covering: \n• natural capital assets and ecosystem services \n• nature recovery linked to Local Nature Recovery Strategy \n• landscape, including designated landscapes \n• designated sites and local sites \n• ecological networks \n• irreplaceable habitats, priority habitats and species \n• protected species \n• impacts on invertebrates \n• geodiversity \n• soils and best and most versatile land \n• green infrastructure \n• biodiversity and wider environmental net gains \n• environmental enhancement \n• climate change adaptation","The Plan should contain policies to mitigate and adapt to climate change impacts on the natural \nenvironment. \nThe Plan should recognise that climate change mitigation and adaptation and biodiversity loss are \ninterlinked. Many habitats provide essential ecosystem services to allow adaptation to climate change e.g. natural flood management, as well as mitigation e.g. through tree planting and retaining peat as a carbon store. Policies shouldset out appropriate nature-based solutions for climate mitigation and adaptation such as woodland or wetland creation or peatland restoration.\nPolicies should address water use, promoting the use of sustainable drainage systems (SuDS) and water sensitive design as part of a wider green infrastructure approach. In areas of known water constraint, plans should include policies to manage available resources, such as water efficiency or water reuse measures.\nConsideration also needs to be given to the likely impacts of climate change on protected sites, habitats and species.\nSee the Climate Change Adaptation Manual, Carbon Storage and Sequestration by Habitat and National biodiversity climate change vulnerability model.\nOur advice on adaptation focuses on measures to assist biodiversity to adapt, and green infrastructure measures to assist people to adapt (principally to extreme high temperature events, extreme high/low rainfall events, and for coastal areas, sea level rise and extreme storm surge events). For example, using tree planting to moderate heat island effects and SuDS to address flooding.\nNPPF paragraphs: 11(a) and 20(d) and Glossary\n7. What measures and standards should the Strategic and Local Plan introduce in respect of the:\na. Construction and operation of new buildings?\nb. Retention and reuse of existing buildings?\nThe Plan should set design standards for high quality placemaking. Local design codes or guidesshould be used to support plan policies to deliver high quality development that responds to and enhances local character and distinctiveness, incorporating nature and GI. Natural England’s GI Design Guide provides details of what good GI design looks like. The guide is linked to the ten characteristics of well-designed places set out in the National Model Design Codeand the National design guide. Landscape and townscape character assessments can also inform good design.NE encourages buildings designed to accommodate high environmental standards as described. \nWe also encourage the Plan to move towards innovative building design that incorporates more opportunities for nature within the fabric of the building. This can be as diverse as designing in opportunities for Bat roosts, Swift and House-martin nests to wall hibernacula for Newts and crevices for invertebrates.\nWe are also aware of Building with Nature, which provides a benchmark for the design and maintenance of green infrastructure in housing and commercial development.NPPF paragraphs: 127, 128","","","Yes","Yes","Carrant Brook should be recognised and safeguarded as an important green and blue corridor. Carrant Catchment Restoration Project | Farming and Wildlife Advisory Group South West Limited (fwagsw.org.uk)Carrant Brook, Tewkesbury | Flickr [Link in document]\nThe Carrant Brook is important for Severn Estuary SPA species such as lapwing. NE has produced an evidence report that looked into the SPA birds use of the wider river landscape, available online here:\nIdentification of wintering and passage roosts on functionally linked land of the Severn Estuary -Gloucestershire and Worcestershire (Phase 5) - NECR401 (naturalengland.org.uk)\nThe proposed development at Mitton and “Garden Town” will put pressure on the brook and therefore the delivery of wildlife / biodiversity net gain and natural flood risk management will be required to conserve and enhance this important green and blue corridor.","Environmental growth and nature recovery should go beyond the protection of a small proportion of our most important landscapes, biodiversity and protected sites. It should actively increase our environmental assets and make better use of nature for drainage, food growing and creating great places to be. All new development should help nature to recover, achieve biodiversity net gain and ensure that residents have access to good quality green and natural spaces and support integration. \n1. Health and wellbeing: The environment should support achievement of better quality lifestyles through the places where we live, meet and play. With nature at their heart, the design of new layouts and communities should include active, connected and healthy places to live with opportunities to grow our own food and to walk or cycle to work and local facilities. \n2. Inclusivity: All communities should benefit equally. New buildings and places must work for everyone, meaning that all ages and physical abilities are able to call plan area home and to be included in society. Developments that are comfortable, nature engaging and safe places for children will also be great places for adults. Equally, additional measures to help meet needs of those with limited movement, cognitive or sensory issues and our older community members will also help to make life easier for all residents. \n3. Resilience to climate change: Our future living environment will be impacted and influencedby climate change. The natural and built environment are resilient to change and help to reduce our carbon footprint, both in terms of the operation of the building (including heating, lighting and ventilation) as well as the fabric of the building (considering low carbon materials, construction and transportation) and the way that we access buildings and places.\nWe would encourage you to review the Cornwall County Council’s new Design Guide which takes a holistic approach and joins all these component options together. Cornwall Design GuideThere is a lot of evidence available to support the value of the natural environment having a positive impact on people’s health, see links below [links in document]:\nImproving health in cities using green infrastructure- a review Natural England’s publications on health and the natural environment\nConnection to Nature \nFirst year of results demonstrate Nature4Health boosts health and wellbeing Health, wealth and happiness: PERFECT Expert Paper\nLinks between natural environments and obesity\nLinks between natural environments and physical activity\nLinks between natural environments and physiological health\nLinks between natural environments and mental health\nNatural England is one of the partners involved in a project to test how to increase use and connectivity to green social prescribing in England to improve people’s mental health.\nIn addition, see our comments in the section Infrastructure.\nShould we allocate sites in the SLP specifically for renewable energy generation or storage?","","",""," The plan should identify suitable areas for different forms of renewable / low carbon energy. As a part of this, the plan should take account of the capacity of the natural environment to accommodate energy infrastructure. These should avoid designated landscapes and sites. Development management policies should address biodiversity and landscape impacts, including cumulative landscape and visual impacts.","","","","","","","","","","",""," We would advise that green infrastructure improvements should be part of any plans to enhance the vitality and vibrancy of the retail and town centres. There is a an opportunity to enhance and create green and blue infrastructure within the centres through retrofitting Sustainable Urban Drainage (SUDS) which can help with water management, planting trees which can provide shading and cooling -an important climate change adaptation and designing in green and blue infrastructure into redevelopment. For information on opportunities and benefits, please see below:\n• Greening the Grey: a framework for integrated green grey infrastructure. \nhttp://eprints.gla.ac.uk/150672/37/150672Full.pdf\n• Designing Blue Green Infrastructure (BGI) for water management, human health, and wellbeing: summary of evidence and principles for design.\n•https://figshare.shef.ac.uk/articles/report/Designing_Blue_Green_Infrastructure_BGI_for_water_management_human_health_and_wellbeing_summary_of_evidence_and_principles_for_design/13049510\n• Introducing England's urban forests. \nhttps://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/700468/IntroducingUrbanForest_FINAL_Sept16.pdf\n• Grey to Green- A Guide to community-led depaving projects. \nhttps://www.london.gov.uk/sites/default/files/grey_to_green_guide.pdf?utm_source=Green+Infrastructure+Partnership&utm_campaign=500c2fc4d9-EMAIL_CAMPAIGN_2017_08_31_COPY_01&utm_medium=email&utm_term=0_f4eb0dc7a3-500c2fc4d9-103374137\n• Putting economic values on green infrastructure improvements.\nhttp://publications.naturalengland.org.uk/publication/5493770651435008\n• Exploring the co-benefits of urban green infrastructure improvements for businesses and workers' wellbeing. https://www.researchgate.net/publication/318965608_Exploring_the_cobenefits_of_urban_green_infrastructure_improvements_for_businesses_and_workers%27_wellbeing\n• Public Health England- Improving access to greenspace. A new review for 2020.\nhttps://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/904439/Improving_access_to_greenspace_2020_review.pdf\n• WHO- Urban green spaces and health. http://www.euro.who.int/__data/assets/pdf_file/0005/321971/Urban-green-spaces-and-healthreview-evidence.pdf?ua=1","","","","Yes","","","","","","","In setting an overall strategy to guide development and allocate land the Plan should:\n• conserve and enhance the natural environment, including landscapes and green \ninfrastructure (GI)\n• make as much use as possible of previously developed or ‘brownfield’ land\n• allocate land with the least environmental or amenity value.\nIt should be recognised that some previously developed land is important for biodiversity as it can contain the open mosaic habitats (dataset), a priority habitat.NPPF paragraphs: 11, 32, 85, 119, 120(b)(c), 174, 175, 176, 180(a), 181, 182, 185)\nWe would advise considering improving green /natural space equality. See the following for further information: Green Space, equality, and fairness.\nYou may find it helpful to look at the Eco-towns advice worksheets which provide information ongood practice in new development in terms of sustainable development.",{"$cut":{"chars":17498,"head":"[Q.8] The Plan should identify and pursue opportunities for securing measurable net gains for biodiversity.\nThis should include setting a percentage target level of provision of at least 10% net gain, higher targets should be supported by evidence. The Plan should also set out the Biodiversity Net Gain(BNG) strategy including:\n• requirements for on-site and off-site provision\n• identifying priority opportunities of strategic significance (habitats and areas) for BNG, for instance through mapping ecological networks\n• advising on the metric to use to calculate gains, for example the most up to date version of Defra’s Biodiversity Metric.\nThe Plan should also aim to achieve wider environmental gains, going beyond BNG, to include wider natural capital benefits such as improved water and air quality and recreation. Natural England’s Environment Benefits from Nature tool can help identify opportunities.\nSome Local Authorities have chosen to set higher BNG requirements (e.g. 20% over 30+ years). However, any increased targets within policy must be evidenced (in terms of viability). Allocations within the local plan area should have (as a minimum) survey data showing biodiversity baseline & indicate whether BNG to be on or off site. It is preferrable to insist that BNG is first and foremost carried out on site (or as close to where appropriate) in order to benefit the local communities connected to the site area. Strategic significance for nature should be established through LNRS/other biodiversity strategy and articulated (given weight) in plan policy. For more information please review - Biodiversity net gain - GOV.UK (www.gov.uk) NPPF paragraphs: 174(d), 179(b), 180(d).\n\nDesignated sites\nThe Plan should include policies and proposals to protect and enhance biodiversity, including designated nature conservation sites (internationally, nationally and locally designated sites of importance for biodiversity). The direct and indirect impacts of proposed development on designated should be considered, including impacts on water quality and the impacts on air quality from increased traffic, intensive agriculture or industrial developments. \nThe Plan should identify and map local wildlife sites and include appropriate policy for their protection and enhancement, reflecting their role in the wider ecological network and for nature recovery.\nCriteria-based policies to guide development should include application of the mitigation hierarchy and how the direct, indirect and cumulative impacts of development on designated sites will be addressed.\nFurther information on designated sites is at Designated Sites View\n(https://designatedsites.naturalengland.org.uk/). Natural England’s Impact Risk Zones (IRZ) on \nMAGIC maps (www.magic.defra.gov.uk) identify potential development impacts. \nIn some Plan areas strategic mitigation solutions may exist or be desirable to address the cumulative impacts of development on designated sites e.g. recreational pressures or nutrient \nimpacts. Where this is the case further advice should be sought from Natural England and robust evidence will be needed to support any strategic approach.\nNPPF paragraphs: 175, 180(a)(b)(c), 181,182\nIrreplaceable Habitats including ancient woodland and ancient and veteran trees. The Plan should protect irreplaceable habitats (including ancient woodland and ancient and veteran \ntrees) from loss or deterioration and seek their enhancement wherever possible. Further advice can be found in Natural England’s standing advice- Ancient woodland and veteran trees: protecting \nthem from development.\nNPPF paragraph 180(c), Glossary\nPriority species and habitats The Plan should protect and enhance priority habitats and species. This should include appropriate \nprotection and restoration of deep and shallow peatlands, found in fen and bog priority habitats that \nare valuable for biodiversity and as a carbon store. Other priority habitats include upland and \nlowland heathland, traditional orchards, meadows, woodlands and coastal habitats. \nDetails can be found on the Joint Nature Conservat"}}]
["Statutory/Specific Consultee","Oakey Hatherley Parish Council","","The plan should look forward 15 to 20 years but will need regular updating. Many changes have taken place since the JCS was agreed - due to the pandemic, patterns of employment, deteriorating and underfunded public services and climate change. \n\nAlthough it is not absent from the consultation paper, we believe that the plan should focus more clearly on how we can deliver affordable homes for new households and do this in such a way that we minimise detriment to the environment that makes Cheltenham a good place to live and work. \n\nWe believe that during the last phase of significant development in Up Hatherley, we got it right. The next phase needs to follow all that good practice but improve on it by maximising sustainability and affordability.","The plan should look forward 15 to 20 years but will need regular updating. Many changes have taken place since the JCS was agreed - due to the pandemic, patterns of employment, deteriorating and underfunded public services and climate change. \n\nAlthough it is not absent from the consultation paper, we believe that the plan should focus more clearly on how we can deliver affordable homes for new households and do this in such a way that we minimise detriment to the environment that makes Cheltenham a good place to live and work. \n\nWe believe that during the last phase of significant development in Up Hatherley, we got it right. The next phase needs to follow all that good practice but improve on it by maximising sustainability and affordability.","No","In an ideal vision, there would be one hospital serving Cheltenham and Gloucester at Staverton Airfield, with good transport links including public transport.","No","We do not think the plan goes far enough in terms of meeting the challenges of climate change. More attention needs to be paid to flood protection and to ensuring that the development of new homes is carbon neutral.","We would like to see the impact on climate change minimised by building to a higher density on brownfield sites but considering carefully where residents are going to work and how they are going to access that work. \n\nWhere development takes place on greenfield sites, the prime consideration should be minimising the impact of that development, and this can only happen if there is a clear vision about access to employment and services.","We believe that the plan should wherever possible seek new uses for empty retail and business property, so mixed use development on brownfield sites at increased density will bring trade to urban areas and help our local economy. \n\nWhere development takes place on greenfield sites, the plan should take advantage of all the new technologies available for house- building, for example off-site constructed, modular, prefabricated eco homes are now being developed around the UK. Smaller and more affordable homes in the right places could meet the needs of new households and would minimise environmental impact.","We believe that the plan should wherever possible seek new uses for empty retail and business property, so mixed use development on brownfield sites at increased density will bring trade to urban areas and help our local economy. \n\nWhere development takes place on greenfield sites, the plan should take advantage of all the new technologies available for house- building, for example off-site constructed, modular, prefabricated eco homes are now being developed around the UK. Smaller and more affordable homes in the right places could meet the needs of new households and would minimise environmental impact.","","No","Success factors in development in Up Hatherley 35 years ago were a drainage and watercourse plan, the creation of a nature reserve and open and green spaces on all developments including play areas. There is also a network of safe footpaths and road crossings, enabling residents to access the surrounding countryside. The pandemic showed how valuable this was to residents.","Bus services, cycle routes, footpaths, shops, schools, GP practices, dentists, parks and play areas, community centres and libraries.","No","No comment","No","We have no expert knowledge on the basis for population estimation. In broad terms, we think the plan should deliver a range of property sizes, with the greatest emphasis placed on smaller and more affordable homes so that first time buyers are encouraged to remain in Cheltenham. At present, newly formed households can often not afford to live locally, which necessitates a commute to work. So many new developments are Retirement homes – we need more for younger households.","No","We have no expert knowledge on the basis for population estimation. In broad terms, we think the plan should deliver a range of property sizes, with the greatest emphasis placed on smaller and more affordable homes so that first time buyers are encouraged to remain in Cheltenham. At present, newly formed households can often not afford to live locally, which necessitates a commute to work. So many new developments are Retirement homes – we need more for younger households.","Yes","We have no expert knowledge on the basis for population estimation. In broad terms, we think the plan should deliver a range of property sizes, with the greatest emphasis placed on smaller and more affordable homes so that first time buyers are encouraged to remain in Cheltenham. At present, newly formed households can often not afford to live locally, which necessitates a commute to work. So many new developments are Retirement homes – we need more for younger households.","","No comments.","No comments.","There could be limited development around existing rural villages where those communities have lost local facilities as people travel to larger/cheaper shops in larger conurbations i.e. those villages are currently too small to make village shops. Post offices, primary schools, pubs etc economically viable. With relatively small-scale development in the village, such facilities may become viable thus generating additional employment opportunities as well as additional housing.","There could be limited development around existing rural villages where those communities have lost local facilities as people travel to larger/cheaper shops in larger conurbations i.e. those villages are currently too small to make village shops. Post offices, primary schools, pubs etc economically viable. With relatively small-scale development in the village, such facilities may become viable thus generating additional employment opportunities as well as additional housing.","There could be limited development around existing rural villages where those communities have lost local facilities as people travel to larger/cheaper shops in larger conurbations i.e. those villages are currently too small to make village shops. Post offices, primary schools, pubs etc economically viable. With relatively small-scale development in the village, such facilities may become viable thus generating additional employment opportunities as well as additional housing.","As stated earlier, key considerations about where to build new homes are where people are going to work and how they are going to get there. The advantage of mixed- use retail/business/residential and higher density build on brownfield sites is that it draws both workers and customers into the town.","As stated earlier, key considerations about where to build new homes are where people are going to work and how they are going to get there. The advantage of mixed- use retail/business/residential and higher density build on brownfield sites is that it draws both workers and customers into the town.","Key considerations are management of flood risk, sustainable commuting (including bus routes and services and fast broadband), schools and GP surgeries and access to green spaces and countryside. This last point is Cheltenham’s USP. Although we are not asked for site specific comments, we noted that the A46 was at capacity.","New Strategic settlements only work if there is already access to employment and services. Unless this is in an advanced state of planning, it will arrive too late for the success of the settlement. However, further developments of new settlements such as Ashchurch can, if well planned, provide a significant contribution to the 35,000 units of accommodation required.","Again, there needs to be clarity about how new residents will access work and services – so commuter routes, bus routes and services and fast broadband are key. In many locations in our county, school rolls are falling, so new families may be welcomed by schools","Yes","","We would suggest another development scenario – which is a combination of urban concentration, urban extensions, new strategic settlements, rural dispersal, and development along sustainable transport routes. In this scenario, we would also like to see the plan make use of emerging technology. Modular, off-site constructed eco homes could meet housing need in a shorter timescale and with less impact on the environment – and there are examples around the country where this technology has been used to great effect.","","In some cases, there are missing pros and cons. Urban concentration There is an additional advantage that this helps mitigate the effect of a decline in the viability of retail – a trend which the pandemic helped along – with empty (and becoming vacant) retail units not only in the town centre but also in local shopping areas and on retail parks. Mixed use development should be considered in all these locations. \n\nUrban extensions There are ADDITIONAL ‘CONS’ ON URBAN EXTENSIONS a. Difficult to provide good infrastructure, especially provide good transport, extended distances to town centres, because areas are not self-contained, and without heritage they will normally lack sense of place or community. To make matters worse, the tendency is to introduce limited public transport after many houses are already built, and that means the new residents must be already established as car commuters, and an hourly bus route isn’t going to change their habits. b. Urban extensions take away the green lung from existing communities, whilst not providing it for the new community either, as in parks, gardens, walking, open space for children, dog walking etc. Planners should not persist in thinking these difficulties can be overcome, as the problems are intrinsic to all urban extensions. \n\nNew Strategic Settlements As stated before, there is only an advantage in this approach if links to employment and services and transport infrastructure pre-exists. We are not asked to comment on any specific sites but Ashchurch would appear to be the only location where this is a possibility. \n\nRural Dispersal An additional advantage is that some village schools are at present not viable because of the lack of affordable housing in rural locations. Access to employment and services is a disadvantage, but to some extent has been mitigated by a number of jobs now being suitable for home- based working and assisted by fast broadband.","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","","No comment","Introduction\n\nUp Hatherley Parish Council have refrained from making site – specific comments about the plan but wished it to be noted that we found it unhelpful and distracting to include a map which included potential sites for development around the town.\n\nOur response to the questions posed in the consultation document is underpinned by several points which we believe should be considered in a plan which seeks to identify \nwhere homes should be built in the next 15 to 20 years. They are as follows:\n\n• The plan should not be developer led. No doubt there will be land- owners and developers keen to bring land into use. It is also tempting to develop on sites where large-scale development can take place and numbers of new homes can be built quickly, easily and profitably. This does not build successful and economically viable communities.\n• Our belief is that the plan should aim to provide homes where people want to live and where they can access employment, services, recreation, and nature.\n• When Up Hatherley expanded over 30 years ago, critical to the success of the development was that infrastructure came first and development followed. \n\nThis meant that our expanded community had a new primary school, a shopping centre, a doctor’s surgery, a community centre, and a library. \n\nPerhaps, even more critical to the success of the expansion was that a distributor road was built, with no housing directly accessed from that road. It functions well and is arguably the best of its kind in Cheltenham. Beyond that road is the green belt and it is the reason people choose to live in Up Hatherley, as they can access employment and services, but also enjoy nature.\n• In any plan about where homes are built, it is vital to consider where people are going to work and how they are going to access that work – either by car, public transport, cycle, walking or connecting to fast broadband.\n• It is a mistake to hope that infrastructure will follow, and we note that with some development, flood prevention has not been factored in, commuter routes are overwhelmed, and bus services are inadequate.\n• Lastly, another critical success factor in our local area is that almost all of our \ndevelopments have provided a mixture of dwelling types and sizes, ensuring \nthat we remain an attractive option for a range of households to call home.\n\nIn conclusion, we believe that the plan should not be developer- led. Although it is tempting to make quick gains through mass development on greenfield sites, this would result in a detriment to Cheltenham and make it an unattractive option for new households and visitors – in both cases to the detriment of our local economy. We feel that any plan for additional housing should acknowledge that the green belt which separates Cheltenham and Gloucester is not only vital to the quality of life for residents on this side of Cheltenham, but it also enables both Cheltenham and Gloucester to maintain their separate and distinct characteristics. This green belt is one of only 14 in England and is the only one which separates a town and a city, as opposed to surrounding a conurbation. Therefore, the solution we would like to see is a mixture of the development scenarios, adding new homes in urban concentrations (including retail and business zones), small scale and sustainable urban extensions, one new Strategic settlement, some rural dispersal and some development along viable transport corridors.We would also like the plan to be bold and harness the new ways of constructing homes, so that wherever possible construction is off site and homes are carbon neutral and do not degrade the landscape or overstress the local infrastructure. We would like to see the plan ensure that lessons are learned from all the best (and worse) examples of development in recent decades.\n\nHow far into the future should the Strategic and Local Plan cover?\n\nThe plan should look forward 15 to 20 years but will need regular updating. Many changes have taken place since the JCS was agreed - due to the pandemic, patterns of employment, deteriorating and underfunded public services and climate change. \n\nAlthough it is not absent from the consultation paper, we believe that the plan should focus more clearly on how we can deliver affordable homes for new households and do this in such a way that we minimise detriment to the environment that makes Cheltenham a good place to live and work. \n\nWe believe that during the last phase of significant development in Up Hatherley, we got it right. The next phase needs to follow all that good practice but improve on it by maximising sustainability and affordability.\n\nShould the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nSuccess factors in development in Up Hatherley 35 years ago were a drainage and watercourse plan, the creation of a nature reserve and open and green spaces on all developments including play areas. There is also a network of safe footpaths and road crossings, enabling residents to access the surrounding countryside. The pandemic showed how valuable this was to residents.\n\n\nShould the Strategic and Local Plan safeguard sites or routes for longer term infrastructure projects? \n\nAs stated previously, we have an effective distributor road in Up Hatherley. The same level of planning and investment needs to be made if large scale urban extensions are proposed. They won’t follow – they need to be planned before development takes place.\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nA combination of approaches would be favoured, but the overarching considerations should be infrastructure, access to employment and services, protection of the environment and mitigation of climate change."]
["Planning agent or developer","Maximus Cheltenham / Stantec","","We agree with the strategic policy topics outlined at paragraph 2.4, which appear generally consistent with the NPPF (paragraph 20).","","","The NPPF (2023) advises that the planning system should be plan-led, with succinct and up to date plans that should provide a “positive vision for the future of each area” (paragraph 15).\nIn the absence of clear government guidance on what the ‘vision’ for a local plan should look like, sources such as the Planning Advisory Service (PAS) have provided a helpful good practice\nguidance on Good Plan Making and this provides a useful reference point.\nThe PAS guidance underlines the importance of establishing a vision that is “aspirational but realistic” and looks ahead to what the area will look like in 15-20 years’ time.\nThe guidance stresses the importance of community involvement and working with other key stakeholders, including under the duty to cooperate, in developing the vision.\n\nAt paragraph 1.3 the PAS guidance recommends five elements that may be included in the\nvision. These are:\n• A direction of travel as to how the plan area will evolve.\n• The general location of where development will take place and where it will not.\n• What the nature of development activity should be in key parts of the plan area.\n• How levels and types of development will be accommodated, both within the short and\nlong term, in specific areas, such as town centres, and in the most sustainable way.\n• Reference to the wider context of the plan area, introducing the importance of links to\nand co-operation with neighbouring authorities.\nBased on these considerations we consider the ‘draft vision’ provides an appropriate outlook for\nthe joint planning area over the plan period.\nWe would however add that if there is any delay in the adoption of the JLP then the end date\nneeds to be amended accordingly so that it covers the minimum 15-year period.","","We generally support the Draft Strategic Objective identified; however, we believe there should be\na clear strategic objective to identify strategic site deliver Biodiversity Net Gain (BNG). This will\nallow developments to contribute to specifically identified off-site priority areas. This approach\nallows a landscape level solution with wider environmental benefits and contributing towards\ndelivery of other objectives of the SLP, such as recreation, green infrastructure.\nIdentifying strategic sites for off-site BNG will assist with delivery of growth targets and help to\nmaximise development in the most sustainable locations.\nWe would also recommend including a commitment to work with key stakeholders including other\npublic bodies (e.g. Environment Agency, Natural England and National Heath Service\nCommissioning Board), and where appropriate private sector utility providers, to assist the process\nof delivery on strategic planning matters.","Paragraph 4.3 of the consultation document sets out eight priorities considered necessary to meet\nthe challenges of climate change and nature recovery.\nWe agree with these priorities, particularly the delivery of development in sustainable locations and\nmaking it easier for people to move around and access services and facilities. This should mean\nprogressing a growth strategy that focuses new development either in, or on the edge of the main\nsettlements of Cheltenham, Gloucester and Tewkesbury. This would ensure a sustainable pattern\nof development and would be entirely consistent with paragraphs 108 and 109 of the NPPF (2023).\n\nIn our view development on the edge of Cheltenham, in location such as land south of Up Hatherley\nWay, as identified at Appendix 1, would represent the most sustainable growth scenario and\ncontribute towards delivering growth that maximises opportunities for sustainable transport.\nUp Hatherley Way already benefits from regular bus services providing access to Cheltenham town\ncentre and therefore the public transport infrastructure is in place to serve a sustainable urban\nextension on the land identified on the Site Location Plan that accompanies these representations.\nThis site is also accessible to an established District Centre providing access to convenience retail,\nand other day to day community facilities.\nMaximus Cheltenham Ltd will be working with other landowners to promote a comprehensive\nsustainable urban extension and would welcome the opportunity to discuss their proposals with\nPolicy Officers as the new JLP progresses.","It is clear the government is committed to improving the energy efficiency and reducing the carbon\nemissions of new homes and non-domestic buildings through changes to Building Regulations.\nPlanning authorities should have regard to other legislation in exercising their functions. We\nconsider that Buildings Regulations is now the appropriate tool to deal with the construction of new\nbuildings and there is limited justification for exceeding these minimum standards without clear\nevidence to do so, including viability testing.\nParagraph 158 of the NPPF advises that plans should take a “proactive approach to mitigation and\nadapting to climate change, taking into account the long-term implications for flood risk, coastal\nchange, water supply, biodiversity and landscapes, and the risk of overheating from rising\ntemperatures”. It goes on to state that new development should be planned in way that “can help\nto reduce greenhouse emissions, such as through its location, orientation and design. Any local\nrequirements for the sustainability of buildings should reflect the Government’s policy for national\ntechnical standards”. It is evident that the NPPF requires the planning system to address issues\nrelating to climate change through careful land use planning and design. We would support policy\nwhich seeks to reflect these objectives.","It is clear the government is committed to improving the energy efficiency and reducing the carbon\nemissions of new homes and non-domestic buildings through changes to Building Regulations.\nPlanning authorities should have regard to other legislation in exercising their functions. We\nconsider that Buildings Regulations is now the appropriate tool to deal with the construction of new\nbuildings and there is limited justification for exceeding these minimum standards without clear\nevidence to do so, including viability testing.\nParagraph 158 of the NPPF advises that plans should take a “proactive approach to mitigation and\nadapting to climate change, taking into account the long-term implications for flood risk, coastal\nchange, water supply, biodiversity and landscapes, and the risk of overheating from rising\ntemperatures”. It goes on to state that new development should be planned in way that “can help\nto reduce greenhouse emissions, such as through its location, orientation and design. Any local\nrequirements for the sustainability of buildings should reflect the Government’s policy for national\ntechnical standards”. It is evident that the NPPF requires the planning system to address issues\nrelating to climate change through careful land use planning and design. We would support policy\nwhich seeks to reflect these objectives.","","","As discussed previously, in order to ensure that net gain targets can be met across the joint planning\narea the Council’s should identify specific sites for the delivery of off-site BNG. This not only acts\nas a safeguard that ensures BNG targets are achieved but creates the opportunity for a more\ncohesive and efficient approach to the delivery of new habitats to be adopted. Not all sites have\nthe capacity to achieve a net gain of 10% and limiting development to sites that are capable of doing\nso. Smaller sites, or those in urban areas, in particular may find it difficult to achieve a net gain, so\nthe identification of strategic priority areas should be a priority.","","Yes","In order to meet the strategic objectives identified in the draft JLP, we consider that broad areas\nsuitable for renewable energy generation, or battery storage should be identified.","","Paragraph 61 of the NPPF advises that the standard method should be used as an advisory starting\npoint to establish the housing requirement for the area. On this basis this method is consistent\nwith government policy. However, the standard method is the minimum requirement and local\nauthorities are able to set higher growth targets if they assist with economic growth ambitions, or\nif they assist with affordability issues.","","There are various designations affecting the joint planning authority area, however the impact on\nthese designations can be assessed or reviewed through the local plan process. This includes Green\nBelt boundaries.\nParagraph 147 of the NPPF states that when drawing up or reviewing Green Belt boundaries, the\nneed to promote sustainable patterns of development should be taken into account. It goes on to\nstate:\n“Strategic policy- making authorities should consider the consequences for sustainable development\nof channelling development towards urban areas inside the Green Belt boundary,\ntowards towns and villages inset within the Green Belt or towards locations beyond\nthe outer Green Belt boundary.”\nIn assessing potential ‘Development Scenarios’, the joint authorities should take a ‘policy-off’\napproach to green belt and assess the most sustainable options for delivering growth. A green\nbelt review should also be carried out to consider the potential for amendments to the green belt\nin locations such as land south of Up Hatherley Way, Cheltenham.","","","","","","","","","","","","","","","","","No","We do not consider the Pros and Cons relating to Scenario 4 to be fair and accurate. There is no\nmention of the potential impact on the landscape character of new settlements (around 4,000 new\ndwellings) in the open countryside.\nThe Sustainability Appraisal (SA) (2023) states:\n“Although there may be some scope within larger-scale developments to reduce the impact on the\nwider landscape and important views, S4 could potentially have a minor negative impact on the\nlandscape overall, although opportunities for some avoiding more sensitive areas are also\nacknowledged.” (emphasis added)\nIt is difficult to conceive how the introduction of a new settlement of around 4,000 new dwellings\ncan only be considered to have a ‘minor negative impact’. It is likely to have a significant urbanising\neffect likely to have an adverse effect on the landscape character of the area.\nWhilst a new settlement may have its benefits, a ‘minor negative impact’ impact on the landscape\nis not considered a reasonable or accurate assessment of the impacts.","Scenario 2: Urban extensions","","","[Q1]\tParagraph 22 of the NPPF advises that strategic policies should look ahead a minimum of 15 years\nfrom adoption.\nWe note that the Issues and Options consultation document assumes the draft Strategic and Local\nPlan (SLP) will be submitted to the Secretary of Statement for examination in April 2026. It is likely\nadoption would be in 2027 based on this assumption. This would mean the plan period would need\nto extend to 2042 as a minimum.\nHowever, the proposed housing requirement set out in the Table showing annual local housing\nneed for each Council (at paragraph 5.16) of the Issues and Options consultation document\nproposes a requirement spanning a 20-year period. This local need figure is based on the\nGloucestershire Local Housing Needs Assessment (2019) which assess needs from 2021 to 2041.\nThis evidence should be updated prior to the submission of the SLP to the Secretary of State. The\nbase date for the plan period should reflect latest evidence available and covers a 20-year period.\n\n[Q8] Any requirements above the mandatory 10% would need to be viability tested and the BNG target\nchecked against other policies in the plan. It is likely that increasing the minimum requirement\nwill impact on the delivery of other planning obligations, including affordable housing.\n\n[Q29] We consider Development Scenario 2 to be the most sustainable, and consistent with the ‘Strategic Objectives’ identified in the draft JLP consultation document.\nIn particular we believe that a sustainable urban extension to the south of Up Hatherley Way,\nCheltenham, as identified at Appendix 1, would provide an opportunity to provide new homes\nwhere services and facilities, including community facilities, can be accessed by different types of\ntransport, including public transport, walking and cycling, and in a location that would not result in\nan unacceptable conflict with the five purposes of the green belt."]
["","",15,"I think that the type of housing should also be considered","","No","Talking about attracting people because of the lifestyle when the councils are allowing and encouraging destroying the very things which constitute this lifestyle is almost funny","No","we need to look at producing appropriate housing ,protecting the environment not just paying lip service with “green spaces”","The sensible thing would be to stop building on flood plains ","One stop developers building massive “detached” houses which are separated by a few inches to cram as many in as possible. Build new houses for young families or singles which are more compact. Also look at creating decent houses for those who want to downsize not the pokey rabbit hutches on offer. House blocking is becoming a thing people hang on to the family homes after children have left because the smaller houses designed for them have no decent living space","","Yes","","Not specifically but areas around Tewkesbury and Maisemore spring to mind. Any land currently classed  as agricultural should be ring fenced for food production and help given to allotments to keep them in place. Wildlife corridors should be mandatory to encourage biodiversity","Schools and Doctors. And they should be in the first stage of any build. The developers should have these ready before the houses are complete ","No","","No","I feel that the figures quoted in the document seem very high. I can’t see why anyone would move here as there are currently no major business opportunities. Most of the old companies are still off shoring","Yes","Yes I think the number should be reduced but that the type of housing should be looked at more carefully","Yes","Currently the area has a good stock of housing for middle sized families but there seems to be a lack of smaller houses for singles also there is a dearth of attractive housing for those whose children have grown and therefore they remain in the family home blocking the next generation. Much has been said about attracting young people to the area to encourage businesses  to move here but there are no places they can afford either to rent or buy","","I think you would need to ask the travellers and the residents if they would be happy with this idea.  I feel that if you asked a developer the answer would be no","","","Accommodation to be able to attract the staff. Good reliable transport links. Parking ","Accommodation to be able to attract the staff. Good reliable transport links. Parking ","Reliable public Transport to get people in and out including night time. Spend a bit of money to tidy up the place so it becomes more attractive. Give new businesses a reduced rate for a year","Maybe give grants to help set up and maintain. Maybe help them link up for support","Schools Surgeries Transport links","Schools surgeries community hubs public transport","How much extra capacity is available in the schools. How the existing roads would cope. Surgery capacity ","Yes","","","","","Scenario 1: Urban concentration","","","[Q11] It would be good if we could but it may not be possible. New houses could have solar panels installed and a grant offered for existing houses who are suitable\n\n[Q28] For me I would suggest regeneration of exisitng urban sites should be the priortiy\n\n[Q.31] I am very worried about the expectation of the number of people expected to arrive in this area. There seems to be little included here to support them in a day to day living. There is no point just building houses to make developers large profits the people need schools surgeries access transport and work"]
["Planning agent or developer","Grundon Waste Management Ltd","","","","Yes","Grundon fully agrees with the draft Vision for the plan. The concept of Green Growth, focused on carbon reduction and addressing the causes and impacts of climate change, strongly resonates with our company's mission. We actively support the principles of a circular economy and prioritize the well-being of both communities and our employees.\nWhile we fully support addressing housing needs, we suggest that any new housing allocation sites be situated at a distance from our operational site (e.g. at least 250m of our site boundary). This adjustment would contribute to a more sustainable and suitable environment and comply with the guidelines for compatible land use.","Yes","We support growth that aligns with decarbonisation efforts, aiming to reduce reliance on fossil fuels and striving for zero and low carbon emissions.\nIn terms of changes, we suggest ensuring that the objectives explicitly support the development of low and zero-carbon energy, including maximising renewable energy opportunities. It's worth highlighting that waste management facilities can effectively contribute to these objectives as well. Additionally, we recommend clarifying how development plans will incorporate measures to reduce waste.","When considering how the SLP can effectively address the impacts of climate change, Grundon advocates for the transition to a low carbon future. This involves shaping our \ncommunities to significantly reduce greenhouse gas emissions, while also bolstering resilience to climate-related challenges and safeguarding crucial habitats and biodiversity.\nAlthough situated on the northern edge of the Greenbelt, our site is dedicated to curbing greenhouse gas emissions and operating sustainably. Currently, it plays a pivotal role in managing residual waste from Tewkesbury and Cheltenham Borough Councils, as well as a diverse array of waste from Gloucestershire County Council Supporting sustainable waste management facilities, like ours, that are committed to adopting environmentally friendly methods and technologies is crucial. By prioritising innovation and engineering, the waste industry can effectively mitigate the impacts of climate change, in line with the objectives outlined in the SLP.","","","","","","","Yes","In response to whether sites should be allocated in the SLP for renewable energy generation \nor storage, Grundon fully supports such allocation. We actively seek out opportunities for \nrenewable energy generation, focusing on landfill gas and solar power, alongside plans for a \nhydrogen generating infrastructure on our site.\nOur commitment to sustainability is evident in our use of electric vehicles, for both our waste \nmanagement fleet and for our employees, to reduce carbon emissions and support a greener \nenvironment. Looking ahead, we plan to enhance our site's sustainability by potentially \ninstalling solar panels on the landfill areas after operations cease while maximising the \nbrownfield land use and supporting biodiversity growth.\nIt's crucial for the Plan to acknowledge the potential for waste management facilities, like \nours, located on greenbelt areas to be repurposed for renewable energy generation in the \nfuture.\nAllocating sites for renewable generation or storage at Grundon's operational site would \nenable us to harness electricity from various sources - landfill gas, solar power, and hydrogen \ngeneration – onsite use and/or export it to the grid. This would facilitate continuous energy \nproduction and usage at our site, both during the day and at night and potentially provide the \ngreen energy hub for the local community.\nThe WFE has a significant existing electrical export connection (1.2MW at present), and it is \nestimated that it could in addition deliver c. 10MW of solar generation. The entire site\ntherefore could become a centre for renewable energy in Gloucestershire.","","","","","","","","","","In supporting businesses to invest, expand, and adapt, SLP should address various economic \nand regeneration needs. Grundon fully endorses the vision for enhancing employment \nopportunities while facilitating the count\nThe SLP must delineate a clear roadmap aimed at fostering the growth and expansion of \nexisting businesses. It should intricately outline the support mechanisms available to them as \nthey navigate the transition towards a low carbon economy and strive to achieve carbon net \nzero targets. This concerted effort aligns seamlessly with the Plan's overarching vision of \npromoting sustainable green growth.\nTo help existing waste management sites, such as ours, to function most effectively, it is \ncrucial that the SLP safeguards the existing waste facilities by bringing the 250m buffer zones \ninto policy wording. This would ensure future uses do not prejudice the ability of safeguarded \nsites to operate. The new developments should demonstrate how both current and future \nuses of the strategic waste sites have been considered in offering mitigation to future \noccupants, i.e. the onus should be on the new development, not the existing waste site \noperator.","","","","","In addressing the types of infrastructure critical to accompany new development, \nsafeguarding existing waste management facilities emerges as a priority. Ensuring the \ncontinuity of these facilities is imperative, as confirmed through consultations with the waste \ndepartment of Gloucestershire County Council.\nThe significance of these facilities cannot be understated. While the landfill use will eventually \nend it is imperative to remember that such areas continue to produce landfill gas and leachate \nthat must be appropriately managed for many years following the landfill closer. \nFurthermore, it is essential to maintain waste management sites operations, such as ours, in \na sustainable manner at their current location, rather than relocating them.","","","","","","","","","","","We extend our sincerest apologies for the delay in submitting this letter, acknowledging that it arrived \nafter the designated deadline. Despite this delay, we kindly request your understanding and \nindulgence in considering and reviewing the enclosed comments. Your understanding in this matter \nwould be greatly valued and appreciated.\nIntroduction\nThis letter provides the representative on behalf of Grundon Waste Management Limited (GWM) to \nthe consultation on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (SLP) Issues \nand Options document. \nThe SLP will cover the areas of Cheltenham Borough Council, Gloucester City Council and Tewkesbury \nBorough Council. It will contain strategic policies which are used in decisions on planning applications. \nAs outlined in Paragraph 2.2 of the consultation document, the plan and strategic policies will:\n“• Set a clear vision, strategy and polices for how the area will grow, providing clarity for what \ndevelopment will and will not be acceptable.\n• Set out requirements for the delivery of new homes, jobs and infrastructure to meet the needs \nof the community and the local economy in a way that is sustainable and addresses our \ncommitments to climate change.\n• Provide a framework for Neighbourhood Plans, which can be developed by communities.”\nAs stated at paragraph 2.9, “At this early stage, preferred development sites have not been identified; \nthis is for a later stage in the process. Sites promoted to the councils to date including by landowners, \nagents and the wider community are presented in the background evidence. However, for the purposes \nof this consultation we are only exploring the overall merits of different broad locations where we \nmight consider promoting development. Some sites are large enough to justify a longer period if they \nwere to be chosen but the longer the timeframe of the Plan then the greater the need for infrastructure \nthat will need to support them”.\nSLP Consultation Letter\nMarch 2024 2\nIt is acknowledged that the current timetable for the submission of the SLP to the Secretary of State \nfor Examination in 2026, followed by adoption by the councils at a later date. Therefore, the SLP would \nneed to plan up to at least 2041. \nWe understand that this consultation serves as the first step in shaping the SLP, inviting input to \ndetermine its scope. While it includes specific questions to guide feedback, stakeholders and the \ncommunity are encouraged to raise any additional issues, concerns, or opportunities not covered. The \ninsights gathered will inform the drafting of the SLP, ensuring it reflects the collective perspectives.\nThis representation letter is to share our company's viewpoints and comments on the SLP Issues and \nOptions Consultation Document. We appreciate the opportunity to contribute our insights to help \nguide the development of this important document.\nAbout Grundon\nGrundon Waste Management is one of the UK’s leading suppliers of integrated waste management \nsolutions. Operating from sites across the south of England, Grundon’s nonhazardous waste \nmanagement operations include recycling collections, waste removal services, waste disposal \nservices, special events services and contract management. Hazardous waste management services \ninclude contaminated waste, clinical / medical waste disposal and the collection and treatment of \nwaste electrical and electronic equipment. In addition, Grundon also have expertise in respect of the \nextraction, processing and supply of minerals and the restoration of mineral sites.\nGrundon was founded in 1929 and is the largest privately owned waste management group in the UK.\nGrundon have been commended by local county councillors for fostering good relationships with local \nstakeholders through undertaking meaningful engagement and pride themselves on operating their \nsites to the highest standards.\nWingmoor Farm East Site at Bishops Cleeve\nGrundon is the owner and the site operator at Wingmoor Farm East (WFE) Integrated Waste \nManagement Facility (IWM) located within the administrative areas of the Parish of Bishop’s Cleeve, \nthe Borough of Tewkesbury and the County of Gloucestershire. The site, that have been operated for \nthe past 60 years, falls within ‘The Strategic Local Plan area’ identify in the SLP document. \nThe Site comprise hazardous and non-hazardous landfills, clay extraction, a hazardous waste \ntreatment plant, materials recovery facility & waste transfer station and an anaerobic digestion plant \n(operated by a third party) and covers an area of approximately 78 hectares.\nThe wider WFE is allocated as one of five strategic waste management sites in Gloucestershire. The \nSite delivers a valuable waste management service to Gloucestershire by contributing to the recycling \nand recovery of waste materials, in accordance with the waste hierarchy.\nThank you for your attention to our company's views on the Cheltenham, Gloucester, and Tewkesbury \nSLP Issues and Options document. We appreciate the opportunity to contribute to the consultation \nprocess and trust that our comments will be carefully considered in the development of the SLP. \nWe look forward to seeing the positive outcomes of this collaborative effort in shaping the future of \nour community"]
["","National Highways","","","","","Broadly National Highways is supportive of the draft Vision, with a focus on active and sustainable travel in line with the principles within NPPF and DfT Circular 01/2022. We would welcome recognition of the delivery of ‘safety’ within the transport element of the vision for the plan.","","We welcome the four specific points identified under a draft strategic objective: “Prioritising sustainable transport and active travel.” A focus on managing down demand for travel in the first instance then promoting sustainable and active travel is a sustainable approach and supported by National Highways. Generally, we recommend consideration of whether SLP aspirations should be identified in a more quantifiable and measurable way – to focus thoughts regarding delivery and ensure aspirations are achievable. This would then inform a ‘vision-led’ approach to transport in the SLP.","We note that ‘Movement’ is one of the four categories of measures being considered for addressing climate change through the development of the SLP. National Highways, like the SLP authorities, has made commitments to reduce our carbon impacts. Wherever possible, we support plans to replace vehicular journeys with active travel modes. However, it is important to stress that our licence with DfT requires us to focus on the safe and effective operation of the SRN and this cannot be compromised for sustainable travel initiatives. The cumulative assessment of proposed sites will be critical to ascertaining what the impact of the SLP will be on the SRN and what sustainable transport infrastructure could be delivered to minimise any climate change impacts associated with new development, while safety is ensured. Whilst the proximity of jobs, shops and services are listed as a measure for consideration, thought should be given to providing mixed use developments where possible to ensure that demand for travel is managed down so that people have the choice of accessing services and other forms of development close to home where possible.","","","","","","","","","","","","New homes The consultation states that according to the Government’s standard housing need methodology, the current housing need is: \n\nCouncil Area \t\tAnnual need for new homes 20 year need for new homes\nCheltenham Borough \t547\t\t\t\t 10,940\nGloucester City\t 681 \t\t\t\t13,620\nTewkesbury Borough \t557 \t\t\t\t11,140\nTOTAL\t\t\t 1,785 \t\t\t\t35,700\n\nTo deliver this level of required growth we invite early discussion regarding emerging sites being considered for allocation within the SLP, with particular consideration to any sites impacting on the SRN. Implication of allocations will need to be identified and mitigation tested through a robust transport evidence base. To avoid abortive work, we suggest that the scope of the transport evidence base is developed in conjunction with National Highways input.","","","","","","Whilst the consultation provides an indicative quantum of employment need for different types, it recognises this work will be updated as the SLP progresses. This is to address the fact that evidence to inform the plan was prepared in advance of Brexit and Covid-19 impacts being understood. We welcome this review due to significant changes in travel patterns in some locations and for some uses following these events. Updated employment assumptions for the SLP are required to feed into the assumptions for the transport evidence base being developed. Paragraph 5.36 references that economic growth is focussed on the M5 corridor due to the high connectivity it benefits from. It also acknowledges that the M5 corridor within the SLP area experiences high congestion and delay during peak periods associated with high demand on the SRN, with the aspiration to transfer trips to rail, specifically the Birmingham to Bristol rail link. While access to the M5 may be attractive for new employment growth, if travel impacts from proposed growth cannot be mitigated, the reliability of the network could become a potential constraint, affecting both the prosperity of the new sites, but also importantly, the existing productivity of the whole area. As above, evidence needs to be developed to ensure the impact of proposed growth on the SRN is understood, with mitigation plans in place to ensure growth is sustainable.","","","","","National Highways welcome the commitment in paragraph 5.50 that infrastructure needs, including transport, will be considered within the SLP area to ensure that the appropriate measures are provided to support growth within the area. We agree that further evidence is required to ascertain the form of mitigation and when it is required to be delivered, both crucial to delivering a sound plan. We have provided advice regarding necessary evidence to inform this workstream in the ‘SLP Transport Evidence’ section above.","","","","","",""," Scenario 1: Urban concentration – increased densities\nWe note that one of the ‘cons’ associated with this option is increased journey length and economic growth diverted to locations outside the SLP area. We request that careful consideration is given to any sites selected within this scenario to ensure that an appropriate number of mixed uses are delivered to meet the needs of residents and employees to reduce out-commuting. This would result in reduced demand on the SRN and would ensure that sustainable growth is delivered within the SLP area. \nScenario 2: Urban extensions - urban extensions to the key urban areas of Cheltenham, Gloucester and Tewkesbury Town\nWe support managing down demand through this spatial scenario by the provision of services/mixed uses close to the need and the subsequent reduction in travel in line with NPPF principles. This will provide an opportunity to support the safe and efficient operation of the SRN through effective spatial planning. We understand that within this scenario a Mass Rapid Transit scheme is proposed as originally discussed within Gloucestershire County Council’s Local Transport Plan. If this option is included within the emerging SLP, we would expect to see the scheme listed within the IDP and modelled within the supporting evidence base. Funding sources and the scheme promoter should also be detailed to ensure that the Local Plan is deliverable and sound.\nScenario 3: Urban extensions, avoiding the Green Belt\nComments relating to Scenario 2 remain valid in this case too, however the transport related ‘con’ identified for this scenario is ‘increased journey lengths as housing and economic growth are diverted to alternative locations outside of the SLP area’. If journey times and out-commuting increase within this scenario, they are therefore dependent upon site allocations that do not offer the highest uptake of sustainable travel. If sustainable travel becomes unattractive due to long journey times, this may result in an increased demand on the SRN and a higher impact in terms of safety and capacity.\nScenario 4: New strategic settlement\nThis scenario proposes a minimum of around 4,000 new homes at one or more sites. Three potential locations have been put forward by site promoters:\n1. Around Boddington on land to the south of the A4019 between the A38 and M5 corridors; \n2. Between Tewkesbury Borough and the Forest of Dean between Churcham and Highnam in the southwest of the SLP area; and \n3. East of the M5 at Ashchurch on the edge of the built-up area of Tewkesbury. This is known as ‘Tewkesbury Garden Town.’ \nParagraph 6.26 identifies National Highways involvement alongside Gloucestershire County Council in relation to emerging proposals for major improvements to M5 Junction 9 and the A46 in association with Option 3 ‘Tewkesbury Garden Town’. This workstream is ongoing. Any new community proposal secured in policy through the SLP will need to be assessed for transport implication considering SRN impacts, with appropriate mitigation identified. Funding and delivery partner consideration is also needed to ensure sites are deliverable. \nScenario 5: Rural dispersal\nThe increased journey lengths and no/low levels of public transport being provided in this scenario are likely to result in a high increase in demand on the SRN and out-commuting. This could result in impacts on the safe and efficient operation of the SRN and therefore may result in a need for improvements on the SRN. A cumulative assessment of the local plan site allocations should be provided to ensure impacts are understood across the plan area and immediate neighbouring authorities. \nScenario 6: Sustainable transport scenario - delivering development in locations along existing and potential high frequency public transport, walking and cycling routes. This scenario is illustrated to focus growth on Cheltenham and Gloucester and along the railway line between. While this scenario could provide increased sustainable travel facilities for urban/suburban areas, it notes that rural areas may not benefit from these resources. M5 Junction 10 and 9 would also face these sites and offer residents vehicular alternatives. This could result in a higher demand on the SRN in these areas.","","","","Draft Site Assessment Methodology (Housing and Economic Land Availability Assessment, 2023)  \nThank you for providing National Highways with the opportunity to comment on the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (SLP) Regulation 18 Consultation and Draft Site Assessment Methodology. As you will be aware National Highways are responsible for operating, maintaining and improving the strategic road network (SRN), which in the Plan area comprises the M5 motorway Junctions 9 – 11a, A40, A46 and A417 trunk roads. The purpose of the SRN, which is a critical national infrastructure asset, is to provide a safe, free-flowing and reliable highway network for strategic movements to support economic growth. It is based on these responsibilities that our comments are made. \nNational Highways and the Plan Making Process \nNational Highways expects transport and land use planning policy to be closely integrated. In this respect, we draw your attention to DfT Circular 01/2022. This document sets out how we engage with the planning system and how, in the context of the SRN, sustainable development should be achieved through planning. National Highways recognises that prosperity depends on our roads, so aims to support growth and facilitate development based on an understanding of traffic conditions and behaviour, to manage the effects of development and ensure road safety. To constructively engage in the Local Plan making process we require a robust evidence base so that sound advice can be given to Local Planning Authorities on the appropriateness of proposed development in relation to the SRN. This also extends to include the identification of transport solutions that may be required to mitigate adverse impact on the SRN and support the delivery of sustainable growth across the plan area. \nSRN Status and Schemes within Cheltenham, Gloucester and Tewkesbury\nWithin the Cheltenham, Gloucester and Tewkesbury area the M5 can experience congestion and seasonal delays. There are significant development pressures across the SLP area, with need for 2 Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ National Highways Limited registered in England and Wales number 09346363 mitigation already identified at M5 Junction 10 and M5 Junction 9 (including the A46). Constraints are also present on the A417, with works underway by National Highways. Cheltenham Borough, Tewkesbury Borough and Gloucester City Councils (SLP authorities) adopted a Joint Core Strategy (JCS) in 2017. This proposed strategic housing and employment sites close to M5 Junction 10, including the West and North-West Cheltenham developments. The JCS mitigation for these sites identifies the need for strategic scale improvements at M5 Junction 10, with a new road linking Junction 10 to West Cheltenham and widening of the A4019 Tewkesbury Road. Gloucestershire County Council is leading on these works. Consent for the scheme is to be secured by a Development Consent Order (DCO). The DCO was accepted by the Planning Inspectorate on behalf of the Secretary of State in January 2024, with the examination planned for May this year, so is currently at pre examination stage. Tewkesbury was awarded Garden Town Status by MHCLG in 2019, with aspirations to deliver around 10,000 homes and employment at Ashchurch, accessed off the A46 which links to M5 Junction 9. Additional road and junction capacity has been identified as required to deliver the Garden Town. Gloucestershire County Council, with input from National Highways, is looking at scheme options. The M5 Junction 9 and A46 improvements are anticipated to include a new or reconfigured M5 junction and re-routing of the existing A46 around Ashchurch. Overall, the planning merits and suitability of potential allocation of the proposed Tewkesbury Garden Town needs to be determined through the SLP. The SLP supporting transport evidence should interpret impacts and mitigation required to support allocations within the plan. The A417 / A419 is an important connection between the M4 and Swindon to Gloucester, Cheltenham and the Midlands. A major improvement on the A417, termed ‘the Missing Link’ is currently under construction by National Highways, involving dualling of a three mile stretch of single-lane carriage way between the Brockworth Bypass and Cowley Roundabout. The objectives of the A417 Missing Link scheme include reducing delays and improving safety at this location. The A40 forms part of the SRN, passing north of Gloucester and joining the M5 at Junction 11. At present there are no proposed improvements for this stretch of the network. Impacts from the SLP will need to be considered for this part of the network too.\nJoint Working and Cross Boundary Implications \nIt is stated that the SLP authorities are seeking Submission of the SLP by April 2026. National Highways has had limited engagement with the SLP authorities in Local Plan development discussions to date. We are keen to engage, to ensure a robust transport evidence is developed, and any identified SRN impacts requiring mitigation are appropriately captured in policy and infrastructure plans. National Highways attend focused meetings regarding emerging junction improvement and development proposals around Tewkesbury impacting on the M5 Junction 9 and A46, these do not cover wider SLP matters. In meetings with the SLP authorities we have discussed the current performance of the SRN within and just outside the authority boundaries. This includes existing areas experiencing congestion and junctions operating at/close to capacity. National Highways consider that any development adding trips to the network, which result in mainline queuing, extends a mainline queue, and/or increases the frequency at which a mainline queue occurs will have an unacceptable safety impact on the SRN (due to the increased risk of vehicle accidents on the mainline), in accordance with paragraph 115 of the National Planning Policy Framework (NPPF). Surrounding the SLP, local plans are emerging in neighbouring authorities. The growth proposed in these plans will cumulatively likely exceed the current SRN capacity, which is particularly constrained 3 Registered office Bridge House, 1 Walnut Tree Close, Guildford GU1 4LZ National Highways Limited registered in England and Wales number 09346363 on sections of the M5 within the SLP authorities. To ensure cumulative impacts are addressed we request joint working on the emerging local plans, to support the delivery of sustainable growth.\nSLP Transport Evidence\nIn accordance with the NPPF all plans and policies should be underpinned by relevant and up-to-date evidence. This should include a comprehensive transport strategy which identifies highway and transport infrastructure necessary to deliver the plan (to be reflected in the IDP) and address any severe and/or unacceptable safety impacts on the SRN. DfT Circular 01/2022 requires the following (paragraph 29): “New connections and capacity enhancements to the SRN which are necessary to deliver strategic growth should be identified as part of the plan-making process, as this provides the best opportunity to consider the cumulative impacts of development (including planned growth in adjoining authorities) and to identify appropriate mechanisms for the delivery of strategic highway infrastructure”. Paragraph 34 of the DfT Circular 01/2022 also states that National Highways engagement in the plan making process should inform infrastructure needs and help to demonstrate the deliverability of the plan: “The company’s engagement with plan-making will help inform the preparation of the local authority infrastructure delivery evidence base. From a transport perspective, this evidence should provide a means of demonstrating to the examining inspector, development industry and local communities that planned growth is deliverable, and that the funding, partners and relevant processes are in place to enable the delivery of infrastructure; or that there is a realistic prospect that longer term investment can be secured within the timescales envisaged”. We anticipate evidence work to include demand forecasting models which tests a core scenario, with supporting analysis of alternatives by accounting for the effects of possible mitigation scenarios that shift demand into less carbon intensive forms of travel. This should set out and deliver a transport ‘vision’ for the plan and explore all options to reduce a reliance of the SRN for local journeys, including a reduction in the need to travel and maximising opportunities for active modes. Transport needs of the SLP need to be analysed alongside existing development proposals, with consideration where necessary of improvements over and above mitigation already planned/delivered. The SRN network needing to be considered within the SLP evidence includes M5 motorway Junctions 9 – 11a, A40, A46 and A417 trunk roads. Where impacts are identified on the SRN operational assessments of components of the network will be required, to identify and test mitigation measures. We anticipate discussing the scope of such work as the SLP develops. Any necessary infrastructure improvements will need to be included within a supporting Infrastructure Delivery Plan (IDP) and clearly signposted in plan policy, setting out what infrastructure is required and when. National Highways look forward to continued engagement with the SLP authorities in respect of the transport evidence base necessary to support the SLP, together with the identification of any mitigation required to ensure the impact of the plan on the SRN can be safely accommodated. As highlighted above, when developing evidence regarding the SRN within the SLP plan area, proposals should be considered cumulatively with other neighbouring emerging planning documents. National Highways welcomes continued engagement with the SLP authorities and Gloucestershire County Council (as Local Highway Authority) regarding the development of the transport evidence base required to support the SLP. Where possible, National Highways will seek to provide access to existing data and models to support this process.\n\nSLP SUPPORTING EVIDENCE AND DOCUMENTS \nSustainability Appraisal (December 2023) \nWithin the Sustainability Appraisal of the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan Regulation 18 we note that section 4.13 considers the transport impacts of each spatial strategy scenario on transport and accessibility. Summarised as: - Scenario 1 and Scenario 6 offer increased opportunities for travel by means other than private car - Scenario 4 offers minor to major positive effects depending on location and design - The outcomes of Scenario 2 and 3 are considered uncertain - Scenario 5 has a negative effect \nBroadly we agree with this initial analysis – and envisage the Sustainability Appraisal will be informed by further transport evidence to appropriately assess the chosen spatial strategy for the SLP. \nGloucestershire SLP Authorities Sustainable Transport Strategy – Broad Site Assessment Report (December 2023) \nThis document is produced by City Science, who were previously engaged in developing transport evidence for the emerging CGT Joint Core Strategy, with plans to produce a Sustainable Transport Strategy for development proposals. This workstream is being revisited to support the SLP. We welcome the acknowledgement within the document that a robust transport evidence is required to support the SLP. Please note the advice given in the ‘SLP Transport Evidence’ section above in this response. Table 1-2 identifies the intended steps in developing transport evidence. Steps 2 and 3 form academic exercises, when it is recognised in the Regulation 18 consultation that the SLP will likely have a spatial strategy that involves a combination of elements from the six scenarios presented, with an untested combination of broad sites to ultimately come forward. However, some parameters of the findings may be useful in enabling the LPAs to interpret the impact of particular sites – choices could be made to actively look to identify sites which avoid locations that require significant mitigations and SRN infrastructure, which also will have carbon implications. National Highways support Step 4 which involves demand forecasting of the preferred SLP option. This considers use of SATURN modelling. Where strategic modelling identifies potential impacts in certain locations on the SRN, Step 4 also needs to undertake operational assessments, to understand both the impact of the SLP on the SRN and identify appropriate mitigation. This stage of evidence development should also consider the cumulative effects of growth beyond the SLP area, as identified in our comments to the Regulation 18 consultation and recognised in 2.4 of the report. National Highways support the proposed sub-objectives for the Sustainable Transport Strategy, which recognises the need to maintain the safety and efficiency of the Strategic Road Network. Table 5-2 considers the metrics used for the SLP. It appears the two metrics for the SRN have their descriptions wrongly assigned – with the safety element considering performance, and vice versa. We have concerns regarding the metric ‘collisions on the SRN and MRN within 2km of the site’. Whilst this might expediate the site comparison exercise, collisions on the SRN within 2km of a site but where the actual SRN access point (junction) is more than 2km driving distance from the site is irrelevant to that site’s potential allocation. This also takes no account of how an existing collision hotspot located on the SRN might be affected by an allocation site’s development traffic if the site is located more than 2km from the SRN access point/junction.\nNational Highways accept that DfT INRIX GPS data from 2023 will be utilised to interpret congestion at SRN nodes as a metric item. We anticipate the ability to review this assessment, and where we have local knowledge, an opportunity to advise whether we agree with the findings of this exercise. We are keen to discuss the modelling approach for the SLP going forwards. It is noted that City Science propose use of the Gloucestershire Countrywide Transport Model, to inform spreadsheet modelling. We wish to flag there is also the new GC3M model in development. As above, operational assessments will be required to understand local SRN impacts and mitigation. As previously stated in this response, National Highways will seek to provide access to existing data and models to support this process and anticipate being a key partner as this workstream progresses.\n\n[General] - Comments also submitted on individual HELAA sites\n\n"]
[null,null,15,"After reading this review, which to be honest is likened to something a year 8/9 student would produce, there are lots of statements or quotes and not one of these has been referenced or linked to an published or factual document. You state 35,700 homes need to be built over the next 20 years, where has this information been taken from? I am sure that locals born & bred in Glos, Chelt & Tewks will not need housing at that rate, so I can only assume you are destroying greenbelt land, green field sites and natural habitats 1) to develop and satisfy the need to accomodate rich people from London etc. who find they can now work from home a lot cheaper in Gloucester. 2) To satisfy 2nd home owners and buy to let landlords 3) To house all the illegal immigrants and migrants that tory BREXIT policy has failed to stop 4) To keep the construction trade at work & massage the unemployment figures. \"we have forecast 23,000 families will need to move to the area\" where does this quote originate from, or is it a guess? Gloucester was once a big \"local\" employer at Dowty Rotol, Smiths, W&J, Lucas Bryce, Dowty for eg had around 25 buses from outlying areas that workers used. It can only be said that the demise of these huge companies was brought about by government policy /lack of support when it was most needed to compete with foreign subsidised competition, and engineering reforms. The transport infrastructure you talk of in this document existed in the 1960 & 70's. We had more rail tracks a lot of which has now been built on. Norman Tebbit said \"get on your bike\" to address the unemployment problems the Tories had created and so many people took to the car to commute to outlying Counties. I speak from experience, that as self employed consultant a commute to a location as far as 80 miles is now not unusual (a 160 mile round trip). Lorries and Artic trucks clog our roadways, why? This should all be transported by rail- ah but the tracks have been taken up and buit on! Have you actually undertaken a study on where Gloucestrians actually work for example, you may be surprised that many work in London, Swindon, Bristol, Wales etc. That suggests that too many houses not enough work to me. If you actually tried to get a freight policy together it may just help before you kneejerk into turning the area into concrete. Take freight off the roads onto train and canal, use local airports (again you are doing your very best to get the airport closed at Staverton by withdrawing funding and hoping to sell it at a profit for development land). With freight off the motorways for example it should be possible to build a rail line using the redundant but existing fast lane to connect major cities by rail while using the existing rail network for commuters. This SLP is not a discussion with the public it is \"this is what we are going to do\"","Central Gloucester for example seems to be enveloped by the Tewkesbury Borough Council boundary to the North, West and East and has to accept decisions that are made by a remote council and that are not in our best interest. This is an example of Councillors moving borders over time to benefit votes at the election Gloucester boundaries to the North should be encompassing Longlevens, (Elmbridge nearly gone) Innsworth and Churchdown and Brockworth. So Tewkesbury a relatively small settlement with a small town dictates what goes in near Gloucester city. True Tewkesbury is starting to grow as it should, what was mainly farming community 40 years ago. Why is this happening, I can only assume it is to swallow up Gloucester's land so it does not have to build in its own back yard. The tories should be standing up for Gloucester not lying back and letting Tewkesbury dictate. I say the boundary commission needs to be disbanded immediately to save taxpayers money, seem like a bunch of idiots to me. Perhaps Gloucester should remove itself from this SLP joint review and work on kicking the boundary commission to touch. HANDS OFF GLOUCESTER",null,"the draft vision is a lot of buzz words based upon suppositions:\n3.3.a) \"climate change\" - will not be helped by converting green field sites into concrete housing and roads. The council's prior record of hacking down mature broad leaf trees shows that this is just a few words to be \"in vogue\" with political rhetoric. A quote from an Eco website \"A typical tree can absorb around 21 kilograms of carbon dioxide (CO2) per year, however this figure is only achieved when the tree is fully grown - saplings will absorb significantly less than this. Over a lifetime of 100 years, one tree could absorb around a tonne of CO2. While this seems like a significant amount, humans are creating about 40 billions tonnes of CO2 each year, meaning that we’d need to plant 40 billion trees annually to offset the emissions created. Even if this were possible, land space would be significantly reduced\". MORE MATURE TREES!\n3.3.b) nature recovery, what will you do here build a local zoo and rubber stamp the paper-Whitehall complied?\n3.3 d) Lets build a shed load of houses around Gloucester say Tewkesbury and the County Councillor's sat up in their Ivory Towers in the Cotswolds. What about the roads of Gloucester and the traffic jams as a result of this poor planning- wont bother Nimby Tewkesbury.\n3.3 f) right size of homes, hah will you be building starter homes , nah maximise profit for the developer 4 beds are best- hard luck first home seekers. you need to address affordable housing, brownfield sites and build apartments-too bad if it costs more to prepare the site. this must be exhasted before any green field building takes place.\n3.3 g) community facilities need to be built to support.....only this week i learn of the closure of Walls sport and social club. has this land been identified as \"developable\"? sort of saying one thing and then doing another. \n3.3. j) Rapid transport routes, like motorways clogged up with lorries, artics and white van people. lets halve the width of the busy road and build a great big cycle path that could be use to land a plane on- yeh that makes sense, oh but its ticking all the boxes in whitehall.\n3.5 green growth is that the stuff that grows on the north side of concrete?\nwhat about Gloucester City centre as its an old town like the old mature trees, there is no place for it in your plans for the future?\nGloucester and Tewkesbury have sufficient traveller locations Cheltenham has none, so I suggest levelling up 20 more in Cheltenham.\nIdeally I would like this plan scrapped, Gloucester's stolen land by Tewkesbury returned and Gloucester to go it alone on its future course. I dont see it should be decided by Tewks or Chelt council's\n",null,"What are you planning to introduce as \"zero and low carbon development\"? what is \"biodiversity net gain\" in your mind?\n\nNew Development must be on brownfield sites.\n\nIn and around Gloucester there has been a tremendous amount of development to the south and North regions. \n\nI notice that the area above the balancing ponds A417 called Tinkers Hill for some reason ? should this not be called Chosen Hill which is primarily arible farm land is identified as developable- can you explain why this is being identified for housing? MUST BE GREEN BELT and also land behind Elmbridge Court. Is this why Tewkesbury want to land grab Elmbridge? So it can build on this land against the wishes of Gloucester- Richard Graham needs to get his act together and stop Elmbridge falling into the clutches of the enemy.","Ideally to get to the net zero carbon emission you quote in para 4.5 that will have the required impact before the 2045 deadline the councils will have to address all the existing residential housing stock to keep the UK within the Paris Agreement. What are the plans to convert existing housing stock to carbon net zero. New build is easier to deliver net zero but how do you propose to achieve this? What means of clean energy production are you proposing? more wind turbines, ground source heat pumps, solar? or another incinerator slap bang in the middle of the cotswolds with some CHP piping delivering energy from burning all the trees that the council have chopped down?",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"[Q.1] 15 years is reasonable. Since this SLP review was cobbled up last year and then thrust in front of an unaware audience, I can only assume you did not want any of us to comment. I have to say this was very poorly publicised the first I knew of this was by a chance person talking of it on social media. Looking at the attendance on you open day events in Gloucester Chelt & Tewkesbury where only one or two people turn up suggests this is a fact. (these may have been local govt employees) This was not properly circulated to the electorate and I suggest that the closure date for review is postponed until the end of April, so that we all get a chance to review this. I have already complained to MP Richard Graham. You need to revise the way you consult with the public."]
["Planning agent or developer","Lovell Strategic Land","","Whilst we agree with the strategic policies, it is vital that the SLP at a minimum, seeks to meet the area’s objective assessed needs as required by the NPPF (paragraph 35). This requirement should therefore clearly be included/set out as part of the strategic policy topics.","N/A","Yes","Whilst we are supportive of the draft Vision, linked to the earlier responses, we would suggest there is specific housing targets set to ensure the objectives are measurable.","Yes","Whilst we are supportive of the draft objectives, in terms of number 3 – “making the most effective use of previously developed land”, the delivery of affordable housing on such land is challenging owing to the costs associated with acquisition, remediation and often higher than normal construction requirements (see paragraph 5.51 of SLP that highlights viability issues with previously developed land). Thus, given market housing is required to subsidise the construction of the affordable, the inevitable consequence is that targets (or objectives) for the delivery of affordable housing are seldom met. \n\nFurther, whilst the principle of making an efficient use of previously developed land is supported, building at higher densities is often to the detriment of ensuring the required mix of types and tenures of housing is delivered – most often, that of family housing/housing with gardens. Therefore, whilst higher densities can be pursued in certain circumstances and locations, it is not simply a one size fits all approach.","Locating housing in sustainable locations and which can support the delivery and enhancement of local services. This is a vital part of achieving sustainable development which in turn can assist with addressing the impacts of climate change.","N/A","N/A","No","No","","Doctor’s surgery/primary school","No","","Yes","Yes – paragraph 61 of the NPPF is clear that “to determine the minimum number of homes needed, strategic policies should be informed by a local housing need assessment, conducted using the standard method in national planning guidance.”","No","","Yes","To ensure accordance with the NPPF, the SLP needs to deliver the full range, type and tenure of homes to achieve the social objectives of sustainable development. This is intrinsically linked to the spatial strategy and ensuring there is a mix and range of sites allocated, delivered in the right locations and which is supported by the necessary infrastructure. \n\nWe would also like to highlight that to deliver what is needed, the Local Housing Needs Assessment from 2020 needs to be updated. This will ensure the policies that support housing delivery are up to date and relevant in meeting the needs of the area.","","N/A","N/A","N/A","N/A","N/A","N/A","The NPPF is clear, “housing should be located where it will enhance or maintain the vitality of rural communities” with this including, identifying “opportunities for villages to grow and thrive, especially where this will support local services”. This is at the very heart of delivering sustainable development. \n\nThus, the SLP needs to ensure new homes are delivered in the right locations which can provide opportunities for services to be protected, enhanced and then supported by new development. This approach will ensure the SLP accords with paragraph 83 of the NPPF.","The level of infrastructure required to support development needs to be considered on a case-by-case basis. Thus, what is required is intrinsically linked to the location of development and to ensure the SLP meets the objectives of the NPPF in delivering sustainable development, sites should be allocated in areas that are in close proximity of current services and which can integrate well with existing communities. \n\nThis approach will allow development to deliver policy compliant levels of affordable housing for example as they will not need to fund other types of major infrastructure work (major highway works etc) that would impact a scheme’s viability and/or, the ability to deliver the full range, type and tenure of housing.","The level of accompanying infrastructure needs to be considered at the outset. This is vital as not only do new settlements take considerable time to be delivered, but the level of infrastructure and associated funding to support such development is extensive.","Doctor’s surgery/primary school/bus links to the wider area.","Yes","No","No – whilst we suggest there are no other scenarios that should be considered, in order “to support the Government’s objective of significantly boosting the supply of homes” (NPPF, paragraph 60), it is vital a mix/variety of sites are allocated. Therefore, the policies in the SLP needs to “identify a sufficient supply and mix of sites, taking into account their availability, suitability and likely economic viability”. This approach will ensure the objectives of the SLP are delivered and allow the SLP to: “identify a supply of: a) specific, deliverable sites for five years following the intended date of adoption; and b) specific, developable sites or broad locations for growth, for the subsequent years 6-10 and, where possible, for years 11-15 of the remaining plan period.” (NPPF, paragraph 69). In stressing the need of the SLP to allocate a specific deliverable supply of housing, we want the highlight Land east of Oakridge, Highnam (HELAA Ref HIG006) which has been considered to be suitable by the Council (Tewkesbury) in 2019 (for 78 dwellings) and developable by the Council through the December 2023 HELAA (for 104 dwellings). In terms of delivery, the Site could be developed within the first five years post adoption of the SLP.","Yes","Yes, but the con/negative of new settlements (development scenario 4) and the length of time of delivery cannot be underestimated. Therefore, and at a time when there is a clear and demonstrable need for new housing, the SLP must acknowledge the ability of sites that are deliverable in that they are available now, offer a suitable location for development now and are achievable with a realistic prospect that housing will be delivered on site within five years. In summary, such sites must form a large component of the housing supply. As set out in response to Q.27, one such site is Land east of Oakridge, Highnam (HELAA Ref HIG006).","Scenario 1: Urban concentration; Scenario 2: Urban extensions; Scenario 3: Urban extensions, avoiding the Green Belt; Scenario 4: New strategic settlement; Scenario 5: Rural dispersal; Scenario 6: Sustainable transport scenario","No","","Please see response to Q.29 in respect of a deliverable site in Highnam (site ref HIG006 – Land east of Oakridge).\n\nShould the Strategic and Local Plan require more than the mandatory minimum 10% Biodiversity Net Gain through development? \n\nNo. \n\nThe Environment Act is enacted and requires at least 10% net gain in biodiversity. Further, new guidance has also recently been published that advises plan-makers not to seek more than 10% biodiversity gain unless justified. \n\nThus, unless there is a justified requirement to go over and above the 10%, the requirements of the Environment Act should be accorded with. \n\nShould the SLP consider going over and above 10%, there needs to be a realisation that this will be an additional cost to developers which could result in developments becoming unviable in consideration of other requirements – for example, affordable housing and the building safety levy. This concern is raised at paragraph 5.52 of the SLP.\n\n\nShould the Strategic and Local Plan safeguard sites or routes for longer term infrastructure projects? \n\nYes. This will ensure positive planning according with paragraph 22 of the NPPF and allow the SLP to deliver infrastructure across the life of the plan period in a joined up and comprehensive manner.\n\n\nWhich of the development scenarios, or combination of them, do you consider the most appropriate for the Strategic and Local Plan? \n\nAs set out in response to Q.27, the strategy adopted in the SLP must allocate a mix and range of sites. It cannot be the case that one development scenario is adopted as the Councils accept that “none of these development scenarios could deliver the likely scale of proposed development in the SLP alone and it is likely that a combination will be required”. \n\nLinked to supply is delivery, and this is the significant con/negative of development scenario 4 – new strategic settlements for the reasons as set out in response to Q.28. \n\nIn respect of the specific scenarios, Land east of Oakridge, Highnam (HELAA Ref HIG006) would fall within development scenario 5 – rural dispersal. Simply put, a dispersal scenario will allow a wider range of housing choice (of all types of tenure) and in so doing, will supply the right type of homes in the right locations to meet the needs of the community – one of the fundamental aspects of the SLP’s vision. \n\nHowever, whilst the Site was assessed by the Council (most recently in December 2023) and considered to be potentially developable for residential development, I wanted to highlight that it is actually deliverable in accordance with the requirements of the NPPF. In summary: \n\nThe Site is available – it is being promoted by the landowner, is in single ownership and subject to obtaining an allocation, a planning application will be submitted shortly after the Plan has been adopted. \n\nThe Site is suitable – as confirmed through the 2023 HELAA, there are no physical constraints that could potentially impact the development of the Site. In terms of any impact on the wider landscape, the HELAA confirms the Site is relatively well contained and with the incorporation of a landscaped buffer along the southern boundary, it would assist in mitigating (any impact) with the development of the Site being seen in the context of Highnam. \n\nThe Site is achievable – the Site is under single ownership and being actively promoted through the SLP process. Further, the Council has considered the Site to be developable in the 2023 HELAA. To this end, there is a very real prospect that housing will be delivered within 5 years of the SLP being adopted and in so doing, will allow the SLP to allocate a specific and deliverable site.\n\nHow far into the future should the Strategic and Local Plan cover?\n\nTo ensure accordance with the NPPF, the Cheltenham, Gloucester and Tewkesbury Strategic and Local Plan (the ‘SLP’) needs to look ahead over a minimum 15-year period from date of adoption. Thus, should the SLP be adopted in 2027, it needs to cover the period of at least to 2042. \n\nFurther, given the expected growth of 23,000 additional families that will form and make the area their home over the next 20 years (pg.2 of the SLP), it is vital that an appropriate strategy is adopted which will then allow for a mix of sites and a range of homes to be delivered which can help combat affordability issues and support growth across the plan period and in the correct areas."]
["","",15,"Conserving and enhancing Best and Most Versatile Agricultural Land / promoting local food production ","Staverton Airport / Cheltenham Spa waters","","With an emphasis on local food production and recreational activity, the existing rural areas and countryside should be conserved and enhanced","","With an emphasis on local food production and recreational activity, the existing rural areas and countryside should be conserved and enhanced","Promoting alternative forms of transport including waterways by reducing car dependency and HGV usage","High standards as to aesthetics and function and strict compliance with regulations","With discretion as much as possible","Yes","","Land (including Grade 1 Agricultural Land) to the North West and West of Cheltenham for local food production and for environmental purposes","Doctors, Dentists, Vets, Community Hospital / Health Centre, Police, \tAllotments, Crematorium and Community Centre with library and provision for food and drinks and community events","","Hydroelectric power harnessed from the Severn Estuary and Wind turbine power generated from the Cotswold escarpment","No","In accordance with the principles of subsidiarity and the devolution of as many powers as possible the decisions should be made by local authorities based on their unique knowledge of the local area, its historical and current uses and future potential","No","In accordance with the principles of subsidiarity and the devolution of as many powers as possible the decisions should be made by local authorities based on their unique knowledge of the local area, its historical and current uses and future potential","Yes","for an ageing population and those with disabilities / special needs","","Not aware of any","Grazing / Streams and fresh water / toilet and washing facilities","Those which are of benefit to the community and environment, non polluting and taking place in attractive and sensitively designed buildings / units having good transport with an emphasis on the reduction of private car and HGV usage","Those which are of benefit to the community and environment, non polluting and taking place in attractive and sensitively designed buildings / units having good transport with an emphasis on the reduction of private car and HGV usage","Those which are of benefit to the community and environment, non polluting and taking place in attractive and sensitively designed buildings / units having good transport with an emphasis on the reduction of private car and HGV usage","Retail trade in city and town centres is seemingly in a state of permanent decline.  Consequently, serious thought should be given to the conversion of these redundant retail outlets into a mixture of residential properties with generous green and open spaces encouraging a sense of community. This could be combined with release of a vast area of redundant car parks as a result of a major transition to public transport","To actively promote this policy and its evolution","Good public transport / cycle tracks / footpaths / please refer to 10. above","Good public transport / cycle tracks / footpaths / please refer to 10. above","Good public transport / cycle tracks / footpaths / please refer to 10. above","No","No","","Yes","","Scenario 1: Urban concentration","","","[Q15] Sites should be made available for their use but their lifestyle to travel through the countryside should be respected and not impeded.\n\n(a) Conserving and enhancing the countryside is also necessary for a healthy lifestyle as the Covid lockdown period has made abundantly clear\n(b)\tAll policies should be directed to the substantial reduction of noise and air pollution (mainly caused by cars and HGVs) and  flood risk\n(c)\tIt is not accepted, in practice, the process to alter Green Belt boundaries is as robust as presented @ par 6 on page 39\n(d)\tWhilst populations are ageing they are not necessarily growing\n(e)\tAs to deprivation, Gloucester’s is high  and Cheltenham’s is moderate"]
["Statutory/Specific Consultee","Gloucestershire Police","","Crime prevention and Designing Out Crime should be considered as an overriding theme for each policy strategy.  \n\nFurther evidence exploring the issues facing those who live or work within the three council areas would be advantageous to safeguarding economic stability could be supplied from Gloucestershire Constabulary","","","The Vision is very long and prescriptive of so many aspects of the county, editing the text and grouping themes would help create a concise vision of the future.","","Would like to see an objective that addressed current and future concerns by offering to create safe and secure homes within environs which reduce ASB or criminal opportunities\n\nTransportation and commuting for work or social reasons should be included so the road network and supporting infrastructure are improved in conjunction with future developments.","","","","","","","","","","","","","","","","","","","","","","The current plan offers no information of the volume of crime and ASB affecting any retail outlet or community resource.  Changes need to be implemented to safeguard each business as there were 2625 reported incidents of shoplifting across Cheltenham, Gloucester and Tewkesbury in the last 12 months.","Creating an environment that safeguards retail and other services","","","","","","","","","","","",""]
["","",20,"Plan should review the strategic criteria for flood risk policy, currently too loose in the light of climate change, resulting in inappropriate sites. Currently too loose resulting in build on inappropriate sites which flood.","The A46 Shurdington Road (and Bath Road) is full to capacity. Cheltenham is built to its boundaries, also there is a proportionately very large amount of urban heritage within Cheltenham. There will be other unique features in individual districts and neighbourhoods which should be respected: E.g Up Hatherley has a distributor road, Up Hatherley Way, and this feature should be connected by side roads to any new houses built via cul-de-sacs and not build houses directly on Up Hatherley Way. All 3 districts have pieces of unique industrial heritage. ","Yes","Yes, broadly.","Yes","Yes broadly, but the plan should consider a new General Hospital to replace GRH & CGH, which would therefore need to anticipate a strategic site.","Should aim to place housing and major workplaces within short travelling distances to reduce environmental damage and improve quality of life.","New build should be to good building standards and fairly high density. Existing buildings should be retained and conserved either where the heritage and history is valuable, and/or where it is economic or environmentally beneficial.","","","","Not specifically at this stage but: a. See answer to Q6 b. Adequate land, that is, much more than is often the case in new developments, should be retained to provide “green lung” areas between developments.","Shopping, medical, schools, recreation and worship, workplaces, and good transport links – and must go in early in the development process.","Yes","In principle yes. Solar farms would work well. (Wind turbines unrealistic in most of Gloucestershire, though might work on hills).","Yes","Broadly, yes.","","Generally, not that I know of.","Yes","Plan needs to take a realistic view of in-migration. so housing quantum and type needs to encourage young adults to remain in, or move into, the area, so as to reduce or reverse the present trend of net emigration. Conversely Cheltenham already has too many care homes, and planned housing types should discourage over provision. There should also be adequate student accommodation including students living off-campus in HMO houses.","","We need to understand our obligations on this subject, and my anticipation is that Cheltenham should increase its provision from its current base of zero. That said I would not consider the highly urbanised nature of Cheltenham as especially suitable for travellers, so the increase }provision would not necessarily be large.","","Quite a lot! Where are the people in these 35000+ new homes going to work?","Identify employment land & work with GCC/LEP, major Employers, developers, and others to deliver the optimum employment places.","Ditto, but on a smaller scale ","Realistic re-planning of town/city centres, to encourage employment opportunities, together with more residential and less shopping. i.e. mixed development based around ‘Urban Concentration’","What powers exist to promote specific areas for commercial/employment use? We should use all means available to do this.","Public Transport (and obviously utilities). Very important that we  do not wait till near the end of a new development to provide buses and the like, otherwise only car-owning people will move to it, and their car-dependant habits will be established well before and after buses etc are provided.","Transport and roads, nearby employment, medical/dental, shopping, schools, recreation and worship; adequate flood prevention measures.","Ditto, but on a smaller scale. Good public transport to nearby larger towns is really critical.","Yes","Yes","NO COMPLETELY NEW DEVELOPMENT IDEAS, BUT A ‘BLENDED’ SOLUTION is needed with emphasis on Strategic settlements. All other scenarios should be included , but Urban extensions should be minimised, especially in Green Belt, and particularly where they have long and tenuous transport and infrastructure links to the centre(s).","Yes","There are ADDITIONAL ‘CONS’ ON URBAN EXTENSIONS a. Difficult to provide good infrastructure, especially provide good transport, extended distances to town centres, because area are not self-contained, and without heritage they will normally lack sense of place or community. To make matters worse, the tendency is to introduce limited public transport after many houses are already build, and that means the new residents must be already established as car commuters, and an hourly bus route isn’t going to change their habits. b. Urban extensions take away existing green lung from existing communities, whilst not providing it for the new community either, as in parks, gardens, walking  open space for children, dog walking etc. Planners should not persist in thinking these difficulties can be overcome, as the problems are intrinsic to all urban extensions","","","On rural settlements - Ask ALL the communities and villages!! Rural settlements are a good idea, and much requested by some communities albeit limited quantum of total potential but should be where they are wanted, and not imposed.","[Q26] Yes, they would have to for the plan to work. [Q29] Strategic new settlements are a good idea, but they need to be large enough to work as towns in their own right, but with good links to other towns. In my view should plan to reach a minimum of 10,000 population. So Ashchurch and Highnam/Churcham should work well, but Boddington would be a disaster – it is not only existing green belt, but it is in the ‘middle of nowhere’, to be frank.\n\nThe Sustainable transport route as a basis  for sites for development is a good idea and provides for possibility of environmentally good solutions including mass rapid transit (MRT). Best use for Gloucestershire Airport Site would be for a major new General Hospital. See answer to 5.\n\nThere is however a risk of ribbon development along the route and of a merger of Cheltenham & Gloucester, which is generally not desired. a. I don’t agree that there is under-provision of food shopping in Bishops Cleeve. There is a large Tesco and Lidl etc.\nb. We should avoid developing in such a way as to physically merge Cheltenham and Gloucester, in order the preserve the character of both."]
["Local Councillor","Prestbury Parish Council","","Secondary health care – i.e. hospitals.","Cheltenham racecourse is in Prestbury parish.  Access for race traffic and local traffic.\nFlooding.","Yes","","Yes","Yes but greater explanation is needed – it is too nebulous.","Prioritise dealing with flooding and drainage.","Maximise re-usage of existing buildings.","Maximise re-usage of existing buildings.","","Yes","Add allotments sites to all new developments.","Schools.\nHealth care.\nCorner shops and Post Offices.","","Maximise use of existing sites – eg Sainsbury’s car park at Oakley could be roofed over and solar panels added.","","We understand the model used dates from 2014.  Much has changed since then – update?","","","Yes","More ‘starter’ homes.\nMore accommodation for older people.\nNot so many 4/5-bedroom houses.","","","","Integration is the key – infrastructure.","","Food security.  Encourage much greater level of food produced from British farms rather than relying so heavily on imports.","Free car parking in all car parks for the first hour.\nLower business rates for all businesses permanently.\nFree business consultation services available to all.","Keep existing car parks.  Cheltenham Borough Council – don’t sell Idsall Drive car park in Prestbury to developers.","An integrated transport policy that includes public transport of all types and provides enough car parking space.\nFailure to provide enough car parking space clogs up roads and causes huge problems for the emergency services.  ","An integrated transport policy that includes public transport of all types and provides enough car parking space.\nFailure to provide enough car parking space clogs up roads and causes huge problems for the emergency services.  ","An integrated transport policy that includes public transport of all types and provides enough car parking space.\nFailure to provide enough car parking space clogs up roads and causes huge problems for the emergency services.  ","Yes","","","Yes","","","","","[Q29] One size does not fit all.\nBits from all the development scenarios are required.\nFlexibility."]
["Planning agent or developer","HGH Consulting ","","","","Yes","","Yes","Yes but the viability of sites and of the Plan generally needs to be fully considered and appropriate levels of flexibility applied as per the NPPF (see attached letter from hgh Consulting on behalf of HBD Golden Valley Limited).","","","","","","","","","","","","","","","","","","","","","","","","","","","","No","No, but the final spatial strategy will need to be a combination of all scenarios (see attached letter from hgh Consulting on behalf of HBD Golden Valley Limited).","","","","","","The NPPF states that Plans should be prepared positively, in a way that is aspirational but deliverable. Contributions from development should be sought, but these should be determined alongside the viability of sites such that the deliverability of the Plan is not undermined.\n\nWest Cheltenham is a strategic allocation in the JCS, and one that is making positive progress through the planning system. Given its scale and importance to the area, it will contribute to the joint authorities’ housing and economic strategies over the next Plan period. It is therefore essential that its viability is maintained.\n\nThe promoters and development partners of Cheltenham Borough Council’s land assets at West Cheltenham – HBD Golden Valley Limited – are broadly supportive of the draft vision and the eight strategic objectives:\n\n1. Meeting the challenges of climate change\n2. Building strong, competitive and sustainable urban and rural economies\n3. Ensuring strong and vibrant city and town centres\n4. Delivering a wide choice of homes that meet the needs of our communities\n5. Delivering well designed, beautiful and safe places\n6. Prioritising sustainable transport and active travel\n7. Making as much use as possible of brownfield land and conserving and enhancing the natural and historic environments\n8. Promoting healthy and resilient communities\n\nThe proposed development at West Cheltenham embodies all of these objectives and seeks to become an exemplar garden community. However, it is not immune to the economic challenges of today and cannot achieve everything that is asked of it.\n\nBy way of example, whilst HBD Golden Valley Limited are striving to achieve commercial buildings with RIBA 2030 operational carbon targets, such targets are difficult to achieve, and a degree of flexibility is required. This aligns with the recent Written Ministerial Statement issued by DLUHC in December which told councils that Plans should not set energy efficiency targets that are stricter than building regulations unless they have a “well-reasoned and robustly costed rationale”, including that development should remain “viable”.\n\nSimilar levels of consideration (and where possible flexibility) should be provided for in other policy areas too:\naffordable housing; biodiversity net gain; SANG; and infrastructure provision.\n\nRegarding the latter, strategic pieces of infrastructure (such as the proposed improvements to Junction 10 of the M5) affect a wide area. They can enable strategic levels of growth. It is important, therefore, that the any contributions towards these projects are proportionately based, with no one scheme being unfairly burdened. The net for catching contributions should therefore be cast widely.\n\nRelatedly, it is HBD’s position that the Plan’s spatial strategy should involve a combination of all development scenarios mentioned in the draft SLP, namely:\n• Urban concentration\n• Urban extensions\n• New strategic settlements\n• Rural dispersal\n• Sustainable transport\n\nThe latest version of the NPPF is largely the same as before. It still requires Plans to “meet the development needs of their area” and, as a minimum, “provide for objectively assessed needs for housing and other uses”. Furthermore, where “exceptional circumstances” exist, Plans can still seek to remove land from the Green Belt to help meet these needs.\n\nThe joint authorities are no exception to this and need to plan accordingly. The Government is currently consulting on a presumption in favour of brownfield development; there are clear sustainability benefits arising from new settlements and urban extensions (particularly where this is linked to sustainable transport initiatives), but such places are complex and don’t typically deliver quickly; and appropriate levels of development in rural areas can help to support existing communities.\n\nIt is important that a suitable mixture of all the above is sought in the Plan; and that this is supported by a robust evidence base that fully considers the viability of sites and shares costs as widely as possible. It would be risky for the joint authorities to place all its eggs in one basket.\n\nWe look forward to submitting further representations as the Plan develops.\n\n"]
["","",20,"Cycle ways \nRiver pollution and management \n\nThere is a need to consider what people in rural communities want. Building on rural land near existing rural communities like Highnam and Churcham adversely affects the rural balance in these areas. People who chose to live in rural communities do not want their choice of a rural environment to be taken away. ","Highnam and Churcham communities are under threat by the proposed areas of development. Highnam has already taken a disproportionate number of new houses over recent years. With the recent approval of a further housing development opposite Highnam golf course, the number of new houses in the existing Highnam neighbourhood plan has been exceeded. For this reason, Highnam should not be expected to take any more houses.","Yes","broadly.\nMention of footpaths and cycleways ","Yes","Yes Overall","•\tThe best way the Strategic and Local Plan could be most effective is as a facilitator to work with other agencies to create a comprehensive set of policies which together have impact and become effective. From the viewpoint of the Parishes close to the Severn Vale, flooding is a major consideration and is already having a deleterious impact on Highnam. There are those properties directly affected which flood, whilst all the communities are affected by the lack of appropriate roads, drainage, maintenance and adequate highway infrastructure. The increase of traffic on an inadequate road infrastructure on the A40 and B4215 is exacerbating the problem. If we are to become less reliant on cars, properly considered public transport systems which are affordable, convenient, reliable and operate at times when passengers need them are essential. Unless the appropriate services are in place to meet people’s needs, transport services will not and cannot be properly utilised.\n\n•\tIt is important to keep development near to main towns. NB Item 2 of the draft strategic objectives is ‘ensuring growth takes place in sustainable locations that minimise the need to travel etc’ \nBuilding in Highnam and Churcham does not meet these objectives as people will mostly be travelling into the main towns/cities to work.\n\n","","","","","","","","","","Would be helpful to clarify how it was decided that 35,7000 houses would be needed.","","","","","No","","","Small settled sites","","","Good transport links and cycle routes","","","Road networks able to support the new capacity\nSustainable development and transport\nEnvironmentally friendly housing and \nGP Surgeries/health facilities\nSchools\nCommunity and sporting facilities\nWater and sewage systems \nCycle ways and footpaths ","Excellent transport routes. ","","","","","","","","","[Q1] 20 or more years\n\nI would be strongly against building on the areas HIG007 and HIG013 (Monkey Back Hill) for the following reasons:\n•\tThis is an area of great natural beauty with uplifting and extensive views in almost all directions, taking in Wales, the Malverns and the Cotswolds.\n•\tThe hill is heavily and regularly used by Highnam residents including dog-walkers, nature lovers, families and older residents.\n•\tThe public footpath across the hill is part of a longer pathway from the village, across the playing fields, through the woods, out onto the hill and out the other side over the stile onto the spine track. This route provides pleasure, exercise and mental wellbeing to many. \n•\tBuilding on Monkey Back Hill would deprive residents of a beautiful natural asset and would be detrimental to their mental and physical health by curtailing their opportunities to get out into the natural environment."]
["Planning agent or developer","",15,"No","In Tewkesbury Council Area the boundary is such that it is meeting the needs of the Cheltenham and Gloucester council areas and using the facilities within those council areas.","Yes","","Yes","Yes, although the emphasis could be on creating jobs as well as supporting businesses which are not necessarily the same thing. ","By locating new development in areas that are and have the potential for increased travel by walking, cycling and public transport.","","","","","","Primary schools and day to day convenience retail.  Appropriate open space and play facilities.","","","Yes","","No","","","","","","","","","","","","Walking, cycle and public transport infrastructure; Infra structure to support transition to electric vehicles in existing and new communities.","Public transport hub linking any new community with existing settlements and strategic employment locations.  Schools – primary and secondary. Local centre. Open space, sports and community facilities. Allotments etc","The presence of a primary school and a range of local facilities within walking distance.","","No","","Yes","","Scenario 2: Urban extensions; Scenario 6: Sustainable transport scenario","No","","[Q.8] No, as it can be very difficult to meet this target on constrained sites, but there could be positively worded policies to incentivise providing more than 10% BNG.\n[Q.29] the response states: Scenario 2 Urban Extensions and scenario 6 Sustainable Transport Scenario are the only options that will deliver the need identified, in a location close to where those needs arise and reducing the likelihood of unnecessary travel into and out of the JSP area as well as providing the opportunity for active travel.  A range of housing types can also be provided."]
["Statutory/Specific Consultee","Gotherington Parish Council ","","","Valued landscapes, nature and wildlife corridors, woodlands and important views.","Yes","Yes, but was the JCS Vision achieved? What lessons have been learnt?","Yes","Yes, but were the JCS objectives achieved? What lessons have been learnt?","By focusing development on areas with good bus routes and other means of sustainable modes of transport, not in rural villages.","Energy efficiency.","Energy efficiency","Yes","Yes","Thirle valley for wildlife and recreation.","Primary school and community recreational facilities","","","No","No, the Commons Select Committee declared that the Standard Method isn’t fit for purpose. Its main defect is that it doesn’t account for local need. Please start with local need, particularly for rural villages.","Yes","Constraints, such as flooding, AONB and transport infrastructure.","","","","","","","","Rural employment should be genuinely rural. Shifting urban employment to rural areas doesn’t make sense.","","More housing isn’t the answer as facilities may not be capable of expansion to meet the needs of additional residents.","","","A rural settlement must have good social facilities (sports field, village hall, etc) to achieve social cohesion.","Yes","","","No","Scenario 5: Rural Dispersal\n\nLessons must be learnt from the JCS and the subsequent excessive demands on Service Villages. For example, Gotherington was allocated 86 dwellings in the period 2011-2031 and already over 200 have been permitted.  Over half of those permissions have yet to be built out. In our opinion there should be no further allocation to Service Villages in the SLP, except where there is a genuine rural need. \nDevelopment in rural settlements is incompatible with the Borough’s Climate Change policies. \nRural Dispersal  is  the least sustainable of all the scenarios. \nWe have reviewed the pros and cons and offer the following comments\nPros:\nRe-use of redundant buildings and sites is unlikely to make a major contribution to housing need.\nWe can’t see why safeguarding the green belt is a reason for rural dispersal. Every application has to be judged on its own merits.\nWhy support thriving communities? The emphasis should be on communities that aren’t thriving. \nOnly a small number of people have employment and family ties to the countryside and in any case are unlikely to be able to afford the houses that would arise from rural dispersal. It must be acknowledged many residents in rural settlements travel along the M5 corridor to work further afield.\nWe recognise that there is a national crisis in affordable housing, but what is the requirement for affordable housing in rural areas? For a variety of reasons it is much more expensive to live in the countryside. Affordable housing should be directed to locations where people in need of affordable housing want to live. We support affordable housing for a genuine rural need.\nCons:\nUnplanned permissions during the JCS period demonstrate that the character and appearance of some Service Villages have been harmed. Unfortunately, some developers will seek to maximise profits by building large houses on small plots, leading to harmful effects on village character and appearance.\nIt isn’t simply the length of the journey that matters. Even for short journeys, congestion around major centres leads to delays and increased air pollution. \nThe Service Village allocations in the JCS were based on the crude metrics of the Rural Settlement Audit (RSA). We believe that the RSA is unfit for purpose since it has no qualitative or quantitative basis. For example, there is no differentiation between  large and small village halls. \nServices Villages, such as Gotherington, are constrained by the footprint of their facilities, expansion isn’t feasible. Even if significant change was desirable, the nature of the incremental development means that we are stuck with our limited central facilities. Larger development (50 houses) attempt to compensate for the lack of facilities by providing limited facilities with the development. This leads to a breakdown in social cohesion as residents on new development may no longer visit central facilities.","","","","[Q1.] At least 20 years. Major infrastructure 30 years.\n[Q8.] Yes, but the gains must be actual and not theoretical.\n[Q26.] Yes, but it is probably too late for the A46 upgrade.\n[Q29.] Only the most sustainable scenarios should be included in the plan.\n[Q31.] We can’t understand why the possible sites map was included. For access and other reasons the sites in and adjacent to the parish of Gotherington are unsuitable for development. Their inclusion causes wholly unnecessary distress to residents. For example, BIS16 lies in the LAN3 strategic gap between Bishops Cleeve and Gotherington which is designed to prevent the joining up of Bishops Cleeve and Gotherington. It should never have been included."]
["Statutory/Specific Consultee","Sport England",15,"While it may be assumed, that formal informal sport and recreational facilities are included in this section, it would better to include them.",null,null,"We have concerns over this phrase: Together with necessary retention and management of existing sports and leisure facilities,\n\nThis is not sound by assuming there is sufficient sports and leisure facilities, and they are in the right places.  There is no evidence to support this.  Sport England is confident by saying there will not be enough facilities for the projected population.  There is a question mark that every facticity is in the right location to serve population. \n\nNB some of the existing facilities are aged and environmentally inefficient.\n\nWe would suggest rephrasing to this:  Together with appropriately located and sustainable  sports and leisure facilities, this will have unlocked opportunities for healthy lifestyles, inclusive access to sport and recreation,……….\n\nSport England would seek to work the those seeking to deliver the SLP in creating a robust evidence basis for creating sustainable and inclusive sports and leisure facilities in the right places.","Yes",null,"Setting out sound policies which have been proven to address the impacts of climate change, and make site allocations in sustainable locations. ","a)\tEncourage passive design, whole life adaptive building design and the requirement for whole life building costs.\nb)\tBefore a building is retained, a total cost benefit analysis on the retention v new build, which should include whole life costs.","a)\tEncourage passive design, whole life adaptive building design and the requirement for whole life building costs.\nb)\tBefore a building is retained, a total cost benefit analysis on the retention v new build, which should include whole life costs.",null,null,null,"Formal and informal sport and reactional facilities. ",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Opportunities for formal and informal sport and recreation ","Opportunities for formal and informal sport and recreation ",null,"Yes",null,null,"Yes","Yes, the arguments are well set out and easy to understand.",null,null,null,"[Q1] The logic of 15 years as suggested in this section seems sound.\n\n[Q.8] This could cause issues with charities, and the voluntary sector both from a financial and land take perspective.  One idea could be a sliding scale could be introduced, like in some CIL authorities, where depending on the location some developments could attract 25% BNG and others 15%.\n\n[Q.26] Yes (safeguarding infrastructure sites) this is important to ensure there good forward planning for future generations. \n\n[Q.29] The order in which they are set out seems the most local with Urban concentration being first – higher density use of low rise flats does need to be considered."]
[null,null,null,null,null,null,"I understand this is about housing and creating places for people to live. I feel that there should be some feedback of views from Police and Fire Stations. There have been a build on Pirton Fields where there was a increase in vandalism. \n\nWhere development is planned, I feel that public safety (road speed enforcement, vandalism, crime) should be included within the plan.\n\nWithout this, we are creating places for people to live - yes, but also not considering how we make this are safe and protect people from lawlessness. I thing costing should include financing in this area."]
[null,null,null,null,null,null,"Broadly, I agree with the draft vision and it's encouraging to see there's a particular focus of creating walkable neighbourhoods. However it focuses on new developments - which is great - but doesn't focus on the housing and developments we already have.\n\nThe places people will want to visit in the future are more than likely to be the places people visit today - town centres, shopping precincts, parks and recreation spaces. We need to focus on making it easier to access these spaces by improving the neighbourhoods and development on the periphery of these. Removing parking and adding dedicated bus / cycle lanes, blocking off main road access to residential streets, speed bumps to reduce rat runs.\n\nThere is no point in creating isolated islands of good development if they don't lead anywhere - people will just use their cars regardless.",null,null,null,null,null,null,null,null,"Transportation is the most important provision that needs to be considered in new developments. How are all of these people going to get to work / school? If the answer is \"cars\" or \"hourly bus\" that's absolutely not acceptable.\r\n\r\n\r\nIf we really want to combat climate change, we need to make it easier and cheaper to take public transport than it is to take a car.",null,null,null,"With housing it is always safer to overbuild rather than underbuild. I think whatever the Standard Method spits out, we should be building at least 10% more. Affordable housing will be automatically created when demand better matches supply.","Yes","Currently we have a shortage of housing in general, and I think we need more than what is calculated and we should be building more, and more densely. If Gloucestershire can position itself as an affordable place to live by bringing down the local cost of housing, workers will follow and drive innovation locally. ",null,"Gloucestershire absolutely needs higher density, high rise and high quality housing. We need to be focused on building up rather than outward, and Cheltenham in particular is constrained by the Green Belt. As an example - instead of taking up housing in St Pauls which could be used long term for families, students to the university should be provisioned for with several high density developments along transit corridors. The university should take responsibility for the students it is bringing to the area and contribute towards development that helps both the university and the community it is located within.",null,null,null,"Provision of low cost, small-scale rental units for local businesses which are located along key public transport corridors and cycling routes. This may include subdividing areas within town centres to provide opportunities for more businesses.",null,null,"There's no point in using buses if they get stuck in the same traffic as everybody else. We need dedicated bus corridors to our town centres to make taking the bus a more attractive option, and dedicated cycle lanes and bike parking to make taking a bike from the suburbs more appealing.","There's a lack of medical facilities and post offices in the more suburban areas of Cheltenham in particular, meaning that people have to drive often to access basic services. We should be rectifying this by working in conjunction with the Post Office and NHS to provide more locations people can access these services on foot from their homes.","Transport! Dedicated bus and cycle lanes leading to these developments can greatly reduce reliance on private cars. People should feel safe and relaxed while travelling to and from home.","You shouldn't need to own a car if you live in one of these new settlements - in fact, it should be less convenient to use a vehicle in them. As others have said, make it easier to travel from these new settlements to where employment and education actually are in established settlements.","Nearby public transport corridors and their integration into the development. Rural roads will get overloaded with private vehicles if this isn't provisioned for. This may mean we need to reopen old railway lines or provide dedicated busways.","Yes",null,null,null,"Agree. Building standards need to be strengthened, so that living in an apartment complex or row house doesn't feel that you are living on top of each other with paper-thin walls. It's possible for higher density housing to be high quality, we just don't legislate for that.","Scenario 1: Urban concentration; Scenario 6: Sustainable transport scenario",null,null,"[Q.26] (Safeguarding sites for infrastructure) 100% provision of rights of way for railways and cycle paths is incredibly important. Even a dedicated bus lane can become a future tram line, if it is protected.\n\n[Q.29] A combination of 1 and 6 are the best way forward for Gloucestershire. We must concentrate development in existing urban centres, building up rather than out and also build along existing public transport corridors. This might mean new busways, new railway stations alongside existing lines or reopening old railways alongside new development. All other options will either create sprawl or destroy a large amount of our natural environment.\n\n[Q.31] In general - if we're planning for the future, focusing on transport is the only way to ensure that any of these goals could possibly be met. There is too much reliance on private cars to plug the gap left by missing public infrastructure. Gloucestershire should also be looking to follow Manchester and bring our bus routes into local council management - this could be a money maker for council but also a useful tool in local planning. We must not continue building flood-prone sprawl, we can be better."]
[null,null,null,null,null,null,null,null,null,null,null,null,null,"Yes","I would strongly suggest two areas from the Tewkesbury Borough CouncilHELAA Map:\nSHUR029\nSite_Location\tLand south of Up Hatherley Way GL51 3YF\nCapacity\t1793\nHousing - Overall Assessment\tPotentially developable\n\nSHUR025\nSite_Location\tLand at Oak Farm, Chargrove Lane, Cheltenham, GL51 4XB\nCapacity\t417\nHousing - Overall Assessment\tPotentially developable\n\nAND SURROUNDING LAND CURRENTLY IN THE GREENBELT\n\nWILDLIFE / BIODIVERSITY NET GAIN\nThese areas already include an orchard with trees protected by TPO, visited by tawny owls and bats which need a green habitat preserving around them to stay viable. The land supports large mammals (foxes and roe deer). It is a hunting ground for large predatory birds: buzzards and red kites. It is visited by lapwings – a ‘Red List’ species which needs every support. I have seen a kingfisher on the stream which runs through the small Nature reserve. There are varied species of butterflies e.g. Marbled White on wildflowers in rough grass, Gatekeepers on brambles. Violets and periwinkles are currently growing by the roadside. There are magnificent mature oak trees, each supporting hundreds of species – and in very urgent need of TPO protection. A remarkable amount is surviving within conventional farming. With some nature-focused management – e.g. wildflower plantings on headlands – even more species could be encouraged. This is a rich oasis near dense housing, much appreciated. It should NEVER be considered for housing and the Councils should work to see how it can be made even more wildlife friendly.\n\nRECREATION\nThese areas are used by hundreds of people of all ages for recreation: cycling, walking, dog-walking, running. People who prefer or need a hard surface to walk can use Chargrove Lane to enjoy views of the countryside, trees, deer and birds. There is also an extensive and very well-used network of public footpaths across this area. These allow the public to observe nature at close quarters -e.g. the many imposing oaks. They are also a link to the area’s history. Up Hatherley people for centuries walked to Shurdington Church. Vitally, hundreds of people can reach this area ON FOOT, which is healthy and reduces pollution. The local beauty spots such as Cooper’s Hill and Crickley Hill are excellent – but they cannot be reached via public transport by people who live near Chargrove Lane and Up Hatherley Way. Since the pandemic, there has been much public comment on problems with mental health, and the need to engage with nature. Doctors now prescribe walking, and there is at least one regular publicly organised walking group. These areas are an ideal resource for healthy recreation and wildlife watching – and should be permanently protected from development.\n\nFLOOD RISK MITIGATION\n\nThis land is needed to absorb local rainfall. Covering even part of it with hard surfaces would displace floodwater elsewhere. Quite simply, it is very, very wet land, especially around Brickhouse Farm. The document\n\nGREENBELT FEB 2024 Reg18-Dec-HELAA-Spreadsheet-1 (1)\n\nnotes ‘surface flooding’. That is extremely obvious at the time of writing! If this land is not used for housing, it can protect local houses from the misery of flooding, and could also be managed as a specialised wildlife habitat. This would enhance both its biodiversity and recreation values!\n\nSUMMARY \nThe very narrow greenbelt south of Up Hatherley Way in Cheltenham is so heavily used for recreation, rich in biodiversity and liable to flooding that it should remain and be enhanced as greenbelt, however strong the pressures from potential developers. No one can ‘offset’ or ‘recreate’ what is here already! It must not be destroyed.\n\n\n\n\n"]
[null,null,null,null,null,null,null,null,null,"Current Building Regs. are not up to the standard required for developments like this. All properties should have green energy systems which are built-in by the developers as part of the contract. Planting of trees and hedgerows should take place before the development actually starts. Corridors of planting should be linked throughout the proposed sites to form wildlife corridors.",null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"[Q.8] Net Gain should be 20% as so far every new development in this area has added nothing tangible to biodiversity."]
[null,null,null,null,null,null,null,null,null,"To effectively support our vital climate change goals no developments can realistically happen on green belt and/or green field spaces. Any existing green space around the three councils must be preserved and enhanced to meet the climate change challenges we face. Building more houses is only a sustainable policy if done on brownfield sites, whilst protecting green spaces and increasing re-wilding."]
[null,null,null,null,null,null,null,null,null,null,"All parking surfaces should be permeable for private housing and for public or commercial facilities. Road surfaces should also not be impermeable","All parking surfaces should be permeable for private housing and for public or commercial facilities. Road surfaces should also not be impermeable"]
[null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"Hi Team, whilst we must accept that there is a need for housing within the Gloucester, Tewkesbury & Cheltenham triangle we must continue to preserve the Green Belt area so that each town/city preserves it's own integrity and identity.\nWhilst there is, without doubt, small pockets of land within the hamlets in the green belt that could sustain small numbers of new build housing, if we allow a 4000 house new town in Boddington, it would effectively create an urban sprawl similar to Bristol by joining all 3 Towns together. \nIs this the grand plan or is the suggested Boddington scenario simply commercially driven because of the 1,200 acre ownership by a major developer currently being farmed as Boddington Estates?\nThere are already  plans to build 1,300 houses between Hayden and Springbank across towards GCHQ which is all on greenfield sites of which 800 or so fall within the Boddington Parish boundary but still retains the green belt buffer. \nWe should treasure rural areas like Boddington and ensure that we preserve for our future generations to enjoy both as residents and as visitors.   "]
[null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"1. The SLP as it stands is woefully inadequate in terms of sustainable Transport policy, particularly on rail and is not in accordance with the national Climate Change Emergency agenda. Rail services are not even mentioned in “Scenario 6: Sustainable transport scenario,” and the important role they can play in new developments and transport that delivers modal change from the car.\n\n2. There is a need for the SLP to continue route safeguarding of the former Cheltenham-Honeybourne-Stratford railway, including the safeguarding the Racecourse deviation, linking Cheltenham Racecourse with the Network Rail mainline, in the vicinity of Swindon Lane and the potential development of a Strategic Park and Ride facility at the existing Cheltenham Racecourse station – attached plan.\n\n3. Such safeguarding would be in accordance with NPPF, December 2023, para 110.c) on route protection of former rail lines, the Gloucestershire Local Transport Plan, 2020 and the Gloucestershire Rail Investment Strategy, March 2020.\n\n4. It is not without significance, the 28 mile Cheltenham - Stratford railway has been protected for reinstatement as a railway, in the Local Plans of Stratford, Wychavon, Cotswold, Tewkesbury and Cheltenham Local Plans, since 1992. Restoration of the railway is also supported in the Gloucestershire Local Transport Plan 4 and the Worcestershire LTP3. Of the original 28 miles, 18 have now been reinstated for rail use. Restoration of the railway throughout should not be lost sight of. It is therefore important that this policy approach is continued in the SLP, to ensure consistency in planning policy on the 28 mile rail corridor and the Racecourse deviation protected.\n\n5. Restoration of the original route to south of the Racecourse to Cheltenham Lansdown Station is highly unlikely in view of the numerous breaches of the trackbed. The original safeguarding was in the context of a Light Rail Scheme that never happened and which did not take into account the vertical alignment and levels necessary to restore a heavy rail connection. \n6.  Gloucestershire’s Local Transport Plan, 2015-41, 2020, Policy PD5.2 aim:-\n\n    • “Work with the rail industry, local authorities and other stakeholders to consider the reinstatement of the rail link between Honeybourne and Stratford on Avon.”\n\n    • It also seeks to ‘Improve connectivity Interchange Hubs,’ in which  \n                “Moreton in Marsh could be regarded as Gloucestershire’s gateway\n                 to the cyber hub from the north east and vice versa for the Growth\n                 Arc from the west. This allows the potential for the station with its \n                 connections to London and Oxford to become a major interchange\n                 hub for sustainable travel. Rail station improvements will help \n                 encourage much needed mode change on the A429 corridor.\n\n7.  Gloucestershire Rail Investment Strategy, March 2020\n\nThe Gloucestershire Rail Investment Strategy was published March 2020 - link below, and identifies a potential Cardiff/Bristol-Cheltenham-Stratford-Nottingham service.\n\nhttps://www.gloucestershire.gov.uk/media/2096940/gloucestershire-rail-strategy.pdf\n\n\n\n8. A report ‘Missing Main Lines’, April 2021, Greenguage21, identified three Missing Main Lines That Could Be Re-Opened:-\n\n“The first of these is the line from Stratford upon Avon to Cheltenham via Honeybourne. The report authors say that the loss of this connection as a useful diversionary route is a critical factor in the case for its re-instatement. We agree. and alongside linkages between Oxford and Stratford upon Avon (of great value to tourism flows), there is the ability to re-create a linkage from Cheltenham to Stratford and on into Birmingham’s Moor Street – which is set to become a new rail hub, alongside Curzon Street HS2 station.”\n\n               http://www.greengauge21.net/missing-main-lines/  \n\n\n9. A High Court judgement in 2002, Mansard County Homes v Surrey Heath Council case, confirmed that local authorities can protect rail lines even if no immediate rail use is identified, as long as this policy is defined in Local Plan.\n\n\n\n10.  Air Quality\n\nThe Government has a 2050 target, to reduce emissions by 80%. That was agreed by MPs under the Climate Change Act in 2008, and now amended to the new, much tougher, goal. Poor air quality is a major influence on public health, causing particular problems for those with respiratory illnesses and cardio-respiratory conditions. Road transport is responsible for 80% of Nitrogen Dioxide emissions, while rail accounts for just 1.6%. NO2 emissions also account for 29,000 premature UK deaths pa.\n\nRoad traffic currently accounts for 72% of total greenhouse gas (GHG) emissions from transport (73% of passenger-kilometres), aviation accounts for 14% (8% of passenger-kilometres), and rail accounts for less than 1% (6% of passenger-kilometres).2\n\n11. 2024 marks the 30th anniversary of the landmark, DfT- SACTRA report, December 1994. This concluded that after 40 years of building roads to meet demand was a failed policy. \n\nWhen a new road is built, new traffic will quickly fill it up. Some will be diverted from other roads, but many people will make trips they would otherwise not make, and will travel longer distances just because of the presence of the new road. \n\nThis well-known and long-established effect is known as ‘induced traffic’. Induced traffic means that the predicted congestion benefits of a new road are very quickly eroded. \n\nTraffic on bypassed roads often also rises faster than expected, all of which means the promised congestion benefits of a new road can evaporate very quickly\n\n*The Standing Advisory Committee on Trunk Road Assessment (SACTRA) is an independent committee appointed by the Secretary of State for Transport to advise on issues related to the appraisal of trunk roads.\n\n\n\n\n"]
[null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,null,"[Q.29] The scenario to maintain the green belt seems the most relevant way forward. Without the green belt north of Cheltenham, the town will merge with Bishop's Cleeve.\nThe idea of linking development with lines of public transport sounds appealing, but none of the local authorities involved in this exercise would be able to induce service providers to invest in the necessary infrastructure."]

{"sheet":"In Person Events","index":2,"n_rows":410,"n_cols":3,"rows_kept":410,"cut":false,"hidden":false,"merged":[]}
["Which board was the comment placed on?","Which event was the comment left at?","Comment"]
["Climate Change","Unknown","All homes to be net zero include heat pumps and solar panels from the start"]
["Climate Change","Churchdown","Use proposed land for development to install solar panels"]
["Climate Change","Unknown","Agree - solar panels for newbuilds and large businesses"]
["Climate Change","Unknown","Increase insentives for road works etc to be finished quicker. With road works being longer, congestions also lasts longer = higher pollution. "]
["Climate Change","Unknown","Plant more trees and section off areas of land as protected areas for animals and plants"]
["Climate Change","Unknown","Recycling of surface water in new homes for washing etc. Integrated transport infrastructure. Requirements on developers."]
["Climate Change","Unknown","Climate change will always happen. Long term records show we do NOT HAVE A PROBLEM"]
["Climate Change","Unknown","Zero carbon housing essential"]
["Climate Change","Unknown","Support wind farms - Cleeve would be ideal"]
["Climate Change","Unknown","Put turbines on the encampment. Can be sensitively sited!"]
["Climate Change","Unknown","Solar panels on new houses (retrofitting to existing houses is much more cumbersome and expensive)"]
["Climate Change","Unknown","Any new houses should be carbon neutral"]
["Climate Change","Unknown","Any developments should include a robust plan of how the buildings will be sustainable ie solar panels grey water tanks etc. "]
["Climate Change","Unknown","Link Retail with transport - public and individual"]
["Climate Change","Unknown","Retrofitting of older homes to be efficient housing stock - need a policy for this."]
["Climate Change","Churchdown","Officers to go out with someone disabled to gain understanding"]
["Climate Change","Churchdown","additional traffic overload, travelling to schools out of town and to ameneties outside of town"]
["Climate Change","Churchdown","NO more houses in churchdown. Consideration of volume of traffic. School traffic congestion. Multiple - shops, post office, schools, doctors surgery, dentist. Recreation. Biodiversity - wildlife being removed from habitat."]
["Climate Change","Churchdown","NO MORE CARS 1000 houses = 2000 more cars at least. AIR POLLUTION"]
["Climate Change","Churchdown","New primary and secondary schools required - so many housing estates already being built - where will these children go? If no new schools supplied they will have to travel - adding to car congestion. Churchdown is already gridlocked between 3-3.30!"]
["Climate Change","Churchdown","Any house built should BY LAW have solar panels and heat pumps installed. Houses only to be built on brownfield sites. "]
["Climate Change","Churchdown","All new houses to have solar panels"]
["Climate Change","Churchdown","Ability to travel to work with low emissions. Weekend travel can be tricky - infrequent buses "]
["Climate Change","Churchdown","We have to use our car if there are no buses! Solar panels are too expensive to install and most existing houses can't have radiators / piping for heat pumps put in - what to do?"]
["Climate Change","Churchdown","Protect AONB SCT sites one have recently won appeal for pods at Littleworth"]
["Climate Change","Churchdown","Flood risk at Churchdown if fields build on - all drainage goes down Brook at White House Farm"]
["Climate Change","Churchdown","Catchment area for schools reduced so children go to their local school and can WALK! (as in Edinburgh)"]
["Climate Change","Unknown","Create guidance on retrofitting for older homes and also policy in SP"]
["Climate Change","Cheltenham 1","Preserve our rural lanscapes!"]
["Climate Change","Gloucester 2","15 minute neighbourhoods"]
["Climate Change","Gloucester 1","All new builds to have solar included as standard"]
["Climate Change","Cheltenham 2","The area has a pathetic number of EV charging stations. Consideration of a 10 fold increase should be forced. "]
["Climate Change","Cheltenham 2","Support projects that help build community resilience and food autonomy. - think climate change adaptation! (it's too late for combating anyway)"]
["Climate Change","Unknown","re-use and refurb all empty buildings rather than demolish. Start here rather than new build"]
["Climate Change","Gloucester 1","Panic! Hydroelectrics. Solar on new homes. "]
["Climate Change","Gloucester 2","Wind turbine energy"]
["Climate Change","Winchcombe","Essential to incorporate air source and other zero carbon measures into all new development. Why are we not doing this?"]
["Climate Change","Cheltenham 2","41 cycling lane is a nightmare (Northway - Beckford). Flooding is a real issue in TBC. Need more joined up cycling infrastructure."]
["Climate Change","Winchcombe","This is the stuff that really matters"]
["Climate Change","Tewkesbury","Require builders to conform to net zero / passivhaus. Much easier to install from new rather than retrofit. Also, they can command higher sales value. Developers were geared up to work to net zero in 2015 before tories scrapped it. "]
["Climate Change","Gloucester 2","Offer free collection of old fridges to avoid f-gas pollution in poorer areas"]
["Climate Change","Gloucester 2","Grey water reuse"]
["Climate Change","Gloucester 2","Don’t allow building on flood prone land!"]
["Climate Change","Cheltenham 1","Rewilding issues with development - tree planting"]
["Climate Change","Cheltenham 2","more segregated cycle lanes!"]
["Climate Change","Gloucester 2","Educate re the harm of backyard fires, esp in poorer areas"]
["Climate Change","Gloucester 2","More bus services esp to rural areas (like 'Robin' service in the forest)"]
["Climate Change","Gloucester 2","Education via plaques when parts of the park are left to wild - to explain the good idea / benefits to avoid criticism"]
["Climate Change","Gloucester 2","Make food waste bins compulsory and educate how to use benefit to cut down methane"]
["Climate Change","Gloucester 2","Build on brownfield first"]
["Climate Change","Gloucester 2","Green walls on buildings. More plants in urban areas"]
["Climate Change","Gloucester 2","Removal of permitted development rights are a barrier to home owners installing energy measures e.g. charging points and solar panels"]
["Climate Change","Gloucester 2","more tree planting. Wildflowers / more diverse fauna and flora. Wind turbines on unused fields."]
["Climate Change","Gloucester 1","Solar panels on the fields - give the soil a rest!"]
["Climate Change","Gloucester 2","More outdoor activities for young people to do - get them outdoors"]
["Climate Change","Cheltenham 2","10 minute cities. No cars in the city centre. cycle lanes stopping cars first! solar panels"]
["Climate Change","Cheltenham 1","Source local materials for area"]
["Climate Change","Gloucester 1","Partner with charities such as N ational Trust for key advice and support"]
["Climate Change","Cheltenham 1","Install solar panels on new builds"]
["Climate Change","Gloucester 2","Manage food waste"]
["Climate Change","Gloucester 1","Don't build on green sites. Don't build on floodplains"]
["Climate Change","Gloucester 1","More trees!"]
["Climate Change","Cheltenham 2","Plant trees!!"]
["Climate Change","Cheltenham 1","Cycling infrastructure. Parking - reduce parking, not forward thinking, need strategic vision"]
["Climate Change","Cheltenham 1","Listed Buildings - allow double glazing. Planning unhelpful. Sustainable transport #6 link to rural areas. Second homes."]
["Climate Change","Cheltenham 1","Cycle paths. Reused materials. Rewilding areas within the new developments. "]
["Climate Change","Cheltenham 2","Evening service is needed for Leckhampton"]
["Climate Change","Cheltenham 1","Where possible, retrofit housing with solar panels and electric car charging points "]
["Climate Change","Cheltenham 1","River Severn - power from tidal"]
["Climate Change","Cheltenham 1","Solar panels on BUS STOPS"]
["Climate Change","Cheltenham 1","Attenuation ponds to be standard in new developments to help prevent flooding"]
["Climate Change","Cheltenham 2","Need two bus wheelchair spaces on a bus and also coaches"]
["How should we plan for future communities and business?","Gloucester 2","More re-use of upper floor living Oxbode for example a prime candidate"]
["How should we plan for future communities and business?","Cheltenham 2","Yellow lines provided in the area of GCHQ"]
["How should we plan for future communities and business?","Cheltenham 1","Combine 3 authorities planning responsibility"]
["How should we plan for future communities and business?","Cheltenham 1","Strategic planning should include local services to reduce transport congestion"]
["How should we plan for future communities and business?","Cheltenham 1","Visitor economy transport. Transport post 6pm. Kidnappers Lane shops, where do people get things from"]
["How should we plan for future communities and business?","Cheltenham 1","No informal football space within housing remove 'no ball games' signs"]
["How should we plan for future communities and business?","Cheltenham 1","Refugees"]
["How should we plan for future communities and business?","Cheltenham 1","Bus services that run during evenings from Leckhampton. Latest bus is 6:30. Barrier to evening activities in town centre - theatre / restaurants etc"]
["How should we plan for future communities and business?","Cheltenham 1","Better decisioned estates for general living"]
["How should we plan for future communities and business?","Cheltenham 1","More GP facilities"]
["How should we plan for future communities and business?","Cheltenham 1","Improve existing stock, lower high street Chelt, Barton Road area Glos"]
["How should we plan for future communities and business?","Cheltenham 1","Highnam does not have the infrastructure / school capcity to support further random development"]
["How should we plan for future communities and business?","Cheltenham 1","Reopen shop mobility store. Focus on accesible shops. Improve roads etc for accessibility"]
["How should we plan for future communities and business?","Cheltenham 1","Cheltenham Gloucester and Tewkesbury town centres are all declining "]
["How should we plan for future communities and business?","Cheltenham 1","Cheltenham - street cleaning. Traffic warden are a plague. Parking charges ridiculous. Cav house. Multi use."]
["How should we plan for future communities and business?","Cheltenham 1","New housing developments need to have attenuation ponds as standard"]
["How should we plan for future communities and business?","Cheltenham 1","Decent public transport. People need to get into towns / villages. Free parking - missing a trick. "]
["How should we plan for future communities and business?","Cheltenham 1","Declining high streets, Tewkesbury losing it's place"]
["How should we plan for future communities and business?","Cheltenham 1","Identify areas for larger business premesis"]
["How should we plan for future communities and business?","Cheltenham 1","More care homes for young disabled people. Not enough supply. Homes are not fit for purpose - need independent care with access to support. Linked to Leonard Cheshire - can site be improved? Opportunity for redevelopemtn? To meet diabled indepdendent needs. "]
["How should we plan for future communities and business?","Cheltenham 1","Quality of highways. Poor quality pavements impacts on accessibility for disabled people: a particular issue on minor roads. Issue is exacerbated when there yeah it's my microphone is poor lighting."]
["How should we plan for future communities and business?","Cheltenham 2","Lack of infrastructure cycle lane between CBC and GCC is a waste of money over looking at Golden Valley Golden Valley is a waste of money"]
["How should we plan for future communities and business?","Cheltenham 2","Park and ride really useful - encouraging people to visit town and city centres - works really well for Cheltenham"]
["How should we plan for future communities and business?","Cheltenham 2","Build on some green belt - not enough brown field sites to build on"]
["How should we plan for future communities and business?","Cheltenham 2","More homes for single young men - they are often forgotten"]
["How should we plan for future communities and business?","Cheltenham 2","The jobs aren't here to sustain this amount of house building "]
["How should we plan for future communities and business?","Cheltenham 2","Leonard Cheshire bungalows - care provided. Need more"]
["How should we plan for future communities and business?","Cheltenham 2","No major development between A46 Brockworth and Cheltenham - impacts on traffic flow"]
["How should we plan for future communities and business?","Cheltenham 2","Get cars out of cities"]
["How should we plan for future communities and business?","Cheltenham 2","Concerns about impact of population on schools. Increasing need for SEN"]
["How should we plan for future communities and business?","Cheltenham 2","Need to build more affordable homes - young people have very few achievable realistic housing options"]
["How should we plan for future communities and business?","Cheltenham 2","Pavements in Chelt town centre and Glos city centre poor for disabled people e.g. potholes "]
["How should we plan for future communities and business?","Cheltenham 2","New independent shops"]
["How should we plan for future communities and business?","Cheltenham 2","Different types of housing types etc. More youth engagement. Link in with sciences and schools e.g. around floodplains. Engage with ICB!"]
["How should we plan for future communities and business?","Cheltenham 2","Gloucester city centre often feels unsafe - make it feel safer"]
["How should we plan for future communities and business?","Cheltenham 2","Consider the need for tiny homes"]
["How should we plan for future communities and business?","Cheltenham 2","Concerns about impact of population on hospitals including waiting list"]
["How should we plan for future communities and business?","Cheltenham 2","Bus passes - disabled but work full time - unable to use before 9:30. Improve bus links to all towns. "]
["How should we plan for future communities and business?","Cheltenham 2","10 min cities!"]
["How should we plan for future communities and business?","Cheltenham 2","Infrastucture is poor quality particularly roads and needs to be redone soon after"]
["How should we plan for future communities and business?","Cheltenham 2","Better facilities for young disabled people. More accessible built environment for young people"]
["How should we plan for future communities and business?","Cheltenham 2","Cap on holiday homes, possibly increase council tax on these, this way go some way to reducing holiday homes and freeing up properties for families"]
["How should we plan for future communities and business?","Cheltenham 2","Not how many in total, but planning needs to be broken down into what sort of housing, social housing, and rental needs to be included"]
["How should we plan for future communities and business?","Cheltenham 2","Not enough schools, will it affect kids getting into school, kids going out of area for school acceptance?"]
["How should we plan for future communities and business?","Cheltenham 2","Older residents -more schools?"]
["How should we plan for future communities and business?","Cheltenham 2","Winchcombe - people want to stop in town centre but they can't stop - poor parking (except library). Narrow highway can create"]
["How should we plan for future communities and business?","Cheltenham 2","Cheaper homes for younger people. Nursery places to support economy"]
["How should we plan for future communities and business?","Cheltenham 2","Investigate opportunities for reusing empty / vacant town / city buildings for residential / mixed use, this will support vitality of centres"]
["How should we plan for future communities and business?","Cheltenham 2","More public toilets - have to use pub toilets. Chelt town centre need regeneration. Youth club for young people"]
["How should we plan for future communities and business?","Cheltenham 2","Blocks of flats are too small - need to have more bedrooms. Generally poor quality and need to do maintenance soon after they're finshed. "]
["How should we plan for future communities and business?","Cheltenham 2","Very few affordable housing"]
["How should we plan for future communities and business?","Gloucester 2","Improve city centre living and redevelop brownfield sites first rather than urban edge"]
["How should we plan for future communities and business?","Gloucester 2","Compulsory purchase of derelict office buildings for housing"]
["How should we plan for future communities and business?","Gloucester 2","Utilise public transport - build flats without parking in city"]
["How should we plan for future communities and business?","Gloucester 2","Create cycle lanes to improve safety and create connectivity"]
["How should we plan for future communities and business?","Gloucester 2","Offer smaller houses - many built by housing developers are too big"]
["How should we plan for future communities and business?","Gloucester 2","Stipulate low carbon new builds - low use of cement - no ensuite bathrooms - hot water solar panel"]
["How should we plan for future communities and business?","Gloucester 2","Stipulate green buffer of trees around new / converted buildings to reduce air pollution for residents"]
["How should we plan for future communities and business?","Gloucester 2","Maintain existing cycleways"]
["How should we plan for future communities and business?","Gloucester 2","Education - schools, capacity is full - this needs to be considered pre new houses!"]
["How should we plan for future communities and business?","Winchcombe","Need another Doctors surgery (and school??)"]
["How should we plan for future communities and business?","Winchcombe","A shopping area (and transport to it)"]
["How should we plan for future communities and business?","Winchcombe","Winchcombe needs more care home provision and sheltered accomodation for the eldery / disabled"]
["How should we plan for future communities and business?","Churchdown","Linkage to promoted walking routes for enjoyments and wellbeing of residents. Green and well drained paths, not tarmac or hoggin."]
["How should we plan for future communities and business?","Churchdown","If Glos Airport site is sold and developed, what will happen the related employers - only employment opportunity in Churchdown"]
["How should we plan for future communities and business?","Churchdown","You cannot continue to build homes without an increase in infrastructure, especiialy schools and doctors surgery. Churchdown has had their fair share already"]
["How should we plan for future communities and business?","Churchdown","Build modestly-priced family houses. Semi detached (I live in one) are a better use of space than detached houses one metre apart!"]
["How should we plan for future communities and business?","Churchdown","Make care homes intergenerational. Units for young and old, some social eating places mixed."]
["How should we plan for future communities and business?","Churchdown","Natural green space. Connectivity for walking and cycling."]
["How should we plan for future communities and business?","Churchdown","Allocate sites for community-led housing schemes. More for not-for-profit!"]
["How should we plan for future communities and business?","Churchdown","Any development must not be driven by speculatory house build. Greed!"]
["How should we plan for future communities and business?","Churchdown","Whatever the end result it will need huge investment in health facilities, education, roads and public transport."]
["How should we plan for future communities and business?","Churchdown","If development proceeds, consider reducing number of houses AKA concrete jungle"]
["How should we plan for future communities and business?","Churchdown","Healthcare: as a priority needs to be considered. GP surgery, dentistry. Demand is at full capacity now!"]
["How should we plan for future communities and business?","Churchdown","We can't cope with another 1000 little boxes. Proper family houses with productive gardens and solar panels on every roof as standard, and 1000 is far too many."]
["How should we plan for future communities and business?","Cheltenham 2","More affordable homes for families and older fragile people. Less executive development"]
["How should we plan for future communities and business?","Cheltenham 2","New builds, poorly built (Persimmon)"]
["How should we plan for future communities and business?","Cheltenham 2","Utility companies coordinating re work"]
["How should we plan for future communities and business?","Cheltenham 2","New homes need infrastructure"]
["How should we plan for future communities and business?","Cheltenham 2","Glos city centre needs tidying up. Better variety of shops."]
["How should we plan for future communities and business?","Cheltenham 2","Encourage people to shop in Gloucester (and Chelt) to encourage people to shop"]
["How should we plan for future communities and business?","Cheltenham 2","5000 children come out of schools in Churchdown between 3pm and 3.30pm. This area is already overcrowded, schools, medical practise in crisis'"]
["How should we plan for future communities and business?","Cheltenham 2","More flats and small houses."]
["How should we plan for future communities and business?","Cheltenham 2","More affordable homes!"]
["How should we plan for future communities and business?","Cheltenham 2","Build more houses!"]
["How should we plan for future communities and business?","Cheltenham 2","Withdrawn bus service (E bus). Need public transport in Saint Marks. High percentage of people disabled or elderly."]
["How should we plan for future communities and business?","Cheltenham 2","All new builds area in developments have to build GPS, schools as part of plan."]
["How should we plan for future communities and business?","Cheltenham 2","New cycle lane too wide near Gloucester airport. Dangerous and affects traffic flow."]
["How should we plan for future communities and business?","Cheltenham 2","Disabled facilities need to be open for longer e.g. Brewery Quarter toilets close at 6:00 PM. Indoor facilities are better for disabled people i.e. warm and dry. Regents Arcade good, Brewery Quarter bad."]
["How should we plan for future communities and business?","Gloucester 1","Balance between local and town centre. Close to services new homes within walking distance to city centre. Build to rent. More private in city centre. "]
["How should we plan for future communities and business?","Gloucester 1","Affordable housing investment into small businesses / start ups"]
["How should we plan for future communities and business?","Gloucester 1","Repair road surfaces before spending money on cycle paths. Consider existing area and surroundings before building mass high density housing. Build housing to blend in with a county area"]
["How should we plan for future communities and business?","Gloucester 1","Key worker housing in city centre and great western housing "]
["How should we plan for future communities and business?","Gloucester 1","Flyovers Elmbridge Court. Dual carriage A40 to Oxford border"]
["How should we plan for future communities and business?","Gloucester 1","Negative attitudes of Glos City residents bringing it down - it's a great place be more positive"]
["How should we plan for future communities and business?","Gloucester 1","Gloucester is good for Brownfield sites, convert more old office blocks into flats for single people or elderly"]
["How should we plan for future communities and business?","Gloucester 1","Less affordbale and negotiate more key worker - could help save NHS!"]
["How should we plan for future communities and business?","Gloucester 1","Transport (more problems) in and out"]
["How should we plan for future communities and business?","Gloucester 1","Training idiots to work"]
["How should we plan for future communities and business?","Gloucester 1","Build back-to-back houses rather than flats which are not suitable for people with children"]
["How should we plan for future communities and business?","Gloucester 2","Support independent shops"]
["How should we plan for future communities and business?","Gloucester 2","Create better signage and links from Docks to city centre / cathedral"]
["How should we plan for future communities and business?","Gloucester 2","Food security - organic farming. Sustainable sewage reuse. Community allotments. "]
["How should we plan for future communities and business?","Gloucester 2","Whatever you build in Churchdown, you must build schools to accommodate the children, there just isn't enough room in Churchdown for more cars. "]
["How should we plan for future communities and business?","Gloucester 2","Introduce a rent table - reducing price per m2 for rent to keep rents affordable"]
["How should we plan for future communities and business?","Gloucester 2","car charging pools in every new estate"]
["How should we plan for future communities and business?","Gloucester 2","Plan built environment that supports mental health and wellbeing"]
["How should we plan for future communities and business?","Gloucester 2","Every new housing development to be incorporated in bus routes and with local shops and surgeries"]
["How should we plan for future communities and business?","Gloucester 2","Building new homes on factories and industrial sites"]
["How should we plan for future communities and business?","Gloucester 2","More social housing - affordable and secure"]
["How should we plan for future communities and business?","Gloucester 2","Limit number of supermarkets and encourage cornershops instead - more money stays locally"]
["How should we plan for future communities and business?","Gloucester 2","More pelican and zebra crossings"]
["Nature","Churchdown","Essential that brownfield is used first"]
["Nature","Churchdown","Wildlife should be a huge consideration"]
["Nature","Churchdown","Where can the dog walkers go when they close the main dog walking site in Churchdown village?"]
["Nature","Churchdown","Traffic is already bad around Zoons Farm duel carriageway (ten pin bowling) More house would add to this problem"]
["Nature","Churchdown","Where are human values in all these bricks?"]
["Nature","Churchdown","Plant more hedgrows. Look after exising hedgerows"]
["Nature","Churchdown","Ensure ditches alongside footpaths and camber for drainage to avoid standing water. May need stone sub and herbs on top."]
["Nature","Churchdown","Human identity is lost in concrete and anonymity"]
["Nature","Churchdown","Knife crime occurs predominantly in cities NOT the countryside. Do we want more of it?"]
["Nature","Churchdown","Outdoor space to be able to walk and enjoy the nature. Benefits everyones mental health."]
["Nature","Churchdown","Retain green walking routes to access the countryside from residential areas. Segregate walking and cycling."]
["Nature","Churchdown","Review houses built against local fields to assess success e.g. have they sold"]
["Nature","Churchdown","View from hills"]
["Nature","Churchdown","Nature must be protected! No building on farmland or green areas. "]
["Nature","Churchdown","Protect Chosen Hill, Zoons Farm development would be damaging for wildlife and for local family who walk around. This area is prone to flooding. "]
["Nature","Churchdown","Wildlife!"]
["Nature","Churchdown","Where are all the people thought to need all these new houses? - not local people!"]
["Nature","Churchdown","Wildlife, deer on the hill, greenbelt, where do they go - extinct!"]
["Nature","Churchdown","Provide green infrastructure requirement for developments. People need to be able to access nature"]
["Nature","Cheltenham 1","Rural and agricultural landscapes must NOT be lost to housing developments"]
["Nature","Cheltenham 2","Important area for nature - Dark Lane, Swindon Village field runs from allotments - otter, deer, muntjack, badgers, red kites"]
["Nature","Cheltenham 2","Land used for agriculture and not more houses"]
["Nature","Cheltenham 2","Create community orchards / edible woodlands "]
["Nature","Cheltenham 1","No building on more greenbelt and fields"]
["Nature","Cheltenham 2","Protect forests, review green belt - build some homes!"]
["Nature","Gloucester 2","More rewilding, less felling of trees or replacing those urban trees that were recently felled or died of lack of water"]
["Nature","Gloucester 2","Protect the green belt around Gloucester (Matson / Tuffley / Longlevens / between town and Maisemore / Tewkesbury Road. "]
["Nature","Cheltenham 1","Litter picking stations - people can use a litter picker to clear up any rubbish while they are out for a walk and can then organise it at set recycling points located around the park."]
["Nature","Cheltenham 1","Increased biodiversity in parks - wildflowers for bees etc. Habitats made for foxes. Litter picking days!"]
["Nature","Cheltenham 2","We are changing - we need to think and embrace change!"]
["Nature","Gloucester 2","More long - term planning for plants in Gloucester Park - at the moment much is being ripped out after a year. "]
["Nature","Gloucester 2","Parks and open spaces at the top of the buildings"]
["Nature","Gloucester 2","More greening up of city centre - walks of buildings, rooftops and planting"]
["Nature","Cheltenham 2","Development doesn't include enough green infrastructure lack of connectivity between green spaces - corridor - importance for wildlife"]
["Nature","Gloucester 1","Creating green corridors and linking up spaces. Make more of the canal and riverside in Gloucester"]
["Nature","Winchcombe","In Winchcombe absolutely NO more large scale building on greenfield AONB"]
["Nature","Winchcombe","Ensure new houses follow green and carbon neutral guidelines. Ensure suitable drainage and sewage infrastructure"]
["Nature","Cheltenham 2","All the woodlands around Cheltenham need to be protected - and more trees planted. Also the River Chelt should be opened up and made more visible and accesible wherever possible. "]
["Nature","Cheltenham 2","All mature trees in and around town need to be protected with TPOs. Farmers need to be encouraged and incentivised to use regenerative farming techniques and bring wildlife back onto their land. "]
["Nature","Cheltenham 2","All new development decisions ought to be made based on the questions: Does it support nature? Does it build community? (If not then the development should not go ahead!)"]
["Nature","Gloucester 1","Wardens, policing allotments"]
["Nature","Cheltenham 2","Build on brownfield sites and refurbish derelict buildings. Don't build on the greenfields!"]
["Nature","Gloucester 1","Cooperation, coworking, with community"]
["Nature","Churchdown","Use brownfield sites!!"]
["Nature","Churchdown","Large green spaces are needed by young and old people and all those in between"]
["Nature","Churchdown","A sense of community cannot be generated in large connerbations. We need to care for eachother"]
["Nature","Churchdown","Preserve agricultural land. Too much local farmland already dissappeared. "]
["Nature","Churchdown","Environment and biodiversity is critical for future generations"]
["Nature","Churchdown","Ancient woodland up Chosen Hill. Development around Churchdown will enclose the hill which is a really special place for many people"]
["Nature","Churchdown","Skylarks nest on proposed development area on Churchdown Hill - how will they be protected?"]
["Nature","Churchdown","Mental health - we need large areas of open green spaces for good mental health"]
["Nature","Churchdown","Building housing etc on brownland / land that isn't tampered with already. These greenfields are important to both physical and mental health."]
["Nature","Churchdown","We need to know our neighbours and share values. Impossible in isolation"]
["Nature","Churchdown","To be able to enjoy open space and nature. Help with your mental health. Have areas to enjoy the wildlife and walk"]
["Nature","Churchdown","Life in concrete and motor fumes is not an attractive prospect. "]
["Nature","Churchdown","Area of large biodiversity - newts, woodpeckers, badgers, skylarks, deer, foxes, grass snakes, adders. These will be greatly affected by habitat loss and increased traffic and human activity. "]
["Nature","Churchdown","Protect Churchdown Hill. "]
["Nature","Churchdown","Planning needs to be enforced. Too many people building and moving onto protected sites without plans approved. "]
["Nature","Churchdown","Can our wildlife survive on a housing estate? Any schools dr's, dentist, playgrounds, other amenities planned? Ca"]
["Nature","Churchdown","Another doctors! Surgery in Churchdown!! If all these new houses keep appearing!"]
["Nature","Churchdown","Keep greenbelt wildlife habitat must be preserved, deer, foxes, badgers, need their habitat. "]
["Nature","Churchdown","How does building yet more houses protect the environment? Use brownfield sites for houses - not more Aldi and other supermarkets. This area is saturated with houses on farmland and we are fed up with it. "]
["Nature","Churchdown","Public rights of way must be protected and where diversion is needed through development areas, more 'green' routes should created. Don't allow diversion along estate roads / footways. "]
["Nature","Churchdown","What an excellent idea! Ditto"]
["Nature","Churchdown","Protect our open spaces - more trees / plants "]
["Nature","Churchdown","Additional allotments a community space to grow food. Current waitlist is 3 years for allotment in Cheltenham."]
["Scenario 1","Gloucester 1","first option housing re purposes"]
["Scenario 1","Tewkesbury","Tewkesbury town has several potential sites for more reuse housing - healing's mill, spring gardens, quay Street. "]
["Scenario 1","Cheltenham 1","essential "]
["Scenario 1","Tewkesbury","just develop glos and Chelt and sensitive Greenbelt and limited for Tewkesbury sprawl "]
["Scenario 1","Cheltenham 2","focus on infrastructure needs to be in place before we build"]
["Scenario 1","Gloucester 1","ideally reuse existing buildings wherever possible. Built flats and two-bedroom homes not all three and four bedrooms and don't build on floodplains"]
["Scenario 1","Gloucester 1","lots more council housing. Use brownfield sites. Use empty buildings in city and town centres for housing. 15 minute city! Build medium rise housing, not detached executive homes. "]
["Scenario 1","Cheltenham 2","building on floodplains continues - this must be stopped!"]
["Scenario 1","Cheltenham 2","there is no demand for all of these additional houses. Central government has no idea, house building is all profit driven"]
["Scenario 1","Tewkesbury","high density housing can be good but needs good soundproofing and good management of communal areas"]
["Scenario 1","Cheltenham 1","mixed-use development will be most efficient! "]
["Scenario 1","Cheltenham 1","YES - transport links already here "]
["Scenario 1","Cheltenham 1",1.1000000000000001]
["Scenario 1","Cheltenham 1","reuse empty shops for housing "]
["Scenario 1","Cheltenham 1","high density is most efficient for infrastructure! "]
["Scenario 1","Gloucester 1","urban sprawl - no thank you! "]
["Scenario 1","Cheltenham 1","better than in rural locations as already near facilities "]
["Scenario 1","Cheltenham 1","do not develop on floodplain zones: keep floodplains undeveloped "]
["Scenario 1","Cheltenham 2","consider using retail parks for housing (build on top of) "]
["Scenario 1","Cheltenham 1","Use brownfield land, and derelict buildings, there are plenty in Gloucester and Cheltenham. "]
["Scenario 1","Cheltenham 2","car parking spaces too small for size of vehicles "]
["Scenario 1","Gloucester 1","build and convert existing buildings first "]
["Scenario 1","Cheltenham 2","houses built are too large 4 bed etc need smaller homes to meet affordable need "]
["Scenario 1","Cheltenham 1","thought to be given to infrastructure and development, roads, schools, shops, doctors, dentists, pharmacy. Developers to be more accountable "]
["Scenario 1","Cheltenham 2","maximise brownfield used for houses "]
["Scenario 1","Cheltenham 2","build more small houses "]
["Scenario 1","Cheltenham 1","definitely use brownfield sites as opposed to destroying the Greenbelt. Look at the mess in leckhampton off kidnappers lane. "]
["Scenario 1","Churchdown","bring back town planning: need to keep existing towns vibrant and relevant"]
["Scenario 1","Churchdown","please think about the infrastructure. Can it cope? Building on infills is OK."]
["Scenario 1","Churchdown","brownfield first! "]
["Scenario 1","Churchdown","should be a priority even if more costly to build"]
["Scenario 1","Churchdown","ensure walking routes in place for urban residents to reach green space"]
["Scenario 1","Churchdown","not enough infrastructure to support extra housing in church down"]
["Scenario 1","Unknown","Maintenance. Tidy, community centre in employment hub, think 70s, first aid training, playgroups"]
["Scenario 1","Unknown","New line worried about so many houses and our infrastructure not coping (doctors, schools etc) need more smaller houses for young people to get on the housing market. Present new builds seem so big."]
["Scenario 1","Unknown","Empty offices and shops in town centres should be repurposed to provide attractive housing, minimal commuting and rejuvenation of town centres"]
["Scenario 1","Unknown","Build only what is needed"]
["Scenario 1","Unknown","Look at brownfield EG Gloucester. Empty cities need social housing in the centre, use old retail."]
["Scenario 1","Unknown","Re purpose redundant and derelict buildings in town and city centres! "]
["Scenario 1","Churchdown","consider area around current parks for housing EG land between railway bridge and winchcombe off Broadway Rd"]
["Scenario 1","Churchdown","proposed for 1000 plus homes near the M5. Problems: Lack of infrastructure, medical centre required, junior and senior school required, major road changes. "]
["Scenario 1","Churchdown","use brownfield sites first "]
["Scenario 1","Churchdown","our towns and villages are getting too joined up EG bishops Cleeve and gotherington "]
["Scenario 1","Churchdown","infrastructure and local needs to be planned for alongside any new development. winchcombe is struggling: doctors, school, roads. "]
["Scenario 1","Churchdown","Don't need more houses as plenty already"]
["Scenario 2","Cheltenham 2","stop putting buildings in the floodplains!"]
["Scenario 2","Cheltenham 2","glos airport! Huge development opportunity: ‘elephant in the room’ why can't we explore this for sustainable development for housing and employment etc"]
["Scenario 2","Cheltenham 2","walked from elmstone Hardwicke - Swindon village footpaths - all flooded at present - this will be Elms park development! "]
["Scenario 2","Cheltenham 2","Elms park development- already parcels of land are being developed piece meal around the area and Swindon village - why? Won't Elms park deliver enough?! "]
["Scenario 2","Churchdown","consider reopening stations such as church town train station to help service the increase in population. Most work or commute to Cheltenham and Gloucester centres"]
["Scenario 2","Unknown","No more building on green spaces. Churchdown's infrastructure is at capacity: the roads cannot cope: getting out of Churchdown takes 20 to 30 minutes in the morning now. "]
["Scenario 2","Unknown","Supporting congestion: church down is already gridlock in the morning and afternoon "]
["Scenario 2","Unknown","regulate multi home ownership"]
["Scenario 2","Unknown","Use urban sites. Please no more houses on green spaces. "]
["Scenario 2","Unknown","We need more and better public transport already without extra housing "]
["Scenario 2","Unknown","redevelop St. John's shops. "]
["Scenario 2","Unknown","pressure on all services schools hospitals roads dentists shops etc"]
["Scenario 2","Unknown","more bungalows "]
["Scenario 2","Unknown","stop second homes! No building on Greenfield sites until there are no brownfield sites to be used for house building and no houses kept empty. Revive town centres by putting in houses and flats. "]
["Scenario 3","Gloucester 1","Definitely not!"]
["Scenario 3","Cheltenham 1","Yes, this will utilise existing brownfield sites and produce additional transport congestion"]
["Scenario 3","Cheltenham 1","Will cause significant additional traffic jams to the B4215 newent Rd and A40 to over roundabout"]
["Scenario 3","Cheltenham 1","definitely not a40 / B4215 already too busy with cars. Infrastructure not here IE schools and doctors"]
["Scenario 3","Churchdown","No chance of doctors appointment as it is"]
["Scenario 3","Churchdown","traffic will be horrific"]
["Scenario 3","Churchdown","Noise, pollution, this is overkill"]
["Scenario 3","Churchdown","government need to revisit the requirement is building new houses actually the answer to the root cause?"]
["Scenario 3","Churchdown","If new houses / development proceeds... consider reducing number of houses AKA... concrete jungle!!"]
["Scenario 3","Churchdown","Need a sensible bus service to doctors from lower churchdown (for older people)."]
["Scenario 3","Churchdown","please use brownfield site worry about farmland and food production"]
["Scenario 3","Churchdown","Urban sprawl traffic needs to be considered"]
["Scenario 3","Churchdown","review crime (much isn't reported). Patterns with those living in locality. Is vandalism caused through boredom. Youth need to live where their facilities are and to be able to walk to those facilities."]
["Scenario 4","Cheltenham 1","Development must be purposeful and accessible"]
["Scenario 4","Cheltenham 2","Green Belt protection, if possible"]
["Scenario 4","Cheltenham 2","New towns - infrastructure embedded - local centres on every corner. Milton Keynes"]
["Scenario 4","Tewkesbury","A new settlement with proper infrastructure could work - but must be on frequent bus route and housing types to encourage home working, artists and crafts and enterprise"]
["Scenario 4","Gloucester 2","Do not build in Flood Zones"]
["Scenario 4","Churchdown","Yes, the new towns have been a success. But where and needs infrastructure"]
["Scenario 4","Churchdown","Ensure airport protected so no building houses on it in the future"]
["Scenario 4","Churchdown","Build two new self contained settlements with schools doctors etc. At junction 9. And on airport site if for sale."]
["Scenario 4","Churchdown","Too many unsold houses already"]
["Scenario 4","Churchdown","NO we need farms for food security"]
["Scenario 4","Churchdown","may be necessary to prevent existing urban settlements becoming too large"]
["Scenario 4","Churchdown","develop brownfield sites before Greenbelt!"]
["Scenario 4","Churchdown","Try to utilise and enhance existing city, town and village centres rather than develop new ones"]
["Scenario 4","Churchdown","Greenbelt must be protected for the sake of nature and to soak up rainfall and alleviate chances of flooding"]
["Scenario 4","Churchdown","too many airbnbs not enough rentals"]
["Scenario 4","Churchdown","don't compromise Greenbelt but identify business expansion space options"]
["Scenario 4","Churchdown","no houses on Greenbelt protect our open spaces"]
["Scenario 4","Churchdown","initial data is required on the number of second homes and holiday let's in winchcombe. Especially in the centre. These need to be affordable and rentable to locals before building additional properties"]
["Scenario 4","Churchdown","Please protect Greenbelt"]
["Scenario 4","Churchdown","Churchdown Oldbury orchard to M5 is Iron Age village and old pastureland"]
["Scenario 4","Churchdown","no more houses in church down"]
["Scenario 4","Churchdown","it should be compulsory that no Greenbelt is built on and brownfield should be explored in the first instance"]
["Scenario 4","Churchdown","No to Greenbelt save the wildlife"]
["Scenario 4","Churchdown","Protect our green spaces and also our airport - no building near there"]
["Scenario 4","Churchdown","lack of infrastructure for additional homes. EG Postal Service overload, GP surgery, schools, supermarket, roads overloaded on narrow through centre"]
["Scenario 4","Gloucester 1","stop lying about building horrible housing then building new large houses 1st to get more profit"]
["Scenario 4","Gloucester 1","last resort easy money machine for developers - here here!!"]
["Scenario 4","Gloucester 1","Definitely not!"]
["Scenario 4","Gloucester 1","Use brown belt before green"]
["Scenario 5","Churchdown","Use brownfield sites and not greenbelt land"]
["Scenario 5","Churchdown","Needs better public transport and services"]
["Scenario 5","Churchdown","Should be a last resort, ideally no!"]
["Scenario 5","Churchdown","Over populated. Limited access routes. Not enough facilities - will these be increased? Is it essential? Extra houses in the country. Is it over building. Greenland"]
["Scenario 5","Churchdown","Lack of integrated public transport"]
["Scenario 5","Churchdown","Green areas are essential for good mental health, especially in young people post-covid. Too many housing estates contain very little green area / natural habitats"]
["Scenario 5","Churchdown","Merging Gloucester Churchdown Cheltenham into one urban area will destroy communities"]
["Scenario 5","Churchdown","More frequent buses to locations out of Cheltenham and Gloucester. (More buses is a relatively quick win for climate change)"]
["Scenario 5","Churchdown","Increase council tax on second homes"]
["Scenario 5","Churchdown","Protect the green belt first before building "]
["Scenario 5","Cheltenham 1","Not too spread out covering a large area"]
["Scenario 5","Winchcombe","Improve bus services to rural communities - last bus from Cheltenham to Winchcombe 6pm?"]
["Scenario 5","Cheltenham 1","Purely car-centric will not work"]
["Scenario 5","Cheltenham 1","NO Rural infrastructure NOT there roads already too busy"]
["Scenario 5","Cheltenham 2","Rural dispersal isn't a good idea - too car reliant. There are no services to sustain this type of development"]
["Scenario 5","Cheltenham 2","Use the greenbelt to build on"]
["Scenario 5","Gloucester 1","Definitely not!"]
["Scenario 5","Gloucester 1","Increase village sizes to support primary schools"]
["Scenario 5","Gloucester 1","Last resort housing. Vetting tenants 4 transport needs and schools"]
["Scenario 5","Tewkesbury","Greenbelt between Chelt and Glos could be developed at a low and wooded density"]
["Scenario 5","Tewkesbury","Limited rural dispersal if facilities are also built so current residents can see the benefits"]
["Scenario 5","Winchcombe","Crucial to allow the national landscape areas to maintain local facilities and a diverse population"]
["Scenario 5","Tewkesbury","Risk of overdeveloping a large rural area"]
["Scenario 6","Cheltenham 1","don't do this! Infrastructure won't handle it"]
["Scenario 6","Cheltenham 1","this incentive needs to be incorporated into all scenarios"]
["Scenario 6","Cheltenham 1","hold ups on A40 / B4215 already too frequent"]
["Scenario 6","Cheltenham 2","Are there opportunities to explore sustainable transport corridors from Gloucester City to Tewkesbury? This seems focused on Cheltenham to Gloucester City corridor"]
["Scenario 6","Cheltenham 2","Cycle lanes poorly designed impact the main part of the road"]
["Scenario 6","Cheltenham 2","mass transport trains trams buses"]
["Scenario 6","Cheltenham 2","restore bus services to reduce car use less congestion and pollution"]
["Scenario 6","Cheltenham 2","why did the railway corridors get built on in Cheltenham and Charlton kings? future transport short sighted"]
["Scenario 6","Winchcombe","Is the most important option low carbon travel is essential"]
["Scenario 6","Winchcombe","Would need public transport & mobile services to support this kind of development"]
["Scenario 6","Winchcombe","Better reliable public transport services between towns such as winchcombe and larger town centres including Tewkesbury"]
["Scenario 6","Winchcombe","lack of public transport no buses to doctors in Winchcombe"]
["Scenario 6","Winchcombe","94 service improved but so hard for drivers with the new cycle path we should be encouraging people to use buses to avoid car use"]
["Scenario 6","Winchcombe","direct public transport provision to Tewksbury including ash church railway station from Winchcombe"]
["Scenario 6","Winchcombe","definitely, but need to ensure not linear development like 1930s - maybe local hubs on route - new villages?"]
["Scenario 6","Gloucester 2","About time houses were built at staverton airport"]
["Scenario 6","Gloucester 2","prioritise walking and cycling possibility of mass transit tram"]
["Scenario 6","Tewkesbury","More trains stopping at ash church"]
["Scenario 6","Tewkesbury","all service villages to have a bus service-  e.g. twyning - and off road cycle ways to twyning"]
["Scenario 6","Tewkesbury","Yes to this - a protected cycle route from Tewkesbury town centre to Gloucester and Cheltenham and then linking to Stroud and Bristol"]
["Scenario 6","Gloucester 1","All towns should be park and ride!"]
["Scenario 6","Gloucester 1","Possibility of a tram system? Especially as Cheltenham and Gloucester become better connected and developed"]
["Scenario 6","Gloucester 1","Kingsway train station"]
["Scenario 6","Churchdown","Far too many houses being built"]
["Scenario 6","Churchdown","Cycle lanes are dangerous if on the main Rd"]
["Scenario 6","Churchdown","Open up train station at church down again!"]
["Scenario 6","Churchdown","Schools bursting at the seams now doctors surgery 2 enough is enough two roads out of church down chaos!!"]
["Scenario 6","Churchdown","Speeding and traffic volume issue on Evesham Rd. No pavements or lighting and lack of speed signage. Increase in housing will add to this pressure"]
["Scenario 6","Churchdown","not enough infrastructure to support more houses. Doctor surgery already way overstretched. Also many more cars to add to congestion and air pollution. Schools already full churchdown down M5"]
["Scenario 6","Churchdown","church down is already overdeveloped. Cheek spree boris seems to be receiving more than its share. Floodplains infrastructure doctors schools traffic"]
["Scenario 6","Churchdown","please save our airport and surrounding area"]
["Scenario 6","Cheltenham 1","Better connectivity in terms of improved connections from ashchurch station to town centre locations"]
["Scenario 6","Cheltenham 1","Need better public transport and more reliable"]
["Scenario 6","Cheltenham 1","yes but not enough"]
["Scenario 6","Churchdown","Churchdown roads already busy at peak times, any further build needs Rd over structure"]

{"sheet":"Young People","index":3,"n_rows":167,"n_cols":8,"rows_kept":167,"cut":false,"hidden":false,"merged":[]}
["When we’re building houses, flats, roads and buildings for business activities eg offices, supermarkets, warehouses – known as development - how/what would you like us to think about in terms of the climate* and/or nature*?","Thinking about what you do every day, what services would you like to see where you live? ","If you could have services within walking distance of your home, what would they be?","Thinking about yourself and the people you know - your family, friends, neighbours, fellow students and work colleagues - what sort of different housing options/homes do you think we need to include? ","Thinking about yourself and the people you know - your family, friends, neighbours, fellow students and work colleagues - what sort of different jobs/employment do you think we should be trying to bring into the area? ","Imagine you were a business owner - what do you think we can do to encourage businesses/other organisations to base themselves in Cheltenham, Gloucester or Tewkesbury?","Based on where you live or have lived, what do you think makes a city, town or village centres a great place to live or visit. You can include things that are not great too.","Based on the answer above and your own experiences of growing up so far, what do we need to think about so that places and communities can change and adapt with the people who live in them – us! "]
["Choosing the most sustainable options when selecting the materials, maintaining green spaces, inflicting the least amount of pressure on the surrounding wildlife during construction. ","Transport options (e.g. bus stops etc.), supermarkets, waste management, local healthcare facilities, designated green spaces (e.g. parks with benches, bins, toilets etc.),","Walk to = small shops, green spaces (parks), pharmacy/doctors surgery, school.\nOther means = supermarket, hospitals.","Flats for young people moving into independent housing for the first time as well as flats/bungalows for older people with more reliable incomes and previous experience in the housing market; space to park cars. Also housing for elderly people with a lift/close to public transport and shops as well as housing that is disability friendly.","","","Multiple supermarkets nearby, strong transport links to other cities, good range of retail stores, nearby hospital, public toilets, council that is quick at fixing facilities/listens to opinions of public.","All housing should be disability friendly so anyone can live there, houses need spaces for car parking and electric car chargers. Places need nearby bus stops as well as green spaces that are accessible for all, as well as enclosed so people can walk dogs etc."]
["Not care about it, humanity before nature","Food","I want bus and road","Flat for old people","Cyber","Get the corpos out","Do something about knives","Make them like lego, expandable house"]
["build it far away from any civilisation","open area/farms/lakes/forest","city/town","wood cabins","people need jobs that will not be taken over by future AI","show amount of profit that is possible to recieve if they were based there","get the crackheads out of town","build a place for them to go so they dont bother normal people"]
["I dont care about the climate make the most damaging house i dont care i will not consider climate change when purchasing or renting a house ","maccies kfc burger king costa corner shop or supermarket near by public transport parks for kids parks for dogs entertainment things","park maccies shops town chippy","big not expensive rent ","maccies offices schools ","advertisment","NOTHING GLOUCESTER IS BAD","yea"]
["BOTH","uni,college,mc-donalds shops park","walking\n","flat home","shop employment","develop organise","quicker faster","work together."]
["the information of misleading nature","supermakets bus stop","school ","where there is big spaces","costomer","IHKL","family",""]
["","car parking space, double toilets, big garden","close to the train or bus station,","cheap houses with double toilets and an eco friendly area","carers. doctors, engineers","cheap houses and more facilities such as park","the cool weather and the eco friendly area",""]
["think about the climate and nature","park","get the bus to go to school","bigger houses with more room","idk","gloucester, more houses","city, more shops","idk"]
["","grocery stores","20mins","modern and antigue","more flower shops","","quite and calm town is better to live. its more peaceful",""]
["take care of the climate.","park","get the bus to go to school","modern houses\n","idk\n","more supplies","idk",""]
["Not really relevant","Shopping centres/supermarkets and things like Costas and Subways","Walk to things like town and cinemas but things like factories and museums could be further away","Houses and Flats or maybe shared apartments for student accommodations ","Engineering centres and Hospitals/Clinics","Put the business in a large open space where its easily accesible to the public and then advertise the company and how its hiring employees","Great-lots of opportunities and things to do\nNot so great-homelessness and traffic/noise","Make places for homeless people like dedicated homeless shelters and fewer hostile architecture"]
["more garden space and parks with trees","more shops where you dont have to drive and you can just walk to","places that sell objects and not food such as furniture shops and Currys","my neighbourhood has more children and families so there should be modern flats and 4 bedroom houses or 3 bedroom houses\n","places where you can get work experience that that are close","more houses attract more people to add traction to businesses\n","things that are great is the community and how the place is kept, i mostly find this is the city centres","more clubs or community areas or buildings"]
["i dont think we should really consider the climate as there are more people than houses so we need the houses more than we need to worry about the climate","hospital","i would like to be able to walk to the shops","i think there needs to be more single room houses for students to live in and stay for cheap\n","i think we need more jobs in healthcare and teaching to teach people how to get the jobs","put posters around","shops town school ",""]
["Build a big garage \nUse as much space as you can ","Needs a shop and a car park","Things like museum,shopping hall and cinema hall etc","Modern type houses and apartments","Business\n","Have the ability to build the business near the city or where people would mostly would be.","It is a great place to live because of the opportunities\nnoises and traffics are not great at all","people could of course leads to a happy and healthy life\n"]
["you can be more careful and mindful with the enviroment and take more precautions","a local shop and services easy accsess","10 mins away from school or to walk","bigger rooms more rooms ","bank hospital","a shop a family can run to pay rent or fast food resturants ig","clean enviroment","no danger near them and a safe clean enviroment"]
["you should think about all of the animals habitats and the climate as animals    should live as well as us and don't cut down any trees YOU SHOULD THINK ABOUT ALL NATURE AND ANIMALS ","shops/supermarkets and other essential services","yes depends how lazy and tired i am that day","small and big houses that are affordable for everyone ","easy jobs that you can do part time ","make it more eco-friendly and easier for people to set up biussnes ","interesting activities to do for all different age ranges to do",""]
["in terms of nature you could add flower patches and trees aswell as recycling bins if there arent any already. you could also include boxes of bird feed or insect houses. restoring houses could also be an option","fish and chip shop, mcdonalds or a burger king","i would like to be able to walk to a co-op or bus stop","my sister is currently a single mum and unable to find housing so maybe family safe housing rather than flats could be a good idea","able to start a business (empty buildings to buy)","building empty buildings to be able to create shops, cafes or hair salons","fish and chip shops are good","?"]
["If that person or people want to live somewhere but as a result you have to break a climate or nature maybe suggest somewhere else instead","easier access to local shops and have mini markets sparsely spread out around the area","shops","explain how rent and mortgages actually work instead of letting them figure it out themselves. suggest a cheaper option to homeless,students or younger people to a more affordable place to live","i think the amount of workers is ok","give a healthy and enjoyable workplace","the culture","give more modern housing and help non English speakers/homeless or not as wealthy people with accessing services"]
["i would like the house/flat to be near local food places and shops as it makes peoples life easier.I dont mind on the impact on climate","i would like to see local corner shops,takeaways,and grocery shops","i would like to walk to get food but not for more than 30 minitues ","in a house theree should be 2 bathrooms around 5 rooms a fairly big living room ","easier jobs should be introduced for example takeaways as it would be easy for a student to get a part time job\n","making the surroundings better/cleaner would convince a buisssness owner to base themselves there\n","having a clean surrounding like roads and streets","i think think that the roads and streets should be clean and therve should be plaes to go to for people to hsve fun"]
["Try to make the houses eco friendly with tecnology or any other way","mosques or any other religious praying areas","i would like to walk to mosque and shops to get essentials i would travel by car or even walking","cheap houses so people can afford.","more healthcare related jobs.","tell them all the positive impacts that could be possible","shops are everywhere which are good for people to get anyhting.","encourage buisnesses to make shops in places that doesnt have a lot of shops"]
["the people and what they want e.g pools","big companies and hospitals and biiiig school","walk for about 15 minutes","around 3 bedroom houses with a bathroom in all the rooms and like a basement and an attic and a flat roof in which you can sunbathe and like have a space for visitors at the top\n","medicine and working from home and like teaching and working in offices","to make the bussiness taxes lower and more affordable","big buildings","no smoking zones for people who dont want to smoke\n"]
["To create a bigger landscape that can be seen from the house and can be used for walks but also not too far from shops and city centres.","The beauty of nature aswell as the busy city.","Infrastructure put in place to reach leisure activities but not straight through nature grounds.","Very modern with no old or historic features or houses that are original from a while back. Also some people would rather nature and the city more than another.","Small capable jobs so people can save up from a younger age.","Land is essential to build on but leave some behind for decorative ideas or just a view. ","Having a place to meet up and spend time with friends and families and also to buy essential as well as anything for a gift or to make ourselves happy.","Have warm spaces like the ewe space near matson shops and the redwell centre for children and adults that give many experiences and even to just get out and socialise. I think they should also give more support to places like these because they help a lot of people."]
["It's inevitable, to not harm nature without building over it. There may be solutions to this although they'll only be short-term solutions. Eventually, we will have to build over any available land to provide a home for everyone.","Shops for everyday needs, nice fields and bike paths, chippy.","I'd want to travel for things like mot, getting something fixed, buying furniture or an oven, etc.","Simplistic, modern and hygienic. It may not be a person's preference, though they can always go to a company which specialises in customising the kitchen and house, and for people who rent and do not have the permission to modify what they've been provided with, it shouldn't matter as it keeps them alive, not everything needs to be pretty, there are more important things.","","","",""]
["I don't know but to have a house near nature would be cool ","A park, small shops nearby","Walk to shops for small shopping","I don't know but housing for elderly","Jobs that pay well that are near house ","I don't know never thought of owning one","That most of my friends/family live near and having places to meet up with friends","I don't know "]
["You should stop destroying animal life.","Cheap, easy, acessesable food and other things","shops,parks, bus stops\n","Enough bedrooms and space for bigger families,big gardens for animals like dogs or birds, houses with extra rooms as more people are starting to have carrers from online instead of in a work place.","jobs that allow ppl to work from home.\n","by encouragining them\n","civilisation, animals, things to do.","Kid friendly areas,,...."]
["Eco friendly  and close to shops as well as being close to services such as medical help and police authority","services such as shops   and bus stops","shops and medical  help or police authourity","houses sutable for bid families ","Hospitals and police authourity","donate money and invest into local buisnesses ","neighbours to socialise with and a positive society","think about how it impacts people mentally and socialy "]
["We should leave wild-life spaces alone, because animals deserve space too and theyre cuter then us, anyway. ","A diverse range of shops and shops.","I wouldnt mind walking anywhere unless my feet are sore, so I dont really care. ","Large gardens for animals because they are better and need space and time for them to relax because they already do so much for us and we need to respect and honour them more, as of right now, they are treated badly by people who should love and care for them such as not allowing them time outside which they require to be healthy, and happy creatures. Animals deserve the world, and it starts by giving them space to be themseleves.","Hair and makeup, because its pretty.","I wouldnt do that, im sorry. ","Animals being allowed to roam free, happily and safely, and them having pet-services. Because, like i said before animals deserve peace and freedom in exchange for the joy and thrill they fill us with every day of their short lives, which is sad, because animals dont live as long as us, and they should fix that instead of employing unsuitable people for jobs they dont deserve e.g  animal abusers; they dont deserve happiness, why are you hurting poor helpless animals ? Are you heartless ?",""]
["Not cutting down any trees and build houses in flat areas ","Some corner shops","I would like to be able to walk","I think there should be more bedrooms and the rents should be cheap and need to have more parking spaces with a garage","shop workers and health care services\n","It should be modern","",""]
["Build the houses away from the natural life and modernise the old areas","Few corner shops not too many and near to the towns","I would like to have trums in our town.","Their needs to be more houses with front parking.","","we need more modern town with more jobs to attract tourists","large shopping centres","less houses near town because there will be less traffic"]
["i think that new houses should not be built on areas of nature such as habitats, forests, wildlife, farms, or areas of agriculture of nature. i also think we should make the houses less dependent on fuels such as putting more solar panels on houses and making them eco- friendly.","less areas like dumping spots in random corners","in 30 minutes or less id like to be able to walk to he shop and be able to get basic food supplies such as water/milk, snacks, fruit/vegetables and hygiene supplies eg. soap, period products products, deoderant, toothpaste.","i think we need to build more one story houses for people with mobility issues that struggle to get up the stairs, and houses with more bedrooms for bigger families. ","i think we should bring in more jobs concerning the care of the enviroment and jobs to rescue/ protect young children and animals that have been inured or abandoned ","advertisements and promoting buisneses that will benefit the community and the enviroment.","close shops, safer streets, and more security.","we need to think about where we build because we need to protect the wildlife and nature."]
["","shops","bus station","big houses","","","",""]
["be ecofriendly","","","tall skyscraper good view of the city and a big bucane  and with a nice brize of air a sun light   a swinging pool and have a good life near hospitals shops and other  buildings  and with a football ground and a grill at the bucane  thats all l think\n","","a big building for more workers to walk big bullet glasses to see  the view and for sun light many facilities for workers  to rest or have a couple of coffe after work  and a big offece for the ceo and a nice view of nature trees and buildings","my house is a flate it has a good view a nice garden but lackes hight to have a good view good sun light after waking up a nice garden play some games and drinking some coffen with a great view",""]
["think about if any animals live there or something yeah safe 1","i would need a tesco for shopping a pub for eating and a car park for my car and like a nature place","i would like to walk to the shop, the pub and the car park. i would get in my car to go to currys pc world","i think my community would like massive villas with 5 swimming pools, 26 bedrooms, 46 bathrooms, 12 kitchens, 10 tennis courts and 3 football pitches that would be lush","full time jobs nearer to my crib so i can get to work easier","cheap land and less rent","yes they are really cool and interesting","think about all the happy people living in houses"]
["Eco friendly, by making sure you plant another plant when you cut one \n","bus","school=walk\nshopping =car","A multipurpose able building","easy and payable","by posters","dog poo in walk way","counselling"]
["make bricks made out of recycled carbon dioxide","sports track, football pitches, parks, open field.","walk to parks, football pitches and sprint tracks.\ntrain to big cities like London, Manchester and Birmingham.\nMore shops for sports.\nSport direct near me.\nJD near me.","a strong house made completely from brick and not wood.\nWarm housing.\nmultiple floors.\nbig backyard area to play sports.\nMore trees and plants around the house.\nIndoor sprint tracks, outdoor sprint tracks.","sports coaches, physiotherapists.\nSport trainer.\nGarden maintainance.\nBus drivers.\nSprint coaches.","Clean the city, the city is too dirty and rough.\nMore investment opportunities (more businesses located in gloucester).\nMore sport opportunities.","Clean environment.\nVast green areas.\nMore sports tracks.","Listen to more young people and their ideas.\nEnsure more police are employed so we all feel safe.\nBUILD MORE SPRINT TRACKS!"]
["I think making sure that all new buildings are properly insulated to reduce the need of running heating as much and adding solar panels where possible to reduce the need on using the grid which would reduce emissions. I don't think we should worry about reducing the emissions when building yet. However I would ask to make sure that the materials used are of a decent - high quality where possible. That would allow the buildings to last longer and make potholes in roads take longer to form.   \n\nI do think it be nice to make sure in major builds some green spaces are added. Not only would that help nature, with places for birds to nest for example, but also mental health. A small park or path with trees, benches and flowers would do.","","A supermarket to essentials during the week, a doctors and a larger green space like a park. A pub for food and drink would be good aswell ","houses and flats to buy are the most important for the people I know. Everyone I know don't want to pay rent but to buy the place they live. In most areas now it feels like renting is costing as much as a mortgage and are willing to live at parent's place or house share, even when they don't want to, in order to save for a mortgage. ","Mid to high skill jobs, like engineering / factory working and IT/software roles. I feel like people my age don't see a lot of higher skill jobs for them, or they think they have to stay at lower skilled / paid roles like retail. Having more skilled jobs around would 100% push people to consider retraining to do it. ","Clean up the general area, like the town center and house the current homelessness. I feel like showing businesses that the area is tidy would consider the area a more professional place to set up shop.  Creating more events that bring in people from outside the area could help aswell, The victorian fair and the retro car show is a hit most years for example, more things like that. A food store would be more likely to open a shop in town if more people go to town, but they need a reason to go to the town center. ","",""]
["Make sure pleasant greenery is included in plans and reduce building footprints to maximise public space and open areas.","collections of shops","mixed shops","small townhouses in areas without large amounts of traffic.","Engineering and design","better connected industrial/ retail areas with reliable public transport\n","In Leckhampton there is bath road which has its own set of shops separate from the town centre. This makes it easy to do shopping without having to take the car. The town centre is a good place to live as it is well connected to other areas by bus and is easily walkable.","places need to be flexible. Places with just housing estates feel unwelcoming as there is no reason to visit other than to go to houses. Places feel more welcoming when there is a community centre."]
["Landscape led design","Accessible public toilets; safe and well designed bus stops","Local convenience stores; well designed and accessible bus stops","Mixed tenure: homes need to be built better and to be more affordable ","Research and younger people professional training programmes ","","",""]
["Keep green spaces","More cafes","Small businesses","Small neighbourhoods for families","","Make the spaces available for cheap","Friendly sit-in restaurants",""]
["Don’t cut down trees, bushes to make room for unnecessary development. Included benefits for nature in the new developments, wild areas, hedgehog highways, ponds etc","More skateparks, hub for young people to do activities, sports clubs etc","Skatepark, gym, swimming pool ","Bigger houses with more space, garden, driveway etc","More sports jobs, more active outdoor jobs","","Enough locally to keep occupied, spaces to go with friends, outdoor spaces for activity or exercise. Being separate from a big town or city","More things for young people. "]
["I get worried about building on flood plains a lot, and whether this is being properly mitigated, especially in terms of whether building on food plains means it will worsen flooding in the area.\n\nI also would really like to see more nature corridors, public parks, wildflower verges, trees and fruit trees and such - areas where we can allow plants, insects and animals to thrive around and within developed areas. \n\nI would also like to see more developments with solar panels, heat pumps and proper insulation. ","I am someone who gets the bus regularly to work, but I find my job opportunities and leisure activities limited by where I can get to by bus. I would like to see more regular public transport and public transport which covers a wider range of areas.","I would have a library, a public park and a doctor’s surgery within walking distance of my house. Also a post office.","I think housing for families is important but maybe flats for single people and couples. As a young person myself, who has lived outside of home and moved back in to my parents house, it would be nice to see more options with younger people in mind. I think it would be nice to have some high-density flats or housing, like a block of flats, near to some shops and local businesses, and public services like GP, library, post office. ","I think we have a lot of hospitality jobs in the area, and while more bars and restaurants are nice to have I would like to see other things prioritised. I would like to see more public service or local government jobs, or more green jobs brought into the area. I would also like to see more creative type jobs brought into the area through things like creative agencies.","","I have lived in Churchdown all of my life, but briefly moved to Bristol for a few years for University. The thing I loved about Bristol in comparison to Churchdown was how easy it was to get places in everyday life via bus or just walking. Most of the shops I needed were within walking distance. Furthermore, it was very easy to go out and meet up with friends because we all lived in the same area and there were lots of things like bars and restaurants within walking distance. Churchdown is a great place because I love how green it is. I see a greater variety of animal and bird species, and I love to see all the new plant growth in spring. However, I feel more limited in terms of travel and what sort of places I can access in terms of finding employment or meeting friends without a car.","I would like to see greater public transport infrastructure and a focus on creating higher density neighbourhoods with more public services and leisure activities like restaurants within walking distance. I would also like to see less emphasis on cars, such as drive-throughs, etc. I would like to see more public parks and nature corridors, and I would like to see an emphasis on accommodating nature in new developments."]
["Consider implementing nature based solutions, sustainable building materials, plant trees, have solar planners on all new houses. ","Shops, refill shop, bus stop, cafe","Shop, bus stop, cafe ","None","Ecology jobs","Small business loan ","Regular bus services, independent cafes and shops. Parks and green spaces","More independent businesses "]
["To make sure growth helps and doesn't harm the climate and nature, businesses should use eco-friendly practices like renewable energy, reducing waste, and protecting natural resources. They can also support efforts to conserve wildlife and plant trees. These actions help the environment while allowing businesses to keep growing.","I would say seeing more access to higher luxury stores that can provide us with more to see and more to look up to in a way","shopping centres, with clothes shops","More apartments, there is alot of homeless people and if we had apartments built there would be more places within peoples budgets to live.","More than shop assistant jobs, if the council gave people jobs to clean up on the streets and start tidying our city that would be a good start","Giving people more hope by doing what I said in the last question will inspire more businesses to be built.","Bringing people together, hosting a gathering and now everyone is socializing and if they show up they get a discount to macdonalds or something like that.","Make people understand there is more out there, alot of people are small minded and its not there fault if you really want to make an impact show them there is more to this city."]
["Look out for wild life and distribution of waste","More youth clubs , more places for people to socialise in general","Youth centre and music / performance space ","Affordable, accessible and supportive ","Youth run services , community development programs and mentoring programs for youth inspired to develop communities ","Make the leases easier to sign up to and hold events that encourage business to take part for example Christmas market style events ","More activity based events in terms of movement also group / team events","Each month 3 businesses should be highlighted and brought forward for the community to go and visit and as a prerequisite the business should do something special for the community building foundations of truth on both sides "]
["Look out for the wildlife while constructing ","Youth club for children","Youth club","Affordable, accessible and maintained housing ","Youth centre jobs , volunteering and mentors ","Be humble to the workers and make leases easier to sign up to","More outdoor facilities","More place's for kids to go"]
["","Shop, Mechanic, Hairdresser, Petrol Station","Shop","More semi-detached housing","Jobs that bring valuable life skills within them such as working in a bar, restaurant, shop etc. Customer service experience.","Have housing that is suitable walking distance. Have mandatory services in the area. Mention about the community and how great they are supporting local businesses.","The community where everyone knows everyone and people are supporting each other's businesses. Not to great can be crime rate where young guys are harassing people, so there should be a high level of authority to avoid this happening.","Have more community events during holidays where people can come together and connect. Have local sports teams for kids to be able to socialise."]
["Forget ornamental plants, protect soils, no weed killer, no chemicals and grow fruit trees where there are bushes or big areas that pointlessly have just grass, organic fruit and veg in empty areas to nourish our community all round","Organic food for all, supermarkets that are natural and independent","If I have to travel I will, means to be creative, artistic and educated to a high standard of freedom to create.","Eco housing that self rejuvenates just like gardens used as permaculture plots for free food, let's make food free by all having food grown in our gardens or local land surrounding our homes, forest gardens for the community is a must above all other things! If we control our food we control our outcomes.","All things that keep life as a limitless cycle, no one job to become stagnant, just an array of potential jobs that we can roll in to.","We need a morale stance that is based on upon optimal health over business, if we go forward to promote organic food and do It as a charity that doesn't charge an arm and a leg then we can offer food that heals at a cheap price, like effectively bringing in local co-op farms like what Ruskin mill have done to extend the quality of food and at a decreased price because most of the food is grown on site and otherwise they use the local farmers to bring down the costs and as a result you can go to their cafe at get an organic meal for £10 which is cheaper than most non organic cafes! And they don't cut the quality, which is how it should all be, bye to GMO poisonous food and welcome the health of our cities back away from corporate cash cows taking money and jeopardizing our health.","Reform the idea of business to that of quality, purity, creativity and most of all Love and heart to heart hugs so we all see one another as I and I, no disconnection just brothers and sisters as one.","We need to think about what people eat, breathe and see as we all know we are what we eat, breathe and see, so if we eat junk food we will continue, if we watch explicit movie scenes that promote violence we may become it, of we are surrounded by parents who only aspire to be by the TV then those parents become that and so do the children, we need to take back the art of crafts as the art of the heart is the most connective part of being but if we suffice as watchers letting life pass us by we may never do it and that's the issue with life, until we find all youngsters and adults reconnecting to art forms then we hold a nation of lost souls who hold no purpose other than the 9-5 to survive without creation and that is a very sad, dull uneducated world where no one realizes there worth and that is a tragedy that needs to be repaired so we all know our innate purposes."]
["Food security ","Schools and Doctor Surgeries","Bus stops","Affordable and energy efficient. ","Production of goods and support for the community ","Business rates are too high, this is why town and city centres are dying.","Make them safe and inviting. Well Policed, no antisocial behaviour.","We all need to think about others."]
["Don’t make them too tall","Gym","Gym ","More estates","Legal","Notice boards","Friendlier environment","More traffic lights "]
["","","","I think more house shares for students or graduates. Mainly new house shares cause a lot of house shares  end up being in a messy state due to people before or need to be in a more safer spot in Gloucester.","A lot more creative opportunities need to be in the area especially acting. All we have is the theatre in town which isn’t enough and requires actors to have to keep on spending money to go to London for those opportunities. ","Business like Loads Of Talent which is a connecting company for actors. Would be nice if they also had a base in Gloucester. This way young actors can connect with a wide range of actors and meet professionals high up in the industry.","I think what can improve a city/town is when you feel confident walking through places like Barton street or even Gloucester park.","I think most importantly is pushing more against knife crime as that has been a big problem within Gloucestershire. \n\nI think also being able to have more of different events, youth clubs. Encouraging for all communities to mix. I grew up not being around enough of my own culture and I think having these type of things could be very beneficial to the youth growing up so they don’t feel left out. "]
["Use sustainable resources more often, ","Master classes, setup a nice venue where people of higher class can come and pass on their knowledge to the younger generations even if it mean paying a fee for entry.","","Quality houses not like the ones that are currently being built with brick work that’s out more than Pinocchios nose ","Personal trainer, construction, ","Moral support, a lot of people want to open a business but are scared due to the lack of knowledge.. if there was a business centre that people could refer to for help it would be beneficial ","People, people make everything.build a strong educated and welcoming community and the town will evolve naturally,  more entertainment, would help and I don’t mean clubs, but place that people can go to and socialise, and can work on their teamwork skills. Paintball, escape rooms and more",""]
["solar heatings use local produce ","Shops , community centres where all locals could meet, schools, libraries, gyms ,playgrounds","gym , library shops ","","more Career guidance, music jobs entertainment, local people offering apprenticeships in all areas and giving young people a chance to decide and learn what they would be good at .","Hard workers , encouragable , passionate about their workers , think outside the box and want more all the time improving as learning , ","People, people’s opinions good or bad because we can only learn from each other, Beautiful walking parks ,Great community centres,the leaders,the parents","Listen to the younger people "]
["","Retail Parks, Supermarkets, Restaurants","Community Centres","More Apartments","Creative jobs which don’t require years of experience ","The community around Gloucestershire is strong so basing it off that could be beneficial to any business and it’s growth","The togetherness is a massive positive. Also having unique selling points like the cathedral will always catch the attention of tourists","Crime rate has increased massively in the last 5 years in my opinion. Anti social behaviour, Knife crime and more has really been a problem around this area which is holding it back from its full potential "]
["Plant more trees when you cut them down","Arts and crafts places","Art courses ","More mortgage schemes ","Youth workers ","More food places and more events to attract tourists eg music festivals etc ","More shops eg food, clothes, shoes and entertainment. Later closing times, most places close at 5 so if you’re working 9-5 there’s nothing to do after work",""]
["More public transport routes","More Public recovery lounges for athletes","","Apartments/condos ","Mechanic","Flyers/pop up shops","Safety/",""]
["We need to absolutely minimise the need for private motor vehicle ownership. This means building denser developments, building up rather than out and along existing and new public transport corridors.\n\nDevelopment needs to be focused on density. It's more sustainable to run utilities to one central site than run them long distances across sprawl.","Supermarkets, doctor's surgeries, post offices, pharmacies, libraries. Some green spaces as well for recreation.","Everybody should be able to walk to access basic services - healthcare, food and communication (post offices and libraries). I think ideally these should come first.","In Cheltenham, we need to focus on more density and within that density, higher quality homes. A lot of opposition to high-rise living I have heard is about lack of space and lack of privacy. Soundproofing of walls needs to be regulation, and we need to be building apartments for families and not single young people. ","A lot of people want a high degree of flexibility in their work, if they can have it. That means for those that normally do office-based work, a flexible working arrangement meaning they are able to spend a few days at home and use quick and cheap public transport to access the office when it is needed.\n\nIndustrial parks should be converted from a few expensive units to many, small, cheap spaces for startup businesses. This removes a high barrier to entry for those businesses and gives the leg up local people need. For those who need to be at their place of work at all times, providing local nearby spaces they can walk or cycle safely to should be a top priority to reduce car use.","We need to prioritize the growth of small local businesses. This means lots of small, cheap office spaces that can be used for startups of all kinds - small scale manufacturing, cafes, restaurants etc. They should be situated in places that are easy to access via walking and cycling - along existing and new infrastructure.","By far the most important thing to me is the ability to move through your area on foot. If a pedestrian environment is welcoming, you automatically want to be there. The Brewery Quarter in Cheltenham is a great example of a vibrant commercial space that you don't need to drive to in order to access - you can walk from most places in the town or take a bus to a major terminal on the high street.\n\nWe don't see as much pedestrian traffic on the Lower High Street as it's choked with parked cars and traffic, and is in general a dangerous space to be a pedestrian with narrow pathways on either side.","It feels counter intuitive to remove car parking spaces but we need to discourage motor vehicle use and simultaneously promote the use of public transport. Any removal of car parking spaces should be matched with other improvements to make accessing that area easier ie. free buses from the new A40 Park n' Ride to the town centre, dedicated bus right of ways, new protected cycle lanes."]
["Unfortunately, however we build houses it seems inevitable that we’re going to harm nature in some way. Piping cuts through burrows, building impairs their hearing and destroys their homes (ironically) and, however much offsetting we do, there are always a few kilograms of CO2 that we seem unable to iron out. Villages also feel threatened and frequently never know work is going to take place - and only adults are ever consulted. The simplest option would be to just cut out the reasons for building: we don’t really all need one home per two or three people and we could have fewer children. But this doesn’t happen and, if we don’t build more homes, there’s no way we can take in immigrants and homeless people, perpetuating the myth that we don’t, can’t and shouldn’t need them. Here are some suggestions: - We start building homes underground, like in the Hobbit or Bob the Builder. To do this, we would need some way of tracking where animals live and making sure we never build through their homes. - When we build roads, it often means the farmers are forced off their land. Why don’t we build some roads underground as well? Some areas are generally not good for farming and wouldn’t need this. Therefore, it is important that we use materials with ideally zero greenhouse gas emissions, for tunnel walls and tarmac/alternatives. - Similarly, cars only use either side of a lane. Why don’t we put a grass verge in the middle? It would probably turn to mud very quickly, but would save up to a third of the tarmac. - You only get one chance at building a road, so we absolutely must put cycle lanes on both sides, even cul-de-sacs. Just putting them on main roads is a step forwards - and we probably can’t put them on any others because it would cause so much disruption - but when we build new roads, we can’t just expect to find alternatives to cars. - On a similar note, could we introduce tolls for new housing developments if you are using a fossil fuel car? Individual low-emission zones might be impractically small. However, people probably wouldn’t like that. - So make sure there are charging points (and lots of trees) everywhere. If we survive this crisis, I promise you we will thank you for it. Like I said, we only have one chance to build a road, so we can’t undo things built in the wrong place.","Two cafés, a bakery and a bus service.","","","","I’m sorry, why would we want them to do that? Does it bring money into the districts? I want our area to feel special - it is - but having national-level companies base themselves here does not really feel like a priority.","Great things about my village: it has lots of small businesses, which are generally friendly, as long as everyone else. It’s generally navigable, has limited cycle paths and has good bus services. Not great things about my village: one of the students at my school recently said they had received homophobic abuse from students they believed came from a school in my village. I don’t know how we can stop this, but it needs to be urgent. Also, there keep being housing developments which don’t take us into account, which are unfair, plus there’s not enough ethnic and religious diversity. Great things about our city (Gloucester): it has a really interesting history (even if it includes slavery) and a limited number of green spaces. It’s also very diverse. Not great things about our city: the council is building a Forum in the city centre, which I know is well-intentioned, but I personally think looks very strange. Please don’t think this is connected to anything else I write here. There is a lot of homelessness and areas consistently connected with deprivation - and my second-favourite café in the country has announced it is closing.","There’s too much discrimination - because people are female, non-white, L.G.B.T.Q.+, dis- or differently abled, neurodiverse, or anything else. Sometimes it’s for no reason - they’re just different and they don’t like it. Counter-intuitively, the most likely marginalised group to do the discrimination is perhaps non-white boys - precisely because they’re the victims. I think they’re sick of being treated like they’re no one and turn to intolerance to cement their place, but that’s not the way forwards. We have to treat B.I.P.O.C. people like they’re “normal”, or we’ll keep finding “reasons” that they aren’t."]
["Not allow building on the floodplain","More, social housing","Parks and recreation spaces and a regular bus service","Social housing","Jobs that allow us to export into the EU","Provide better support for businesses to export to the EU","Create more green towns","Keep communities separate from each other, rather than one sprawling mass of urban houses"]
["More green space ( small parks or dog walking areas) full with lots of flowers and plants.","I have lots of small shops, bakeries, and takeaways near me as well as lots of parks and even Robinswood hill. There is also direct busses into town.","I have lots of small shops, bakeries, and takeaways near me as well as lots of parks and even Robinswood hill. There is also direct busses into town. ","Small affordable family houses","I think in Gloucester there are a wide range of jobs already","Make places more appealing by picking up rubbish and cleaning","There are plenty of shops which means that if you need something, it is minutes away",""]
["Keep things green, keep trees in the streets and green areas for properties even if they are communal ","","Local shop, gp","Townhouses and flats, rather lice in smaller accommodation and have greater outdoor space ","Greater options for retail, clothing etc ","","Clean, green spaces, great variety of shops and places to eat",""]
["Incorporate green spaces into these areas.","Green spaces and nice parks closer to the centre. These places feel safe and if they are close to shops will become a hop spot for relaxing on your lunch break. Look at Bristols College Green, Castle Park, St Andrews Park, Brandon hill.\n\nIncorporating green spaces that are landscaped properly - and placing these near shops, offices and housing creates social spaces that both draw people into the city, and also give residents a place they can relax.","Intercity Trainline or tram","All types - this depends on space and area.","Cultural and creative opportunities. Creativity makes a place feel safer, more welcoming and also draws others into the city giving it a buzz. We need a cultural hub in Gloucester. This should be surrounded by independent food markets, music venues/hospitality venues but there should be a big push for independent business. The character will get sucked out of the city by any chains.","Gloucester needs financial backing to encourage business as it has been underfunded and forgotten about by the local council. \n\nCreate a cultural quarter specifically for independent business, coffee shops, bars, music venues, thrift shops etc. If there is not space for independent local business the city centre will die. Reach out to local communities and back them financially.","Green spaces. Independent businesses. Cultural quarter.",""]
["","","","","","","having a thriving library is amazing","well kept green spaces, community police presence etc"]
["space for renewable energy and green spaces, trees for air quality and quality of life. ","","GP practice","More affordable ones","hospitatlity is always a good one, more job diversity perhaps","","Things to do and nice spaces, interesting architecture or well planned spaces are always appealing. Limiting driven vehicles around the city centre (like European style) trams and more consistent bike lanes","Good cultural awareness with businesses and activities. Gloucester isn't the most diverse so more effort could be made to bring in more diversity "]
["Ensure sustainability is kept in mind where possible and greenery is planned for. Not only is it good for the environment, green spaces are good for mental well being. ","Supermarket, bank, charity shops, cafes, local businesses","Supermarket ","Homes of 2-4 with green spaces. These seen to be most popular for students","More local/ small businesses ","Make them more happy looking places. Lots of areas are rundown and grey.","I like it when the twin is a nice place to be. Small businesses usually make it nicer with less big marketing and commercially run","Maybe more green spaces or maybe adapting our current green spaces so they can be used more. "]
["Take nature into account and have more green spaces","Shops for food shopping, more free car parking, better transport to Hartpury university","Corner shop, pub, gym","More affordable student housing, more options for 1 student needing to rent on their own, better structured houses to prevent mould","Warehouse work, retail jobs","Incentive to move location (money), advertising of that business so they don’t lose clients during the move","The atmosphere between neighbours, the green spaces are good, parking is an issue","The cost of living, especially as a student "]
["We can check the environmental impact of the specific action that is seen as growth, and then find more sustainable alternatives if it is not already eco-friendly.","","A supermarket.","The option to have solar panels.","I would like to either be a 3D animator or a programmer, both of which I could do at home or in an office. I will need to have an exceptional understanding of computers and maths.","","Being surrounded by nice greenery is essential, such as trees, grass bushes, etc.",""]
["I think its critical that the natural landscape is taken into consideration. Gloucester particularly has beautiful countryside and it is one of the brilliant things about the city that make many people happier to live there. I believe it would be important to think about how to make these buildings co-exist with the nature around the. Use bricks perhaps that look more natural and plan the houses in ways that can incorporate the nature around them as opposed to simply building the houses etc and discarding the natural scenery and eradicating it completely in most cases. ","More local cafes that are family run perhaps, more book shops, more natural parks with ponds, more places for people to do activities - for example more opportunities at community centers to do art classes and pottery.","A café that I could go to with my friends after school and do work in.","I think you need homes that are more individual and unique, also I think you need a few more terraced houses and flats but larger houses as well for larger families with 5-6 bedrooms.","I personally want to become a journalist, there are hardly any job opportunities in that area in Gloucester so I will probably have to move. I know other people wish to become models, artists, photographers, actors, firefighters. I believe that you need to be bringing more creative forms of employment to Gloucester, for instance many of these types of jobs would be easier to achieve if there were the same opportunities as in Gloucester.","Advertise Gloucester better. Clean up the roads and make Gloucester in its poorest areas better - then it might encourage local businesses to set up their organizations as they have more to work with aesthetically.  ","I think having a strong sense of community is important in creating this. I think there could be more festivals and at Christmas maybe a carnival type event that goes all the way through Gloucester where everyone can join in. I also think there could be more Community activities. I think this will all create an increased sense of pride - I know many people are not proud to live in Gloucester and can't wait to leave.","I think its important to remember that some people have lived in the same community all their lives but they are just so bored! I think it's important to remember to bring excitement to these places for all generations and think about the community and break it down into these generations and then target each - think about how to bring the excitement back for each generation."]
["Keep in mind biodiversity and how biological corridors may help for example gardens or even just fields left and not managed to allow a small habitat for animals.","A local shop and a bus route","Shops, buses ","Id like them to look aesthetic for the area as it would create a sense of place rather than just clone towns like Cooper's edge or Kingsway which don't have any real character to them. Also I think social housing is important as it supports many especially in this current time when housing prices are exponential.","Environmental manager ","","Give them their own identity and have consistent style to create senses of community",""]
["Consistent green areas. Plenty of trees, flowers and an open green area in the middle ","Better bus services","","Housing prices are fucked anyway so nothing you can really do ","Part-time jobs are a nightmare to come by currently. 100% needed. Also ban zero hour contracts","Offer small business support in setting up. Not just financially but have a support line (not automated, just a phone call to a REAL person) where people can ask for advice on running/starting a business","Not feeling like you’re going to get stabbed round every corner","Sort the criminal justice system out "]
["Solar panels on roofs ","Park for people to walk around with their dogs or children","Small store ","Houses with 3 stories,pool and detached","Litter picking community service for criminals ","Higher pay for workers as it will make them move and increase work efficiency and ethic.","shopping centres,fun activities and places to go to,cleanliness","reduce homelessness"]
["planting trees and plants alongside the development ","dentists","dentists ","affordable small flats\n","something to do with an art gallery\n","make rent affordable\n","its livable , we have a nice public library building joined with the Gloucester museum.","personally i would love a ice skating rink, i think its would do well money wise as there isn't one close by"]
["more environmentally friendly energy options, don't cut down and over take nature and make sure the environment is cared for ","better services for housel repairs, more nature care, better safety regulations, more entertainment activities.","entertainment facilities and homeless shelters","more housing for people struggling, good build and not overly large.","more jobs for younger people, more shopping markets with support outlets for people in need, charities that can help in close contact eg food banks.","provide funding ad support. this can be through loans/grants alongside cheaper advertisement.","there is good architecture and some interesting shops.","make it cleaner and provide people who are on the streets support and better shelters, reduce littering and pollution."]
["Dont build flats on fields the size of Quedgeleys asda","","More shops","Skyscrapers, mega mansions, lidl, salvation army.","tesla ceo, mars rover, lidl employee, bin men, busker, homeless person, a fly, grafter, electrician, grass cutter","Get rid of barton st, reduce the amount of stabby people, ","a maccies","more maccies in town"]
["leaving room for more parks and fields for the scenery ","better shops, in town they only have Primark and H&M we need better shops","shops and resturants ","two story houses with big living rooms and kitchens and gardens for summer and family events ","restaurants and retail","post more about the company ","the people and the area","more two story houses instead of bungalows "]
["Use longer lasting materials that are suitable to the weather according that the location built","Exercise, gym, type of stuff","Bank services ","Spacious but not too expensive houses or flats","Part time for now",". ",".",". "]
["We are nature and intrinsically linked so it needs to be thought through as a whole cyclical ecosystem. Do these people have walking access to wilderness? if not is there a regular public transport system to get them to a place they don't see human activity. Are there local heritage trees shrubs, wildflowers. do the buildings have cavity's for birds to nest. Is the supermarket plastic free, supporting local, organic farmers. Are there cycle lanes and places to park. Are there public toilets, public water fountains, places for communities to gather and create. Are there safe spaces 24/7. are there wildlife corridors? cycle lanes? ponds? community artwork linking people to their heritage.  ","places to park safely for the van community,  places to get food that is organic, seasonal - farmers markets, local that will aid my health, public showers, public toilets, public water fountains, public clothes washing, village halls, community meals, music and art events, nature in abundance, places to pick herbs","places to park safely for the van community,  places to get food that is organic, seasonal, local that will aid my health, public showers, public toilets, public water fountains, public clothes washing, village halls, community meals, music and art events, nature in abundance, places to pick herbs ","low cost housing, desperate would take anything that I could afford, its incredibly stressful knowing that I will always be displaced. I thought we had an agreement that housing was an essential to being, why has this been ripped from young peoples grasp. Almshouses for young people, co-housing, with land to grow on food, like the war time houses. ","community work that is funded, that unites people and planet, raises peoples spirits, wellbeing, mentality to understand we are a unified beating consciousness that can produce beauty for all. ","lower rents","nature, flowers, art, festivals, creativity, ideals based on the book ecotopia","the people in charge of their community, making active choices about where money goes, having sovereignty over their place, so they can take ownership, in collaborative, creation and care "]
["Maintaining our fields as much as possible and keeping the places you get people go to hang out ","Close and more convenient small corner shops","Tesco's ","More affordable housing that those in difficult house holds can afford so they can leave their toxic environment as well as housing that those who struggle financially can afford","Good paying stable jobs that don't require alot of experience to obtain ","","Making the centres a safe and comfortable place for teenagers to visit by themselves without adults.",""]
["how it could damage a habitat and the species/individuals which are currently living there","nice flowers or planting trees","","houses for families of 4 as its a typical family size ","environment jobs and jobs which can benefit the changing climate","Price of the premises can be expensive and due to the rising cost of living and products it may be hard to maintain suppliers","nice modern buildings which make the place look better","accepting change and not trying to resist through petitions and complaining about how it will affect them, e.g. noisy "]
["add more solar panels, we use to much fossil fuels","shops, public transport, restaurants, entertainment","public transport and shops","more flats are needed\n","pet based jobs\n","","make things cheaper again.",""]
["","Better trains, more bus stops, more phone booths, more cycle lanes and better park infrastructure.","","","","","",""]
["More green space. Housing with solar panels. More efficient heating and insulation systems.","","","Cheap reliable housing that builders aren't making huge profits off.","Banking, engineering ","Reduce taxes and cut minimum wage so economic activity becomes viable for businesses ","Cycling lanes, lots of parks and tree lined streets","Reduce crime rate and vandalism to community spaces "]
["Wildlife conservation ","More frequent busses","Railway connections ","Carehomes","Flexible hours","","Looks nice, low crime, history",""]
["Replant an equivalent number of plants or trees which you cut down in a different area making sure that they are the same type but also make sure that it's not interfering with a different environment, you should analyse how the eco system works in that area and make sure you are not cutting of vital arterys","Entertainment like Cinemas and a mall as well as public areas like a park with a pond","A supermarket, bus stop, pharmacy, pub","Lots of medium density housing, especially in a suburban area ","Working as an engineer","Create space for businesses outbof town and have good transport links there","A town central which has the ability to host plays and events as well as a leisure centre",""]
["Ensuring that you don’t build on open areas, destroying greenery. It destroys the habitat of tones of animals and only increases pollution and our local biodiversity suffers. ","A more reliable bus service, if my public transport is available then less people will be driving cars creating pollution and risking more road accidents.","A more frequent bus service that could take me to the closest train station. ","more affordable housing that is still comfortable. All the current council housing has been left completely uncared for, not only being unpleasant for those living in them as it makes them feel like they’re not really cared for, but also they don’t make our local area look like a friendly and welcoming environment.","Crossing guards for children’s safety crossing roads.","Make the the area look more pleasant so people actually want to visit and therefore more people may want to shop in the areas (Gloucester is particularly bad)z More effort to keep the streets clean, keep buildings maintained etc. ","A lot of services within walking distance, an area that looks clean and respectful, an area that looks cared for by the council.","Improve accessibility and keep the accessible features working. Repaint and repair buildings that are there as well as enhance and protect the historic features on buildings found on the high street. Keeping this local heritage keeps our community alive as well as a level of tourism and therefore income for the area, making it easier to maintain further on. "]
["by not destroying the greenary around it ","","","plenty of rooms","","having it its all eco friendly","no build to many houses and make the road larger","having more places to go"]
["A Cheltenham/ Gloucester / Tewkesbury mega city would be bad for nature","I don't want a 15 minute neighbourhood","I don't want a 15 minute neighbourhood","I do not want a Cheltenham / Gloucester / Tewkesbury Mega City","I do not want a spy hub for the Government","Lower business rents","No 5G masts","Banning 5G which has not been proven safe, and harms the wildlife and bees"]
["I do not want a smart city","I don't want a smart city","I don't want a smart city ","I don't want a smart city ","I don't want a smart city ","I do not want a smart city ","I don't want a smart city","I don't want a smart city "]
["I do not want to see a SMART CITY between Cheltenham / Gloucester / Tewkesbury. It's bad for nature!","I do not want to see a SMART CITY between Cheltenham / Gloucester / Tewkesbury. I do not consent to 15 minute neighbourhoods","I do not consent to 15 minute neighbourhoods and trying to get rid of cars","I do not want to see a SMART CITY between Cheltenham / Gloucester / Tewkesbury. I do not consent to 15 minute neighbourhoods","I do not want to see a SMART CITY between Cheltenham / Gloucester / Tewkesbury. I do not consent to 15 minute neighbourhoods","I do not want to see a SMART CITY between Cheltenham / Gloucester / Tewkesbury. I do not consent to 15 minute neighbourhoods","I do not want to see a SMART CITY between Cheltenham / Gloucester / Tewkesbury. I do not consent to 15 minute neighbourhoods","I do not want to see a SMART CITY between Cheltenham / Gloucester / Tewkesbury. I do not consent to 15 minute neighbourhoods"]
["Keep as many trees as possible. Have plenty areas of grass/flower beds for drainage.","Perhaps a local supermarket/general store shop. As long as there is a good transport system it wouldn't matter.","A pub would be good but not essential.","More social housing.","Again it shouldn't matter if the transport system is adequate.","Lower the taxes and rental costs.","Mend the pot holes properly using decent contractors. Ensure public transport is sufficient. Keep kerbs and public areas  tidy. Cheap parking. Reduce commercial rents. Encourage locals to get more involved planning to stop ugly buildings getting the go ahead!","Councils need to listen to their citizens. Stop cutting down trees without consultation. Give people freedom to choose what's best for them instead of following government directives."]
["I don't want a mega city. We should be preserving nature. Don't build on farm land or flood plains. ","Community meet up spaces. Sports areas. A good bus service. Small boutiques and green grocers. More shops for jobs.","Decent clothes shops. Cinema. Restaurants and cafes, not just macdonalds and fast food outlets.","Parking spaces and outside area. Don't want to hear neighbours arguing. ","Small companies and start up schemes to help young people work for themselves. More apprenticeships. Engineering schemes. Nursing and medical training. Hospitality. Farming. \n","Clean up the streets and brighten up shop fronts. Make shops affordable. Free parking. ","More small shops. Boutiques, cafes. Live music events. More seating areas.","Don't have more foreigners than English people. It can put people off when it doesn't feel like our country anymore. Make housing a priority for people who have families who have lived here. "]
["I do not want a SMART City between cheltenham / gloucester / tewkesbury.","I do not want a SMART City between cheltenham / gloucester / tewkesbury.","I do not want a SMART City between cheltenham / gloucester / tewkesbury.","I do not want a SMART City between cheltenham / gloucester / tewkesbury.","I do not want a SMART City between cheltenham / gloucester / tewkesbury.","I do not want a SMART City between cheltenham / gloucester / tewkesbury.","I do not want a SMART City between cheltenham / gloucester / tewkesbury.","I do not want a SMART City between cheltenham / gloucester / tewkesbury."]
["Less wireless and more park and play areas","cycling, organic food, less internet","healthy food and outside activities","houses with gardens like they used to build","trades","encourage lots of independent businesses","independent shops","think about peoples health and access to good local food"]
["Make sure there are plenty of trees and shrubs and hedges for all the birds, bees and micro systems that give us life","Do not want a smart city environment between Cheltenham and Gloucester","Do not want a smart city ","Do not want an smart city between Gloucestershire and Cheltenham","Do not want a smart city","Do not want a smart city in Cheltenham, Gloucester and Tewkesbury","Decent shops that you keep shutting down",""]
["Aesthetics and natural biomes.","Community.","Unaltered nature","Normal, high quality houses.","Maintenance, Gardening and wildlife preservation","Lower setup costs, more locations ","Tradition, history, culture, nature, not a smart city","Dangerous populations."]
["Stop building, we have already lost too much farmland, woodland and natural environment","Sports facilities, swimming pools, frequent bus service, libraries, local shops and businesses.","Don't want smart city.\nWant freedom to travel in whatever conveyance and drive a car wherever I want, whenever I want.","Don't want smart city.\nAll types already exist for all kinds of individuals and families.","These questions seem very contrived for the outcome you are seeking to promote.\nDONT WANT A SMART CITY","Keep Cheltenham, Gloucester and Tewkesbury completely separate,  they have their own unique charming characteristics ","It's own unique, history, culture and character.","Listen more to the people who live in them and don't change things they haven't requested. "]
["no smart cities just open country space","","they are already there, food / parking / walks / shops","cheaper with no mortgage","more industry to create work","no business rates","community - I grew up in HK, condenscend living but no community",""]
["You should use better longer lasting materials in stead of cheap non reliable ones","More public bus services because they can be very over crowded","","Flats and all different size houses and bungalows ","Office jobs and retail jobs ","More events to draw more attention ","",""]
["","Free bus travel (stagecoach buses) for children. It can just be during school term time if the cost is too much. ","","","","","",""]
["Build higher buildings and find more clear space","I would like to see more buses and less taxis","Local food shops and Park","More accessibility to disabled people","Office buildings","Add more houses to grow there possible consumers","Popular shops",""]
["Using sustainable energy sources while building things","Supermarkets, doctors offices","Supermarkets","Affordable flats and houses for families ","Doctors teachers engineers plumbers","Benefits, affordable buildings","",""]
["do not destroy habitats or green space and keep the landscape as it is ","supermarkets, doctors","supermarkets, and shops and post office ","affordable homes","doctor, teachers and shopkeepers and police ","give them money ","lots of shop but also wildlife","keep the landscape don't ruin it "]
["How much trees you are taking down and being able to plant them elsewhere as well as using sustainable items","More public transport ","Supermarkets, bus stops ","","Engineers and doctors ","Cheltenham and them spreading into other areas","",""]
["We can use more sustainable materials and preserve our nature.  You must listen to me our climate matters. WE MATTER.","Free female sanitary products","Bus stops","Houses that match my energy ✨","Jobs for under 15s who are trying to find money here and there who are willing to do a little hustle and bustle","Supporting and creating more advertisement for smaller businesses ","Having more places to entertain Gen Z because we are always \"glued to our phones\".","Having more litter picking and a cleaner environment."]
["We need green spaces preserve our nature if you don't then your contributing to global warming and that's terrible we are the FUTURE, we want NATURE. Nature around the houses would be cottagecore/ fairycore","Train station, bus stops, trams ","Bus stops, trams . Free bus rides for under 18s","Many variety ","Jobs for 13 - 16 who are young money makers. More volunteering areas to help our community","Advertising, support for businesses, business classes","Many shops and small cafes, a place to hang out. There is sometimes stabbings and theft","More parks /green spaces that sre safe for children to be hanging out at"]
["We can use nature around the buildings because it looks better more inviting and good for nature","More malls theme parks cinemas fun entertainment places also we NEED FREE BUSES FOR UNDER 18 LONDON HAS IT WE DONT PEOPLE TAKE IT TO SCHOOL ALSO CHICK FIL A","Buses and trams trams are good for the environment and eco buses like the ones in Germany also free buses for under 18 because people use it for school every day and it’s very expensive CHICK FIL A","More nice apartments with a good garden space in the middle and shops next to it and spas and stuff like that like the ones in London I would ask appreciate more halal shops and chick fil ay","Maybe journalism or detectives stuff and maybe make a school or like be a therapist ","Well visit the universities and schools and reach out to see what they want as businesses and make more specialised things for Gloucester also focus on Gloucester cathedral as it brings in tourists and like have less big businesses like Starbucks instead have local ones also use social media too spread this more like the Gloucester stalls in town or Cheltenham festival or Cirencester sailing or costwalds cottages ","Well they show the culture and stuff a lot on social media which I think brings in tourism and the amount of shops and green space we should also have thrift shops ","Well what I love about London is the way there are a lot of shops next to apartments and green spaces in the apartments also trams are really good as well and I love thrift shops we need more"]
["There is no climate emergency","","","","","Reduce business rates.  Mend the roads.  Keep the streets clean.","",""]
["There is no climate emergency.  Buildings and warehouses are not helping nature.","","","","","Low business rates.  Access to good roads.  Low crime.","",""]
["Climate change is a scam. ","Swimming pool, cinema, shops","I have a bike","Bungalows ","My Fans page","Bribe them","Trees","No taxes"]
["We do not want \"SMART homes\" built under the disguise of \"climate change\". ","A safe place without any 5G surveillance systems","I wholeheartedly oppose to this \"nudging\" trying to gain consent for 'Low Traffic Neighbourhoods' / 15-minute cities which are being stealthily being  introduced like in Oxford and Bristol:\nhttps://www.bristol247.com/news-and-features/news/bristols-first-liveable-neighbourhood-trial-go-ahead/\nI DO NOT CONSENT","A return to contemporary buildings, planning policies and decisions not being influenced by the satanic Freemasons","More local businesses and no business rates for small businesses","Get rid of 5G weapons systems on our streets, lower business rents, get rid of the satanic Freemasons","No Freemasons","No 15 minute cities / Low traffic Neighbourhoods. Get rid of that freemason Max Wilkinson who is conspiring against Cheltenham residents"]
["","","","","","","",""]
["Animals","Shops","Shops","Family","Wildlife","I do not know","Everywhere is really nice and you don't come across bad people very often","Parks"]
["Cut down less treea","Bus stops","Schools","","?","Lower the amount of drug addicts in town","Things that make a city or town a great place is when it feels safe and there are little bits of nature","We need to think about making it less dangerous for shop owners "]
["That they are sustainable and don’t damage nature and the world around us ","A bus service, a car, and affordable things","Shops and entertainment places ","Affordable housing and not houses that will fall apart ","That you shouldn’t have to have qualifications for jobs that don’t even need that qualification","In warehouses","A place that is safe to walk alone as a woman","More policing around town centres where it’s a drug dealer hub"]
["i think you should avoid building in places where there are already alot of houses and nature and build schools or hospitals instead if you have to build something","more shops and transport stops and make them accessible to everyone","shops, gym","making it more affordable","buisness, law, higer education needing jobs","advertise as easy and having a wide range of customers?","good options regarding shops, cinemas, restaurants","climate change "]
["make the flat look good 👍🏽 👌 ","","","AFFORDABLE ","business, law, higher education ","idk","many types of shops, parks, houses, churches/places of worship","dk"]
["Permanent green spaces you cant build on","A bus that goes further than central Gloucester (maybe a bus that goes to central Cheltenham)","A nice green area to walk around","More affordable homes that are easier to get and afford","I think you should try and bring more creative jobs","Tell them about the opportunities and the growth opportunities ","Places to hang out with your friends,parks,",""]
["don't wreck the place","","","","","","",""]
["Think about the trees and green areas as these are good at keeping the air clean.","Supermarkets and shops.","Shops to get food when needed.","Houses, flats, apartments land bungalows.","Engineering jobs.","Show them the amount of people that could visit their business and then persuade them based off that.","When it has green places around like parks and fields. The air would feel very fresh in these places.","Plant even more trees and plants to oxygenate the air."]
["","","","","","","",""]
["That we give greenery room as well as housing space.","Recycling drop off points, deliveries,","Recycling, post office, co-op, library, ","?","A range of different jobs which give different pay opportunities","Make it less risky to live there","More shops; don’t close all the shops","Make there more entertainment places and"]
["Planting trees","","Bus stop\nFood shop","Bungalows\nBig houses\nFlats\nLittle houses","Jobs for teens","Cheap rent","Fun things to do\nNature parks\nRestaurants","Litter\nCrime\nPollution "]
["Be aware of the surroundings and try not to damage more nature","A food shop and bus stop and a couple street lights","A food shop the same as above","Big houses for large families \nFlats \nLittle houses \nDetached houses\nEtc.","Job’s for youth and teen \nHigh paying jobs \nMinimum wage jobs","Cheap rent of buildings","Fun things to do \nNature parks \nAnd more thing that to include protecting nature","Littering \nCrime"]
["Be aware of the surroundings and try not to damage more nature (for example trees)","Bus stops (that say which bus goes there and where it goes), shops, street lights","Shops ","Big houses for large families \nFlats \nLittle houses \nDetached houses \nEtc.","Jobs for teens, high-paying shops, minimum wage jobs","Cheap rent of buildings\n","Fun things to do \nParks \nFood places","Littering \nCrime "]
["Affordable and sustainable housing facilities ","Less people being homeless and less deforestation for unnecessary building sites.","Bus (public), train, taxi transport, anything but walking ","Really affordable prices for those who don’t earn as much, therefore we all get food and shetltery","I think we should keep the jobs part time/ flexible hours for those who are studying and can’t work daily and don’t earn much","We could encourage businesses by encouraging others to continue what they are working on and following dream","Where I live, there are many good things, fairs/circuses, shopping outlets, food markets etc.","Kind community, quiet, not biased, no discrimination etc."]
["Green spaces that don't include gardens","I would love for my local bus service to go to more places around my area so I can travel more independently.","Anything","More cheaper, small housing in rural areas for students and younger people.","Online job","","It's not very good that we have to go a long way to buy food and essentials, but ordering food online works, and reduces carbon emissions. Its good that I live in such a beautiful, rural place, but I think there should be more public footpaths. Its also not good that our power goes out quite a lot (every few days for about an hour) especially when it is winter and very rainy/stormy.",""]
["When building new houses or any sort of building in a space which was once a home to nature I think burrows and dens must be checked and hopefully some animals regimes before their homes are destroyed. This is because whenever I think of development I think of habitats being destroyed and I really want that to change.","Schools with a more even quality between them (not extremely bad)","Shops in walking distance \nBus stops in walking distance","Flats\nStudent housing \nDifferent types of houses (semidetached etc)","Wildlife\nConservation\nFashion design","Supporting family businesses","Cleaner city centres\nRange of shops\nActivity centres",""]
["Use sustainable and eco friendly equipment and make sure not harm is done to nature while building hpuses","Clubs and activities centres","Taxi, bus and train","Houses that are well built with a good structure ","Office work, health care jobs, maybe art and culture jobs ","Money and a good stability ","A wide range of cultal shops and activities","More activities like fun fairs, cultural events"]
["more affordable housing using eco friendly materials ","Less people on the side of the streets , and less deforestation for unnecessary things","Bus, train, car, taxi, anything but walking cycling etc ","affordable prices so we all get a place to stay with food and shelter","I think we should keep the jobs and not let them be taken by ai","I think we should encourage businesses owners to continue what they’re doing by showing them how much they help the country\n","Where I am based there are many good things such as fairs or circuses etc but the only bad thing is if there is a place with roadworks it disrupts half of the city making it hard to transport, if you were to make this better you could do roadworks at night instead of day",""]
["Sustainable Develop so we don’t use to much trees","Leisure centre","Grocery shops","Sustainable homes flat apartment ","Accountant Doctor and care workers ","Money","Lots of shops, vapers, restaurants,","Have more items in shops that are from different cultures so that it is inclusive"]
["making sure you sustainably drvelop these things so its not damaging too many trees or environment","A leisure centre","Grocery stores","apartment,flat,sustainable homes","Doctors,accountants and care workers ","money and stability ","Lots of shops, smokers,restaurants","have more items in shops that are from different cultures so that it is inclusive "]
["I think there should be dedicated green spaces for animals to thrive and an awareness for their existence so that people can help injured animals who need help","Food shops, parks, nature reserves, electric car chargers, vets and hospital/ GP services","Shops, parks and nature reserves","Detached houses and student flats","I think sustainable and eco-businesses should be supported and jobs that you don’t need lots of work experience for","Support smaller family businesses ","I think green spaces and places for support groups to meet up are good. Libraries, Museums, galleries and wildlife areas help as well. I don’t think industry estates help anyone.","Community green spaces"]
["I think you need to make sure that you leave green areas and forests because they are important for animals ","Hospital, vet, parks/ nature areas, shops","Parks, shops and nature areas","Detached houses, student apartments/ flats ","Jobs that are sustainable and don’t require much work experience so that a wide range of people can access jobs ","Support smaller family businesses instead of buying from bigger companies that already have lots of money","Nature spaces, places that you can visit and do activities with your family eg. Farm parks, museums","More community meet up areas for all ages "]
["Reduce pollution, using sustainable materials that hopefully benefit the environment, preserving animals.","","","","More doctors, more nhs workers, teachers.","","More scenic views, leisure centres",""]
["Make sure animals are safe and create habitats if you know they might lose their own homes due to development of these places.","Give more access to public transport especially buses, some more supermarkets near rural areas","Buses","Solar panels, gardens/balcony, sustainable heating ","Airport, leisure centres","Organic local food markets, sustainable farming, recycling centres","Parks, leisure centres,nature trails nearer to central Gloucester especially","More social events with different ethnicities, religions,race"]
["Make sure that animals are safe and have a home and create habitats if you know that they might lose their habitat and home due to the development of these places.","More access to public transportation especially busses","Busses, bus stops, wind turbines","Solar panels, green gardens, balcony, more sustainable heating","Airports, leisure centres, ","Sustainable farming, organic local food markets, recycling centres","Parks, fields, leisure centres, sport fields, nature trails","More social events with different ethnicities, religions and race and in different places."]
["You need to think about the impact that it’s making so a few things that you can do is use sustainable products and create a protected area for the animals and plants to grow and live","More swimming pools","I would love to have a badminton court nearby and a swimming pool because I love playing badminton with my dad and I didn’t get very good swimming practice because of covid 19","People need homes that match their needs ","People need the chance to do what ever job they are good at doing ","","Lots of nice peaceful parks with lots of wildlife are always good and enjoyable ",""]
["Avoiding the cutting down of trees and not building on areas with dense populations of wildlife.","More study cafes and spaces for students","","Affordable housing that is suitable to live in for the type of person the house is created/marketed towards.","Part-time jobs for students. I would love more animal related jobs to come up in the area that are suitable for students.","Improving the appearance of the city and the streets where properties may be sold for businesses to use. Ensuring that these properties are affordable for small businesses to buy and maintain.","Personally, I love a place that is thriving with people and small businesses. Having lots of unique places to shop in and visit adds to the charm of a city. Equally, having spaces for nature such as parks or even flower baskets along a street contributes to the overall vibrant feeling of a place. Maintaining streets and removing unwanted vandalism is a good place to start in creating a positive environment within a city.",""]
["reuse things that help the climate ","","","flats more 3 to 4 bed homes ","Make net zero by 2032","by saying we want to be net zero by 2032","not having much trees or plants in some to most villages esspiacally the forest of dean","Making sure we use sustainable sources to make homes"]
["","Schools hospital jobs","","Houses and flats?","Game designers","Have good places  for businesses ","",""]
["Use energy saving electrical sockets.","A playground or little food stalls","","Elderly home care or even a soup kitchen where if people have no food then they can always have an alternative ","","","A park or shopping center and generally the amount of friends you can make","the amount of smoke that is being polluted on the air by truks or factories."]
["Make sure the building and stuff stays away from the environment ","","","","","","",""]
["","Litter picking sice there is a lot of plastic in my house","","I don't know","More creative arts","","",""]
["On roofs of houses people could plant trees , grass ,flowers and fruit ","Schools ,shops markets","Schools","Cottages, family homes","Conservationists of nature ","Make themselves sustainable ","Village","Let people live in areas that they enjoy living in "]
["","","Clothing stores, grocery stores, a school, a GP/hospital , a fast food restaurant","","","","Lots of shops , flats,Trees, parks, traffic",""]
["recycle the buildings ","No junk mail","A local food store","More than 2 stories houses","Well paid jobs (at least 40k)","","More trees",""]
["We can navigate local parks.","Maybe more big shops which you can walk to.","","More cheaper houses.","","","",""]
["nature","","nature conservations and workshops","","","","",""]
["Plant and make enough space for lots of trees, don't cut down loads of trees","Libraries, cafe's, bakery, scenic walks, drives etc...","","","","","",""]
["don't cut down any trees","","","different size houses and a variety of gardens\n\n","","more available spaces \n\nmore spaced out","pollution","less diesel cars\n"]
["Stop cutting trees ","Helping the environment in any way possible","Donating ","","CEO","More available spaces to start businesses","Pollution","Less car which are diesel "]
["Whatcb out for wildlife ","not sure","Shops","","Teacher","Dont know","",""]
["leave some trees and nature for parks and grassy areas.","more small local parks as all the parks near me are big but far away","","we need more 4 room houses","half times which are more flexible for student who are in education"," make unique businesses ","safe","listen to others and make public seveys in house shops so people can give ideas"]
["Leave lots of trees and nature for parks ","","GP/medical center, clothing/grocery stores, fast food restaurants, parks/playgrounds, school, bus stops","","Half times which are more flexible for students who are in education ","Unique businesses ","Tall buildings, safe environment, parks, traffic,","Listen to others and make public surveys in the house,"]
["Planting trees when houses are built \n","More recycling and wildlife/ nature area","","","Part time jobs ","","Not a lot of trees/ nature in the town centers. Bins are overflowing with rubbish","More recycling bins/ food waste bins\nPlanting more trees"]
["Use the nature as a canvas and work in harmony","More picking up litter to save the world","Services that recycle clothes and plastic. ","Flats and small buildings would be nice. ","More of a variety of jobs and less of the same jobs. ","To hold speeches. ","Loads of shops and food and culture.","Advertise them by putting up billboard and other stuff. "]
["It would be helpful to think about the preserving some of the wildlife that face extinction and important natural landmarks. Make sure that we are not increasing our carbon footprint.","More recycling committees and animal shelters","More recycling committees and animal shelters","Cheaper flats with university/college students struggling with any student loans","Part time job helping with experience for your actual job (aimed at students) ","Base themselves on everyday needs and necessities to ensure a good money/profit flow","Cheap food","Cheaper food"]
["It would be helpful to think about preserving some of the wildlife that face extinction and important natural landmarks. Make sure that we are not increasing our carbon footprint.","More recycling committees and animal shelters","More recycling committees and animal shelters","Cheeper flats for university/collage students struggling with any sort of student loan.","Part time job helping with experience for your actual job (aimed at students)","Base themselves on everyday needs and necessities to ensure a good money/profit flow","Cheaper food","Cheaper food"]
["se more sustainable ways of living and be more eco friendly ","ECO BIULDS","","","eco friendly ","","",""]
["We need certain landscapes and forests for animals to be used to.","more nannies and caregivers","the government listening to what people say","college flats for people struggling with loans","care workers and school therapists ","people that need things that small business owners can provide ","'-recycling bins\n-flats for uni students\n-guidance for children struggles with mental health","schools need to be more wary of what kids are doing ton their phones "]
["Make space to plant trees so we can have an unlimited supply of oxygen","Parks ","Parks ","Workshops and Cafes from walking distance","Child specialist-  This means doctors working with children with special conditions. Many people don’t see this as a job so we need to raise awareness.","Tell the world about the good things about these places and how their business would be thriving if they bought it here.","Things that are great is the community. Things that aren’t great is the cost of houses and petrol.",""]
["Put more trees and greenry","Buses","Buses","Big and affordable homes","Millitary soldiers","Give more jobs for people","An area of homes and an area of shops and city centres",""]
["You could make your building environmentally friendly by using electronic instead of petrol building machines and using the space that we already have instead of cutting down trees","We could do with a lot of things like benches, parks and more waste bins on pavements.","","Basically all houses big or small.\nThere needs to be more affordable homes for not only people who are struggling financially but those who just want a new start","More fun and entertainment jobs because we could be preventing younger generations from dangerous  situations and its just as fun for the adults ","Make it more lively. People want to be in a place that is filled with life and will build up their business.","Parks and museums are a good thing.\nLitter and dullness is bad.","PARKS and festivals "]
["Build cafes, places to access quality and healthy food. Like salad bars.","I do not want a SMART City between cheltenham / gloucester / tewkesbury","I do not want a SMART City between cheltenham / gloucester / tewkesbury","I do not want a SMART City between cheltenham / gloucester / tewkesbury","I do not want a SMART City between cheltenham / gloucester / tewkesbury","I do not want a SMART City between cheltenham / gloucester / tewkesbury","I do not want a SMART City between cheltenham / gloucester / tewkesbury","I do not want a SMART City between cheltenham / gloucester / tewkesbury"]
["","","","","","","",""]
["Preserving our natural landscape by leaving it undisturbed","I’m happy with just fields","None if it means even more destruction of our natural landscape","None- you’ve built enough. There are new houses everywhere","None of it destroys more of our natural landscape. Why don’t you do more to support businesses that are already here","By reducing business rates","","Do not turn the area into a 15 minute city"]
["Making sure the materials you use are made in a sustainable way and not being wasted.","More small shops in small villages that sell essential food and toiletries.","A train or bus station and a shop.","Flats, free accommodation and houses or different sizes.","Ones for everyone’s skills like bakery’s and tailors.","Make the rental of shops cheaper and make creating a business easier.","There are many things to do and explore.","Have more attractions."]

{"sheet":"Housing 13-25 year olds","index":4,"n_rows":74,"n_cols":7,"rows_kept":74,"cut":false,"hidden":false,"merged":[]}
["Do we need more housing in the area?","What stops young people getting housing?","In the next 15 years (when you will be between 28 to 40 years old) would you like to have moved from the home you live in now? ","What type of home would you like your next home to be?","Thinking about your next home, who would you pay to live there?","Thinking about your next home, who would you like to live with?","Is there anything else you would like to tell us about housing?"]
["Yes","Cost of housing - it is too expensive, Not enough homes","Yes","Flat (also called an apartment), House, Bungalow (a house with no upstairs)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to rent a home and pay a landlord","I would like to live on my own, I would like to live with a partner",""]
["Yes","Cost of housing - it is too expensive","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner",""]
["No ","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs","Yes","Studio (a small flat which has just one room for your bed, sofa and kitchen), House, Boat","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to rent a home and pay a landlord, I would like to build my own home","I would like to live with a partner","FIX THE RENT PRICES I BEG BRO, ALSO INFLATION WHY AM I PAYING 50 QUID IN KFC"]
["No ","Cost of housing - it is too expensive, Poorly paid jobs, Lack of jobs","Yes","Mobile home, caravan or static trailer, House, Bungalow (a house with no upstairs), Boat","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live on my own","there should be more housing away from cities and surrounded in wildlife e.g. forests,farmland or lakes"]
["Yes","Cost of housing - it is too expensive, Not enough homes","Yes","House","I would like to rent a home and pay a landlord","I would like to live with a partner, I would like to live with my childhood family (this could be your parents, guardians, grandparents or brothers or sisters)","climate nature"]
["Yes","Cost of housing - it is too expensive, Poorly paid jobs, Finding other people I want to live with","Yes","Bungalow (a house with no upstairs)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner","no no no no no bad house "]
["Yes","Cost of housing - it is too expensive, Not enough homes, Poorly paid jobs, Lack of jobs","Yes","Flat (also called an apartment), Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner, I would like to live with my childhood family (this could be your parents, guardians, grandparents or brothers or sisters)",""]
["No ","Not enough homes, Lack of jobs","No ","","","","the house to have big garden,near shops"]
["Yes","Cost of housing - it is too expensive, Poorly paid jobs, Not enough homes, Lack of jobs","Yes","None of these","I would like to build my own home, I would live for free or pay rent to my family","I would like to live on my own, I would like to live with a partner",""]
["Yes","Lack of jobs, Cost of housing - it is too expensive","Yes","Flat (also called an apartment)","I would like to build my own home, I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live on my own","there should be more than one toilet it a house"]
["Yes","Cost of housing - it is too expensive, Not enough homes","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner","i like big houses"]
["Yes","Poorly paid jobs, Cost of housing - it is too expensive","No ","","","","no"]
["Yes","Cost of housing - it is too expensive, Not enough homes, Poorly paid jobs","Yes","House, Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs), Flat (also called an apartment)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live on my own, I would like to live with a partner",""]
["Yes","Cost of housing - it is too expensive, Not enough homes","Yes","Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner",""]
["Yes","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs","Yes","Flat (also called an apartment), House","I would like to rent a home and pay a landlord","I would like to live on my own",""]
["I don't know","Poorly paid jobs, Cost of housing - it is too expensive, Finding other people I want to live with","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner",""]
["No ","Cost of housing - it is too expensive","Yes","House, Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs), Flat (also called an apartment), Bungalow (a house with no upstairs)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner, I would like to live on my own, Other","I think that while renting can be easier to get into than buying a home, I think often landlords raise rents in a way I would consider unfair, based on my experiences of living outside of my parent’s home. Also they are often negligent in terms of responding with issues. I would like to see more help given to first time buyers, or maybe homes set aside for first time buyers rather than landlords, so we can avoid this."]
["I don't know","Cost of housing - it is too expensive, Poorly paid jobs","Yes","Flat (also called an apartment), House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to rent a home and pay a landlord","I would like to live on my own, I would like to live with a partner","It would be beneficial if housing prices were lowered for people of this age group due to the ongoing inflation and rising housing prices, I am worried that I won’t be able to afford to move out until later in life as opposed to the age my parents were able to move out at."]
["Yes","Cost of housing - it is too expensive, Poorly paid jobs, Not enough homes","Yes","Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs), House","I would like to rent a home a pay a housing association (a housing association rents homes to people on low incomes), I would like to rent a home and pay a landlord, I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner, I would like to live on my own","It is impossible for young people to private rent that isnt a HMO/house share. Young people dont want to live with strangers, yet society expects us to want to."]
["No ","Cost of housing - it is too expensive, Poorly paid jobs","Yes","House, Bungalow (a house with no upstairs), Boat, Mobile home, caravan or static trailer","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner, I would like to live on my own","Building new estates are filled with expensive houses, with no adjustment to amenities. Utilising run down areas/brown land would be more beneficial and building quality houses with actual gardens/parking and then adjusting local amenities (drs/dentists/schools) to accommodate more people."]
["Yes","Cost of housing - it is too expensive","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner",""]
["I don't know","Cost of housing - it is too expensive, Finding other people I want to live with","Yes","Flat (also called an apartment), Studio (a small flat which has just one room for your bed, sofa and kitchen), House, Bungalow (a house with no upstairs)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to rent a home and pay a landlord, I would live for free or pay rent to my family","I would like to live on my own, I would like to live with a partner, I would like to live with a group of people (who are not my family) in a house or flat share",""]
["Yes","Cost of housing - it is too expensive, Poorly paid jobs, Lack of jobs","Yes","House, Flat (also called an apartment)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner, I would like to live with a group of people (who are not my family) in a house or flat share",""]
["No ","Cost of housing - it is too expensive, Other","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner","Please stop trying to spread the lie that there are \"not enough homes\" and that building more will bring down prices or make housing affordable.  Studies show that even when tou build loads of homes, prices go up. This site has one agenda, make the prospect of tens of thousands of homes on the edges of towns and cities, already widely criticised as unsustainable suburbanisation, palatable. Disgraceful the lot of you."]
["Yes","Cost of housing - it is too expensive, Poorly paid jobs","Yes","House, Flat (also called an apartment), Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner, I would like to live on my own",""]
["I don't know","Cost of housing - it is too expensive","Yes","Studio (a small flat which has just one room for your bed, sofa and kitchen), House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live on my own, I would like to live with a partner",""]
["Yes","Poorly paid jobs, Cost of housing - it is too expensive","Yes","None of these, House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to build my own home","I would like to live with a partner","Houses should not be built for profit they should be built with sustainability and good quality in mind. Not just building it for as cheap as possible without a care for everyday."]
["Yes","Lack of jobs","No ","","","","Not "]
["Yes","Cost of housing - it is too expensive, Poorly paid jobs","No ","","","",""]
["No ","Cost of housing - it is too expensive, Poorly paid jobs, Other","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), Other","I would like to live on my own, I would like to live with my childhood family (this could be your parents, guardians, grandparents or brothers or sisters)","Make sure there’s no mold or decaying materials, the landlords have to understand the issue and make sure the houses are sustainable "]
["No ","Cost of housing - it is too expensive, Poorly paid jobs","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner","please dont build too many houses, we are ruining everythinng all these houses are demolishinh feilds and forests its just not right, people can live with their parents for a bit longer or live with friends. also please PLEAASEEE make more jobs available to 13-15 year olds and also if you do need to make more houses ar least make them look nice the new style of houses are just horrible i love thr old vintage look, we have lost all of our artistic skills and just build squares that look like theyre made of lego. also please fund denkmark road high school we have no money xx"]
["I don't know","Cost of housing - it is too expensive, Poorly paid jobs","Yes","Mobile home, caravan or static trailer","I would like to build my own home","I would like to live on my own",""]
["I don't know","","Yes","Studio (a small flat which has just one room for your bed, sofa and kitchen), Flat (also called an apartment), Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs), House, Bungalow (a house with no upstairs), Mobile home, caravan or static trailer, Boat","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to build my own home","I would like to live on my own, I would like to live with a partner, I would like to live with a group of people (who are not my family) in a house or flat share",""]
["Yes","Cost of housing - it is too expensive, Poorly paid jobs, Not enough homes","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner","No"]
["No ","Cost of housing - it is too expensive, Poorly paid jobs, Finding other people I want to live with, Other","Yes","Studio (a small flat which has just one room for your bed, sofa and kitchen), Flat (also called an apartment), Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs), Mobile home, caravan or static trailer, House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to rent a home a pay a housing association (a housing association rents homes to people on low incomes), I would live for free or pay rent to my family, Other","I would like to live with a partner, I would like to live with a group of people (who are not my family) in a house or flat share, Other, I would like to live on my own","make it more affordable, bills too much plus tax"]
["No ","Cost of housing - it is too expensive","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to build my own home","I would like to live with a partner",""]
["No ","Cost of housing - it is too expensive","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with my childhood family (this could be your parents, guardians, grandparents or brothers or sisters), I would like to live with a group of people (who are not my family) in a house or flat share",""]
["I don't know","Cost of housing - it is too expensive, Poorly paid jobs","Yes","Bungalow (a house with no upstairs), House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner, I would like to live with my childhood family (this could be your parents, guardians, grandparents or brothers or sisters)","I have moved house a few times in the past year but that is basically the only reason I know about housing."]
["I don't know","Cost of housing - it is too expensive, Poorly paid jobs","I don't know","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner","No"]
["No ","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs","Yes","Flat (also called an apartment), House, Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs)","I would like to build my own home","I would like to live with a partner",""]
["I don't know","Cost of housing - it is too expensive, Finding other people I want to live with, Other","Yes","Flat (also called an apartment), None of these, House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to rent a home and pay a landlord","I would like to live with a partner, Other",""]
["I don't know","Cost of housing - it is too expensive, Poorly paid jobs, Lack of jobs","Yes","House","I would like to build my own home, Other","I would like to live with a partner","No"]
["I don't know","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner","ni"]
["Yes","Cost of housing - it is too expensive, Poorly paid jobs, Lack of jobs, Other","Yes","Flat (also called an apartment), House, Bungalow (a house with no upstairs)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live on my own, I would like to live with a partner, I would like to live with a group of people (who are not my family) in a house or flat share, Other",""]
["I don't know","Cost of housing - it is too expensive, Poorly paid jobs, Lack of jobs, Other","Yes","House, None of these","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to build my own home, Other","I would like to live on my own, I would like to live with a partner, Other",""]
["Yes","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs, Not enough homes","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner","Renting/buying a house is expensive "]
["I don't know","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs, Not enough homes, Finding other people I want to live with, Other","I don't know","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to rent a home and pay a landlord, I would live for free or pay rent to my family, Other","I would like to live on my own, I would like to live with a partner, I would like to live with a group of people (who are not my family) in a house or flat share, I would like to live with my childhood family (this could be your parents, guardians, grandparents or brothers or sisters), Other","They are all expensive, if more cheaper, more people would take them and it will make more profit"]
["No ","Cost of housing - it is too expensive, Finding other people I want to live with","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would like to build my own home","I would like to live with a partner","There shouldn’t be houses which are millions of pound with houses which are council houses because if you’re gonna spend a bunch of money on your house you probably don’t want to change neighbours that much"]
["I don't know","Cost of housing - it is too expensive, Poorly paid jobs, Finding other people I want to live with, Other, Lack of jobs","No ","","","","Lower prices in certain areas"]
["I don't know","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs, Finding other people I want to live with, Other","No ","","","","Lower prices in certain areas "]
["No ","Cost of housing - it is too expensive, Lack of jobs, Other","Yes","House","I would like to build my own home","I would like to live with a partner",""]
["No ","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs","Yes","House, Mobile home, caravan or static trailer, Boat","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), Other","I would like to live with a partner, I would like to live on my own, Other","Make houses cheaper "]
["I don't know","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs","Yes","House","I would live for free or pay rent to my family, I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner, Other","Houses are to expensive "]
["No ","Cost of housing - it is too expensive, Poorly paid jobs, Not enough homes","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner",""]
["I don't know","Cost of housing - it is too expensive","No ","","","",""]
["No ","","No ","","","","i feel that houses are populating some of the nicest parts of the country!"]
["I don't know","Cost of housing - it is too expensive","I don't know","None of these","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner","I think that even for the cost of living crisis we should make council housing queues shorter."]
["I don't know","Other, Cost of housing - it is too expensive","I don't know","House, Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs), Boat","I would live for free or pay rent to my family, Other","I would like to live with my childhood family (this could be your parents, guardians, grandparents or brothers or sisters)","No thank you"]
["I don't know","Cost of housing - it is too expensive","Yes","House","Other","I would like to live with a partner","No "]
["No ","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs","Yes","Bungalow (a house with no upstairs), House","","","No I haven’t ever been impacted by housing issues "]
["I don't know","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs, Other","I don't know","House","I would like to build my own home, I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner, Other","No"]
["I don't know","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with my childhood family (this could be your parents, guardians, grandparents or brothers or sisters)","My family could only afford a small 4 bedroom home because the others were a bit too costly "]
["Yes","Cost of housing - it is too expensive","No ","","","","no"]
["I don't know","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs, Other","I don't know","House, Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home), I would live for free or pay rent to my family","I would like to live with a partner, I would like to live with a group of people (who are not my family) in a house or flat share",""]
["I don't know","Lack of jobs, Cost of housing - it is too expensive, Poorly paid jobs, Other","I don't know","Flat (also called an apartment), Maisonette (a building which looks like one house but is actually two flats - one flat on the ground floor and one flat upstairs), House","I would like to build my own home, I would like to rent a home and pay a landlord","I would like to live with a partner, I would like to live with my childhood family (this could be your parents, guardians, grandparents or brothers or sisters)",""]
["Yes","Cost of housing - it is too expensive, Poorly paid jobs","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live with a partner",""]
["No ","","Yes","","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","",""]
["No ","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs","Yes","Flat (also called an apartment), Bungalow (a house with no upstairs)","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live on my own, I would like to live with a partner","have nicer landlords"]
["I don't know","Lack of jobs, Poorly paid jobs, Cost of housing - it is too expensive","Yes","House","I would like to build my own home","I would like to live with a partner, I would like to live on my own, I would like to live with a group of people (who are not my family) in a house or flat share, Other",""]
["I don't know","Cost of housing - it is too expensive, Lack of jobs, Poorly paid jobs, Not enough homes, Finding other people I want to live with, Other","Yes","","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","",""]
["Yes","Poorly paid jobs","Yes","Studio (a small flat which has just one room for your bed, sofa and kitchen)","I would like to build my own home","I would like to live with a partner",""]
["Yes","Cost of housing - it is too expensive","No ","","","","no"]
["No ","Cost of housing - it is too expensive, Poorly paid jobs","Yes","House","I would like to own the home myself and pay a mortgage (a loan from a bank to buy a home)","I would like to live on my own","No "]

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["Your role ","Organisation","Title","Description","Comments (see table below)","Likes","Dislikes"]
["Resident","","Build on the airport.","Gloucestershire is well served by airports in Bristol and Cheltenham. Normal people in our county do not need an airport. Normal people need homes. You could fit hundreds if not thousands of homes on the airport site. Its in a prime location. Please don't discount this just because it could be politicly difficult, it is the right thing to do.  We young people just need you to build homes.",2,4,3]
["SLP Team","SLP Team","Culture and heritage","The area’s thriving cultural offer will have flourished, and its rich diversity of heritage assets preserved through carefully considered developments and enhancements.",5,1,0]
["Local Councillor","","Decarbonisation","The level of decarbonisation needed in our area to meet current statutory targets will be significant over this SLP time period (and probably more significant than people currently imagine). We need an honest and bold  sense of what our decarbonisation targets are going to be early on.  This will help us understand what risks and opportunities we face when confronted with things like sustainable development choices (i.e. the proposed Development Scenarios that appear later in consultation - each of those must be modelled according to their carbon impact).  Every choice we make throughout the SLP process should consider its decarbonation potential and cost.  Decarbonisation done well has huge benefit potential to the local economy as well as health and wellbeing.  Done well, it could be what sets our communities apart from elsewhere.",3,2,0]
["SLP Team","SLP Team","Harness green growth","By 2041, and beyond for larger scale developments, the Cheltenham, Gloucester and Tewkesbury area will have harnessed the opportunities of green growth to create thriving, beautiful, energy efficient, resilient and healthy places. Growth will have afforded the highest possible quality of life for all in a manner which achieves carbon reductions and addresses the causes and effects of climate change.",2,0,0]
["SLP Team","SLP Team","High quality environment for people and nature","Growth will have been supported by the provision of a range of essential digital, transport, community and other infrastructure. Equally, alongside conserving the area’s special landscapes and its attractiveness as a place to visit, a network of interconnected green spaces and waterways will have secured a high-quality environment for people and nature. Together with necessary retention and management of existing sports and leisure facilities, this will have unlocked opportunities for healthy lifestyles, inclusive access to sport and recreation, active flood risk management and improvements to biodiversity.",3,1,0]
["SLP Team","SLP Team","Housing need","People’s housing needs will have been met through the provision of sustainable, high-quality market, affordable and other specialist homes set in beautiful, safe places and conforming to sustainable standards of design and construction.  The focus will have been on making best possible use of brownfield sites in built up areas and large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved.  ﻿The vital role of the area’s city centre, town centres and high streets will have been improved through careful management of development and land uses.",5,1,0]
["Resident","","How about you listen to rhe people?","The vast majority of normal people will not benefit from plonking tens of thousands of new box homes on fields and tou know it. Do not gaslight us.  When the population declines in the next 50 years, what do you propose to do with all these box homes?  Your objective is to ultimately maximise the profits of big developers. We all know it. You won't acknowledge this will you.",3,1,0]
["Business owner","L3Harris","Improvement of public transport and links to surrounding areas.","In support of reduction of business scope 3 travel emissions, we would like to see major upgrade of existing train and bus services that service the local business parks. This would enable local staff to use public transport that is affordable and reliable.  This infrastructure should efficiently connect to the surrounding areas appropriately. Many staff feel that public transport is not an option based on the frequency and availability of services.  The business parks already struggle to cope with the volume of traffic.",0,1,0]
["Resident",null,"Keep the Airport","The demographic of Cheltenham is fast becoming a retirement town. In the 70s, there was a good balance between manufacturing and service industries this  meant that the town was wealthy and vibrant, this balance is trending towards service provision working from home and less wealth. To redress the balance we need more wealth creating industries, the Cyber Park will help but we need to create an attractive offering to new businesses.  The documents I have seen so far have lots of nice words to attract businesses  but little detail. Prospective businesses need : suitable buildings or land to build on, skilled employees or local schools/ colleges/universities which are closely aligned providing well educated apprentices, business rate incentives, good communications and a helpful, engaging, welcoming local Council. The Airport and surrounding business parks would tick many of the boxes and should not be wasted on housing.",0,4,0]
["Resident","","Key worker housing","The recruitment & retention problems experienced by Glos Royal Hospital and the wider health & care sectors are well documented.  In my view the city council should adopt a policy/strategy to provide a significant number of homes for key workers.  I would suggest that all new build affordable housing built within a 30 minute walking radius of Glos Royal Hospital should be designated as Key worker housing.  I am obviously aware that there is already a waiting list for affordable housing, but consider that prioritising the health & well being of the wider population as more important. The Eutopia homes site in Great Western road would be an ideal place to start (I read that Eutopia are already doing this with one of their Exeter developments), as would the 2nd phase of the Whitefriars development at King's Quarter, the former Wessex house site and the Longsmith car park site.  I strongly feel that this issue should be the number one housing priority in the city. In fact it could it ultimately mean the difference between life and death for some patients",0,1,0]
["Resident","","Link people to work by public transport","There are too few public transport facilities at industrial estates. It should be possible for people to get to any industrial estate from all local residential areas by public transport. It should not be necessary to travel to work by car. Car parking in industrial units should be severely restricted to encourage use of public transport.",2,3,0]
["","","Make the vision shorter and punchier","The vision is too long and is just a stringing together of the strategic objective headlines and some of the detail. I stopped reading after the first few lines.  My effort just from what is written without necessarily agreeing...  By 2041, and beyond the Cheltenham, Gloucester and Tewkesbury area will be a thriving, beautiful, energy efficient, safe, resilient and healthy place to live.  People’s housing needs will have been met through the provision of sustainable, high-quality market, affordable and other specialist homes. We will have conserved the area’s special landscapes and its attractiveness as a place to live and visit and have a network of interconnected green spaces and waterways to secure a high-quality environment for people and nature.  ﻿We will have healthy, accessible and walkable neighbourhoods, active and sustainable travel and provision of new transport systems to enable local people to access employment and sport and leisure facilities for a healthy lifestyle.  We will have made the best possible use of brownfield sites in built up areas and large-scale, comprehensively planned new development to ensure our valuable green spaces and highest quality farmland are preserved. The area’s city centre, town centres and high streets will be thriving as a result of careful management of development and land uses.  We will have attracted and be retaining a younger workforce. There will be new premises and flexible workspaces to support a flourishing economy and we will be a focus for inward investment, innovation and growth in cyber and digital-tech, food/agri-tech, advanced engineering and tourism.",1,4,0]
["Resident",null,"Observations On Draft Vision","Some comments on the Draft Vision -  Para 1 - is it only green growth which will provide this, or is it growth, including green growth?? What if green growth is curtailed, or simply doesn't happen??  Para 2 - presumably we want to attract a younger workforce, whilst motivating, re-skilling and retaining those already there, and attracting the right, new older workforce too??  Para 3 - housing - should this call out the need for appropriate build standards, minimising ongoing energy consumption, etc.??  Para 4 - should this be explicit in calling out active / sustainable / public transport as being the priority, at the expense of private??  General - should something be said about linkage to surrounding areas?? Playing a role?? Join up?? Engagement??  General - overall, really like the Draft Vision,  it is quite long, however - should some of this be moved elsewhere??",7,3,0]
["Resident","","Shift to strategic planning for housing","We cannot continue to drift with housing development. Our infrastructure (schools, etc) is becoming strained. Developers are looking for cheap greenfield sites to drive their profits. There continues to be growth in population driven by the attractiveness of Gloucestershire and immigration.  Now is the time for a major attractive new settlement with state of the art infrastructure with spare capacity for future growth. This should be designed to provide the variety of homes needed, not more 4-5 bedroom houses. Lets support the young members of the society find their first homes and provide homes for the elderly to proactively encourage them to move from their existing large properties (creating space for families) into beautiful communities (at reasonable cost).  The strategic development should not be excuse for poor quality homes or infrastructure. The town should be built with a pre-defined character (like Bath does) set out through planning principles. Let's avoid a mash-mash of styles driven by developers!  A new strategic development provides a real opportunity to make healthy communities, flood protection, biodiversity and renewable energy to be by default.  Developers should be pushed to build on brownfield sites in urban areas and penalised to build in Greenfield areas through the costing model used to define their infrastructure contributions. Building in urban areas should always be the preferred choice.",10,1,0]
["Resident",null,"Standardised housing","A standardised range of houses whereby the facade can be changed but the remainder is standardised can improve quality, environmental rating, speed of construction and reduce cost significantly. If parts of the house can be built in a factory even better. Planning could impose the build standard and potentially guarantee business to a standardised house builder to locate his business in Gloucestershire.",0,2,1]
["SLP Team","SLP Team","Sustainable locations and active travel","Growth in sustainable locations will have enabled the provision of healthy, accessible and walkable neighbourhoods, the promotion of active travel and sustainable travel, and provision of new transport systems that work for local people.",7,2,0]
["Resident","","Tewkesbury Borough Council need to justify their assumptions","I would like to see evidence that the SLP body has shown due dilligence in producing this unsubstatiated report.  1) Where do the required housing figures come from, please share reports and studies. (facts and figures).  2) Have you surveyed the purchasers of all new housing built in the last 5 years, I hope so.  3) What are the proportions & type grouping of the buyers? for eg. First time buyers, Local buyers, buyers from outside Gloucestershire, developers, second home buyers, Foreign buyers (non UK based). and please not a cobbled report that no one public servant has the guts to sign. like the SLP.  4) Why has Tewkesbury land grabbed Longlevens and potentially grabbing Elmbridge? is it to complete their plan to overload Gloucester road infrastructure? Hands off Barnwood you medievel scoundrels, this might just lead to a battle of the green belt.  5) I dont really think Innsworth or Down Hatherley should be Tewkesbury either....there is a link all these locations have or are suffering from over development.  6) Tewkesbury stays relatively the same -  oh it has the good village award for its flowery roundabouts is that an excuse to not participate in your own plans? Come on lets build 500,000 homes in North Tewkesbury - PROBLEM SOLVED",0,1,0]
["SLP Team","SLP Team","Training, skills and workforce","Investment in training, skills and development will have attracted and retained a younger workforce and provided new premises and flexible workspaces to support a flourishing circular economy in both urban and rural areas. Inward investment, innovation and growth in key sectors including, amongst others, cyber and digital-tech, food/agri-tech, advanced engineering and tourism will have been fostered.",1,0,0]
["Resident","","Use the green belt","The Gloucestershire Green belt lacks wildlife and landscape interest and is occupied by uses such as the airport.  It is by far the most sustainable location for new development with all the services of Cheltenham and Gloucester on its doorstep. It also has the best bus route in the county and a brand new cycle highway.  Sensitive development could increase its biodiversity and even landscape value. If the airport was used for residential development there would be other benefits in terms of local amenity.",0,1,1]
["","","Where’s the detailed vision of how we’ll be living our lives in the 2040s?","Now is the time to think and plan ahead and stop incremental short term planning where housing is built seemingly ad hoc to meet demand (although supply and demand aren’t always matched to create the type of housing people need in the places they want to live) with a failure to invest in the necessary infrastructure causing tension and frustration as traffic jams just get worse, people can’t access doctors or dentists and there is a fight for places at nearby schools.  What will life be like in  the 2030s and 40s? What will family life look like? What will AI do to the job market? Will many people continue to work from home? How will social needs be met by providing opportunities to build communities?  If we start with a vision of how people in the coming years will be able to enjoy fulfilling lives then we can start to fill in the detail of how we can achieve this by building first the right infrastructure then the right kind of facilities and houses in the right places.",2,2,0]
[]
[]
["Comments received on above suggestions"]
["Your role ","Organisation","Title ","Comment","Likes"]
["Resident","","Build on the airport.","If the airport is removed, we need to increase our rail infrastructure to provide suitable alternatives to air travel.",0]
["Resident","","Build on the airport.","No, the regional airport should remain untouched as it provides good transport access and commercial catalyst for surrounding businesses.  It also provides a green buffer between Cheltenham and Gloucester whilst supporting aviation leisure services which larger airport cannot support.",0]
["Resident","","Culture and heritage","Need to pay more attention to curating a broader “night time” economy with a wider appeal.   More midsize live music venues. Encourage racecourse/centaur to play a wider part and improve transport.  Better transport options into evenings, particularly between urban centres.",2]
["Resident","","Culture and heritage","'@David Heat  Agreed, nightlife is important to young people especially and there's no reason we shouldn't encourage it in our town centres with good evening transport and nightlife areas.",0]
["Resident","","Culture and heritage","If a development is right beside an important local heritage area, build sympathetically. If not, don't over regulate house builders during a housing crisis. Just build something.",0]
["Other","Tewkesbury Civic Society","Culture and heritage","The \"Night time\" economy in smaller market towns can run in opposition to intention to rebuild resident communities. Tewkesbury for instance has suffered badly in the past by ill run late night venues. Montells and the Abbey Mill were classic examples, there have been others, fun for those living elsewhere, painful for locals. Such venues should be confined to the larger urban areas, Cheltenham and Gloucester.",0]
["Other","Tewkesbury Civic Society","Culture and heritage","The Authority makes great play of the value to tourism and the local economic benefits of the Heritage assets incorporated in the Conservation Areas within communities like Tewkesbury town, however it allows wheelie bins to proliferate  on pavements within that same area! The lack of a policy REQUIRING rather than REQUESTING that such bins are not kept on pavements is unacceptable if we are to truly value and exploit the Heritage assets we have. HSHAZ money is being spent , very usefully, by one group whilst another allows bin blight in the same proximity!",0]
["Resident","N/A","Decarbonisation","Good point, @Matt Dimond-Brown  - being honest - about what we know, what we don't, what things look like, what we may well need to do... It's all part of it, isn't it??",1]
["Resident","","Decarbonisation","It'll come to a point where we're doing absolutely anything we can to decarbonise. Let's start now and prioritise rail transport and cycling corridors.",1]
["Resident","N/A","Decarbonisation","'@Ynte Lammertsma - absolutely agree... It's the old adage - start as early as you can, it'll be easier that way, in the long run.",0]
["Resident","","Harness green growth","Can we request future developments are carbon negative! this would help work towards UK's goal of being a carbon neutral.",1]
["Resident","","Harness green growth","'@Sam Allin We have a housing crisis, we just need to build something. Don't over regulate during a crisis.",0]
["Other","The conservation of swifts and cavity nesting bird species","High quality environment for people and nature","Improve the biodiversity of the built environment by requiring all new building to include nesting provision for cavity nesting species of birds. BS 42021: 2022 provides full detail and should be referenced in the Local Plan (https://knowledge.bsigroup.com/products/integral-nest-boxes-selection-and-installation-for-new-developments-specification-1?version=standard). BS42021 has been endorsed by the NHBC in NF89 Biodiversity in new housing developments https://www.nhbc.co.uk/binaries/content/assets/nhbc/foundation/biodiversity-in-new-housing-developments.pdf page 42. “Fitting at a ratio of 1 nest brick per house across the development will ensure sufficient nest sites for colonial species. 3-5 can be located in one house, so helping locate them in suitable locations for access to foraging habitat. The British Standard BS42021 sets out details on nest box installation for the above species into domestic and commercial properties.” Universal bricks, based on the design of a swift brick, are used by 4 red listed species (swift, house sparrow, starling and house martin), as well as much-loved blue tits and great tits and overwintering birds and insects. They are an invaluable boost to biodiversity in a built environment.",1]
["Resident","","High quality environment for people and nature","Don't over regulate house builders during a housing crisis.",0]
["Resident","","High quality environment for people and nature","One of Cheltenham's great strengths, and why I really enjoy living here, is that it has some amazing public spaces and natural features. We need to retain those. It's possible to do that while also providing dense housing developments. Any new housing developments should also be adding green space on the scale of Hatherley or Pittville Park, this is key to preserving the quality of life for people in Gloucestershire.",0]
["Resident","","Housing need","Any major urban housing scheme (particularly social housing) should be incentivised to look at district heating solutions as opposed to more gas or individual heat pumps.  More attention to ability to cool our buildings and urban zones as warmer weather increases and drainage as rainfall increases.  We also need to see capacity for further electrification (both for consumption and micro generation), quality broadband by default, water and sewage.  Waste and recycling infrastructure also has to mature for these high density areas -  cannot keep stacking recycling crates and wheelie bins.",1]
["Local Councillor","","Housing need","Thought should be given to creating more beautiful, well-designed places with a consistent high quality design i.e. tree-lined streets, high quality facades of buildings with developers taking into account local heritage, architecture and materials. Too many new developments contain characterless, boring buildings.",0]
["Resident","N/A","Housing need","More houses should be build so that our children will be able to afford to buy a house when the grow up.",0]
["Resident","","Housing need","We need a review of greenbelt allocation to enable housebuilding on land between Cheltenham and Gloucester. There is plenty of land near the airport (and the airport itself) that can easily be built on. There are not enough brownfield sites for us to build enough homes.  You will always face opposition, but it is your duty to build. Under 25 year olds don't stand a chance otherwise.",0]
["Resident","","Housing need","It should be required that new development provides adequate public transport options based on the number of people living there. At a certain threshold it should be required to have a rail connection. We absolutely can not achieve the future we want with roads choked by private cars.",0]
["Resident, Business owner","","How about you listen to rhe people?","Currently house prices are at an unsustainably high level and without building more homes those prices will continue to rise, putting further strain on family budgets and making it impossible for young people to own a home or even rent affordably. A very large number of ordinary people will benefit financially from high-quality affordable housing. This is not gaslighting, it is simple economics.  Why would Cheltenham, Tewkesbury and Gloucester councils wish to maximise the profits of big developers? Unless there is actual, concrete evidence of bribery or corruption this is an irresponsible, baseless accusation and smells strongly of conspiracy theory.  Finally, as an idea, \"how about you listen to the people\" is a very strange proposal on a website which is explicitly designed to elicit feedback. That's the whole point of the website!",0]
["Resident","","How about you listen to rhe people?","'@Duncan Thacker Firstly there is absolutely relation to house building and prices. The vast majority are not actually \"affordable\" in any sense. There is a lot of evidence that irrespective of the number of houses built, prices go up. Go and check out the data on this yourself. Gloucester has had a record increase in population last year because of record housebuilding. Prices have in no way become more affordable as you incorrectly insinuate. Of course they want new homes, they want new council tax payers. Of course there is financial gain bore for councils and developers. As for this site, the vast majority of people do not even know it exists. And your build build build narrative, which is complete unsustainable and does not even achieve affordable housing targets, is not in any sense popular in Gloucestershire. Also, why does Tewkesbury and Stroud continue to build eye-sore private housing estates on the edges of Gloucester and Cheltenham? It's disgraceful.",0]
["Resident","","How about you listen to rhe people?","'@Duncan Thacker Duncan, you want to open your eyes, I totally agree with Joseph there is no sense in this and to have it imposed by Cheltenham and Tewkesbury NIMBY's it sucks.  Elmbridge is currently being brought under the wing of Tewkesbury, WTF you may say but the cunning councillors who are supposed to exist to represent their electorate, represent Whitehall indstead and just go through the motions of supposedly consulting the electorate. In my view they (tories) all deserve to be thrown out at the next set of local & General elections. The plot of land behind Elmbrige court has been designated as developable -there you have the reason..... change the boundary to get their way. Tewkesbury imposing further developments on the edge of Gloucester putting tremendous strain on our infrastructure.  Also they have designated Arible land around the balancing ponds at Barnwood Link/A417 as developable, this is green belt for christ sake. I say we should all say a big NO to this SLP cobble.  \"A record increase in population last year\" as you have the facts tell us all where these people came from? London, or further afield, its not local people the houses are big to maximise profits of the developer - lets have the facts not jibberish. Build big homes for Londeners to WFH around Gloucseter = house price inflation.  From your comments \"Why would Cheltenham, Tewkesbury and Gloucester councils wish to maximise the profits of big developers? Unless there is actual, concrete evidence of bribery or corruption this is an irresponsible, baseless accusation and smells strongly of conspiracy theory\" you sound like you may be a local government influencer is that true? If councillors genuinely want ot help young people onto the housing ladder they must build on brownfield sites around Tewkesbury and Cheltenham and Gloucester (if any still exist in Gloucester which i doubt) and build apartments and 2 bed homes not mansions.",1]
["Resident","","Link people to work by public transport","Additionally - for those who want to cycle there should be secure bike parking available.",0]
["Other, Resident, I work for a charity or volunteer in the area","Flood Warden","Link people to work by public transport","As a youngster, Smith's industries in Bishops Cleeve and also Dowty's I believe along with other employers organised their own bus services from Tewkesbury and outlying areas in a contract system with Warners buses and coaches. Other employers did the same.  I agree with the comment above. The bus service from the Ashchurch Railway station through the industrial estates into Tewkesbury could be much improved/",0]
["Other, Resident, I work for a charity or volunteer in the area","Flood Warden","Make the vision shorter and punchier","As a Parish Councillor one always looked at Planning Applications which were pages long with waffle that somewhere was a hidden comment that you weren't supposed to spot but that later the applicant could say - we told you it was in there!  Wonderful words but one doubts that the relative Councils will contribute to the vision. They may prepare the ground but it will be the companies that will sow the seed and reap the rewards.   I was once designated as a Knight of Tewkesbury to give talks at conferences on the benefits of brining your business to Tewkesbury.  Yes they came but later  complained about Junction 9 ,  but the Borough, The County and National Highways have successively walked away from J9 and are still doing so.  After care is just as important as \"the Vision\"",0]
["Resident","","Observations On Draft Vision","It all feels a bit vague to me: a series of laudable aspirations that are surely matched by the aspirations of every city in the UK. What in this plan is going to help Gloucestershire stand out and compete on a national or even global level? How are we going to generate this ‘green growth’ (whatever that is). At the end of the day, our region has to articulate what makes it the best place to work, do business and live in the UK, or else it will just become a huge residential estate for wealthy old people.",1]
["Resident","N/A","Observations On Draft Vision","'@Simon Boswell  - it's the old Vision / Mission / Objective / Aim thing - at which point does it become more tangible??",0]
["Resident","","Observations On Draft Vision","Very little of the vision relates to infrastructure.  There is a brief mention of increased demand for water which will actually be significant but nothing at all about addressing that such as a suggested site for a new reservoir - plenty of water flows through but we need to capture it.  Also the impact on roads needs to be high on the agenda and no longer an afterthought. Many developments will need existing T Junctions and crossroads amended to be roundabouts or traffic lights to cope with the increased traffic levels and roads like Frog Furlong Lane widened as was originally required by planning - the needs of the many outweigh the needs of the few. Plus replacing the over-rail hump bridge  between Badgeworth and the Reddings with a new bridge alongside the old, wide enough for traffic plus pedestrians (and cycles) for when that area is all built up. Liaising with Network Rail will be a long job, start now.  These things need to be done ahead of building houses.",1]
["Resident","N/A","Observations On Draft Vision","'@Robert Weller  - agreed... But isn't vision 'big picture', and infrastructure 'what helps you get there'??",0]
["Resident","","Observations On Draft Vision","'@Dan Etchells In some senses it is but you can't build a vision for life in fantasy.  Even at the vision stage there has to be a perception of a baseline.  You could not build the vision of several thousand houses and then afterwards wonder what those houses needed. My vision encompasses the two things where the housing plugs into adequate facilities - you can't build one without the other and the infrastructure has to come first.",1]
["Resident","N/A","Observations On Draft Vision","'@Robert Weller - hear what you say, but not sure I agree... The vision is, say, '1000 new homes between Churchdown & Cheltenham' - that's the headline... Then there are many, many tangible activities which deliver that... The vision is the headline, not the delivery plan or the enabling activities.",0]
["Resident","","Observations On Draft Vision","'@Dan Etchells Beyond the initial pages the Plan goes on to talk in paragraph 5.16 of the Gloucestershire Local Housing Needs Assessment with annual and 20 year projection for the three authorities.  The total annual need, bearing in mind that their stated aim is to work together on this, is 1,785 new homes annually with 35,700 over the twenty year period.  This could be approached in piecemeal unconnected packets or it could be built into a long term plan to tie them all together in a coordinated fashion. What I am apparently saying not very well is that the Strategic and Local Plan is an attempt to do the latter but is an opportunity to see how the new and the existing structures can work together without overwhelming the existing infrastructure. Sewage pipework and water treatment works need to be in place ahead of anticipated demand.  Getting these things done on a new site is much easier and cheaper than trying to do them afterwards and some of the cost can be directed to the developers rather than all coming out of the local authorities (ie. our local taxes) account.  I am trying to look at the big picture across the three authorities rather than concentrating on us in Churchdown.",1]
["Resident","","Shift to strategic planning for housing","A new strategic development should also enable biodiversity and renewable energy by default.",0]
["I work for a charity or volunteer in the area","Winchcombe Walkers are Welcome","Shift to strategic planning for housing","Fully agree with Alex yet I always hear from Councillors that their hands are tied in favour of developers. Neighbours drive their young children to the next village. Doctors are struggling and cannot attract staff. We need a joined up policy working with all the local agencies.",0]
["Resident","","Shift to strategic planning for housing","'@Robert Talbot Thanks for your support.  I would suggest a strategic development would give good developers plenty of opportunities.",0]
["","","Shift to strategic planning for housing","There seem to be two unrelated, and perhaps contradictory, themes here:  - A major new settlement - Building in urban areas should always be the preferred choice  I agree with the first.  The SLP should identify the location for the new settlement, or at least recognise that work to identify the location is the responsibility of the Councils.  The chosen location should be outside the area of the River Severn Catchment Flood Management Plan  ( https://assets.publishing.service.gov.uk/media/5a7c82dae5274a559005a5f6/River_Severn_Catchment_Management_Plan.pdf ) , so river flood defences shouldn’t be an issue.  More generally, the various documents currently being consulted on should draw upon the content of the Catchment Flood Management Plan.",0]
["Resident","","Shift to strategic planning for housing","At this point we just need to build something. Its disgraceful Cheltenham doesn't have a 5 year housing supply.",0]
["Resident","","Shift to strategic planning for housing","'@Daniel Collins  Cheltenham is constrained on all sides and its only viable option for additional housing comes from densification. This means a steady programme of replacing housing with appartments in the suburban areas. This has happened extensively in the South London borough of Bromley. Building something is not going to help because what will be built will still be unaffordable for anyone on average wages.",0]
["Resident","Churchdown Hill Alliance","Shift to strategic planning for housing","I'd like to see the Plan encourage more community-led (not-for-profit) development - such as cohousing, or group self-build schemes. In most of mainland Europe this is now a mainstream way of delivering new homes. There the councils allocate a portion of the housing land for community groups, the council specifies the cost of the land and the main planning parameters, and they select the community-led schemes that offer the most to the community (eg the highest proportion of affordable homes, or the most eco housing)...it's not about price, more about quality. If this is done alongside private sector development its also a way of speeding up the delivery of new housing as it generates a much wider range of properties.",0]
["Resident","","Shift to strategic planning for housing","I agree that the area needs a far more strategic and targetted approach. However this will only be achieved if we recognise that the total housing need in the current forecasts is flawed and massively overstated and should be reduced down to the lower level of forecast. This will allow the council to work effectively on planning what our town centres are really going to need to be like for 2040 living and they can focus on how to provide genuinely affordable housing for the jobs we really need to be done - which are almost certainly on average earnings.",0]
["Resident","","Shift to strategic planning for housing","'@James Nicholson-Smith I'd disagree with this. We already need more new homes, and nationally we should be building more than we need in order to bring prices down and make homes more affordable for people trying to buy their first home. We can both plan town centres and create affordable housing by increasing supply, we don't have to pick one.",0]
["","","Shift to strategic planning for housing","Every council should know exactly what housing they need for their own population. All buildings not used or lived in should be re utilised to house people The Green Belt should be left as Green Belt including all farm land must be kept for growing our food we do not need new towns built in our countryside or building large housing estates on the edges of towns and villages. The infrastructure never seems to cope We must preserve our countryside and wild areas at all costs",1]
["Resident","","Shift to strategic planning for housing","'@sue phillips If we're going to do this, there needs to be an understanding that we need high-density development in our urban centres. It's possible to make high quality, high-density development that looks good, but we need incentives to create this rather than luxury homes.",0]
["Resident, Business owner","","Sustainable locations and active travel","These are laudable goals but could be more explicitly linked to the stated goal of fighting climate change. Ideally I'd like to see a firm commitment to reducing car dependency across rural and urban communities.  You could also consider adding some language about inclusion, as active travel and transport systems can be a major issue for the elderly, disabled, and less well-off.",3]
["Resident","","Sustainable locations and active travel","We need a large expansion of segregated cycle lanes and restriction of car movements within town centres. Road narrowing will also be crucial to enable accessible, walkable neighbourhoods. Lowering speed limits and banning private vehicles near schools during pick-up and drop-off is also needed.  We need to make it as quick, if not faster to cycle or take public transport across Tewkesbury, Cheltenham or Gloucester than using a car. You will not achieve your goals if otherwise.",2]
["Resident","","Sustainable locations and active travel","'@Daniel Collins Cheltenham is flat as a pancake. We could be a cycling city, but it's more important for people to park their SUV on the side of a major road rather than provide a safe, segregated place to cycle.",0]
["Resident","","Sustainable locations and active travel","'@Ynte Lammertsma  it’s a pretty lumpy pancake out in Charlton Kings but I take your point. With e-bikes growing in popularity there’s a major opportunity to get people into active travel but you need the infrastructure in the towns. Problem is the County council are splurging all their money on the ‘cycle spine’ rather than sorting out the trickier local infrastructure.",0]
["Resident","","Sustainable locations and active travel","Sustainable travel = rail. Trams and trains can be powered by renewable energy and to a certain extent so can buses. It's not just bikes and there seems to be some sort of resistance to mentioning rail in the draft vision.  I think we need to be looking at reopening old railway lines and creating bus and cycle-only transport corridors. The busways could be converted to light rail at a later date when populations increase.",0]
["Resident","","Sustainable locations and active travel","Need to get people out of single person car use, including myself, however that is a problem as the alternatives are not attractive enough. Cycling  can be unsafe. Bus services can be slow and very time consuming. To attend an 1 hour exercise at 10.00 I would need to leave just before 9, walk to bus stop catch bus. After 11 next bus would get me back after 12 and another walk. This is about 2 hr 40 min travel for 1 hour session that by car would take 40 min return journey.",0]
["Resident","","Sustainable locations and active travel","The need to improve cycling routes is obvious however how with the existing infrastructure. The cycle route between Glos and Chelt is a good idea but suffers from existing build restrictions and the deign is poor on certain parts.  Agree we need to use rail lines more, but there is capacity problems in stops and trains. It is difficult to build new bus lanes and re-opening train lines PLUS the costs.",0]
["Resident","","Training, skills and workforce","If you build affordable housing, a young workforce will come.",0]
["Resident","","Where’s the detailed vision of how we’ll be living our lives in the 2040s?","Supportive of Anne’s views. I appreciate not everyone works in an office but hybrid working should be looked at. For example, loneliness can be an issue for people working from home.  Maybe create spaces in communities, eg apartment blocks, from where individuals can work together.",0]
["","","Where’s the detailed vision of how we’ll be living our lives in the 2040s?","There is a significant risk (?) / chance that the number of people Working From Home will return to pre-pandemic levels. Humans are essentially social, and achieve their best when in the company of colleagues. This is especially true for young or inexperienced members of a team. Providing shared work space away from colleagues and the home seems doesn’t seem ideal.",0]
[]
[]
["For complete comments on the Draft Vision please also refer to 'Questionnaire Responses' sheet 'Q.4' and 'Q.4a'"]

{"sheet":"Strategic Objectives","index":6,"n_rows":66,"n_cols":7,"rows_kept":66,"cut":false,"hidden":false,"merged":[[65,0,67,4]]}
["Your role ","Organisation","Title","Description","Comments","Likes","Dislikes"]
["SLP Team","SLP Team","Brownfield land, conserving and enhancing the natural and historic environment","Making as much use as possible of brownfield land and conserving and enhancing the natural and historic environments  1. Protecting and enhancing the area’s unique historic and cultural environment, archaeological heritage and geological assets whilst enabling appropriate development that facilitates the cross-cutting objectives of sustainable development;  2. Conserving, managing and enhancing the area’s unique natural environment and biodiversity, including its waterways, Sites of Special Scientific Interest (SSSI), the Cotswolds National Landscape, and areas of landscape and biodiversity importance, and maximising the opportunities to use land to manage flood water;  3. Ensuring developments support green infrastructure and improve existing green infrastructure within urban and rural areas to provide movement corridors for people and wildlife.",1,0,0]
["SLP Team","SLP Team","Building strong, competitive and sustainable urban and rural economies","* Providing the right conditions and sufficient land in the right locations to support existing and new businesses and deliver the ‘green growth’. * Improve the area’s economic resilience, supporting a highly skilled workforce, skills and educational development attainment. Providing the right environment for business start-ups, entrepreneurship, and the improvement and expansion of education and training facilities to develop the skills employers need. * Supporting the needs of agricultural businesses, encouraging farm diversification, the development of small rural business units, the conversion of existing buildings for rural business use, appropriate expansion of existing businesses. * Supporting effective home working through provision of housing with adequate space and services. * Developing the area’s role as a tourist destination, building on the unique and varied cultural offer that already exists. * Ensuring access to high speed, reliable full-fibre broadband connectivity in both urban and rural areas.",3,0,0]
["Planning agent or developer","Cheltenham Borough Council","Cheltenham Borough - Local Green Spaces - Policy GI1","Policy GI1 of the Cheltenham Plan identifies a number of individual sites across the Borough that have been assessed and designated as Local Green Space.  These sites, which are characterised as “locally-valued open spaces” within the Cheltenham Plan (paragraph 16.15), provides some protection from development without securing the views of local residents.  Over the last 12 months, there have been a number of green spaces which have come to the market as potential development opportunities, which has caused concern for local residents. These are often important areas of amenity and landscaping within established residential estates.  It is proposed that as part of the Strategic & Local Plan review, the Planning Authority should:  * Undertake a review of the criteria used to determine Local Green Spaces, ensuring such sites are open and available to the public; * Review existing designated sites to ensure they continue to meet the criteria set out and are open and accessible; * Seek to identify new sites that could come forward for allocation and protection.",0,1,0]
["Resident","N/A","Comments On Strategic Objectives","Climate Change -  Overall, really like this.  7 - should this say 'reduce waste and promote reuse & recycling'??  General - should it call out contribution to Net Zero explicitly.  General - should it call out, linkage to surrounding / area / national activity??  Urban & Rural Economies -  Again, overall really good.  6 - should this call out full-fibre, or simply say 'appropriate, modern' - full-fibre may not be needed, or may be obsolete by 2040.  City & Town Centres -  1 - Should 'needs of communities' be something like 'needs of all our communities'?? Feels more inclusive of diversity, disability, etc.  General - should there be something on 'enabling everyone to feel safe and included'??  Homes -  General - should this address affordability, in some way??  2 - should this call out the need for build standards which help the move to Net Zero - insulation, move away from gas CH, etc.??  Beautiful & Safe Places -  * What buildings are these?? Public?? All?? General - unless I'm missing it, nothing here addresses 'safe'??  Transport -  General - overall, fully support all of this, but should it be explicit about saying 'key services and opportunities to work are available'??  Environment -  Like all of that.  Healthy & Resilient Communities -  General - could this call out 'all members of our communities, of all demographics' or something to increase sense of inclusion??",0,1,0]
["SLP Team","SLP Team","Delivering a wide choice of homes that meet the needs of our communities","* Delivering sufficient new homes in the right places to meet the needs of our communities, including market and affordable, specialist homes (e.g. older persons), Gypsy, Travellers and Travelling Showpeople and those wishing to build their own homes (self and custom build homes). * Delivering housing of the right size, type and tenure to crate mixed and balanced communities, in sustainable locations and with good access to shops, services and facilities.",3,0,0]
["SLP Team","SLP Team","Delivering well designed, beautiful and safe places","1. Supporting the creation of high quality, beautiful and sustainable buildings and places through good design.  2. Ensuring that new development is integrated well with existing communities and providing well-located infrastructure which meets the needs of communities;  3. Creating a strong sense of place through high quality and inclusive design that respects and enhances local distinctiveness.",0,1,0]
["Resident","","Delivering well designed, beautiful and safe places","I am afraid that recent developments have neither been well designed or beautiful. Will we honestly look back on the building done so far this century with any pride? I doubt it. Recent strategic developments in Twigworth and Innsworth are a case in point.  The problem is that developers have been allowed to get away with far too much by falling back on affordability and frankly because of a lack of proper supervision by planning departments. However, beautiful developments need not necessarily be unduly expensive and given the profits being made by the big home builders they have plenty of margin within which to operate. I recommend the following:  Insist on a set of design criteria from the outset which must be agreed at the time of the granting of outline planning permission and from which the developer cannot deviate.  Reduce density and give people some breathing space.  Reinforce planning departments with empowered design consultants who can hold developers to account.",0,4,1]
["Resident","","Ensure areas used for dog recreation are retained","A field declared to be \"potentially deliverable\" behind Oldbury Orchard in Churchdown is the only area in which dogs can be safely exercised off-lead. It is regularly used by many dog owners (of which I am not one). Most other areas in Churchdown require dogs to be on lead or carefully supervised as the areas are also used by children. There needs to be adequate dog exercising areas in all urban areas where children's activities are not impacted by dogs.",1,1,0]
["SLP Team","SLP Team","Ensuring strong and vibrant city and town centres","* Ensuring a network of city and town centres that meet the needs of communities, including supporting cultural uses and events, and that are able to respond and evolve as the role and function of centres changes. * Support the provision of a wide range of different uses appropriate to city and town centres, including new homes, to create activity at different times of the day and build an active city and town centre community. * To draw on the uniqueness of the different centres in planning for their future.",2,2,0]
["Resident","","Ensuring strong and vibrant city and town centres","Gloucester has become an embarrassment. For a historic cathedral city to be in such a poor state is a very poor reflection on those charged with its upkeep. You need to:  Develop the centre of Gloucester to get people back into the city by getting rid of parking charges and reducing business rates.  Where shops are being left empty convert them to attractive affordable housing but ensuring you do not create ghettos.  Create better linkages between Gloucester Quays and the City.  Prioritise attractive brown field mixed use developments.",3,2,0]
["Resident","","Five Year Supply","If we are going to have a Strategic and Local Plan for Cheltenham, Gloucester and Tewkesbury it follows that we should then have a shared 5 year supply target. This would get rid of the ludicrous position where Tewkesbury cannot demonstrate a 5 year supply because much of the new build in Tewkesbury Borough has been been counted towards Gloucester's targets. It would also make it more difficult for developers to game the system by withholding supply to force through windfall opportunities.",0,2,0]
["","","Flooding -  the proposal needs to go further","You say: “Ensure development is located in areas that are not liable to flooding…”  You should also be considering the impact of development on the flooding of other areas (down stream of the site).  You should be planning appropriate use of the flood plains, setting aside land specifically for that purpose. Quoting from the Environment Agency’s River Severn Catchment Management Plan  ( https://assets.publishing.service.gov.uk/media/5a7c82dae5274a559005a5f6/River_Severn_Catchment_Management_Plan.pdf ) :  “Encourage compatibility between urban open spaces and their ability to make space for rivers to expand as flood flows occur, particularly in key locations such as Cheltenham and Tewkesbury. One example of a flood- compatible use is playing fields. Appraise strategies to create ‘blue corridors’ by developing/redeveloping to link these flood-compatible spaces.”  The strategy should recognise the ongoing work of the Environment Agency to reduce the risk of flooding in Newtown and Tewkesbury  ( https://environment.data.gov.uk/flood-planning/explorer/cycle-2/measure?uri=http%3A%2F%2Fenvironment.data.gov.uk%2Fflood-risk-planning%2Fdata%2Fmeasure%2F0203809030 ( https://environment.data.gov.uk/flood-planning/explorer/cycle-2/measure?uri=http%3A%2F%2Fenvironment.data.gov.uk%2Fflood-risk-planning%2Fdata%2Fmeasure%2F0203809030 )  ):  ”Between 2021 and 2027, the Environment Agency will investigate the benefits of slowing the flow of tributaries into Tewkesbury and identify optimum locations for natural flood management measures and river restoration in the catchments of the Carrant Brook, Tirle Brook and River Swilgate in/upstream of Tewkesbury to inform future works to reduce flood risk and improve the environment in the Avon Warwickshire Management Catchment.”  Carrant brook flows through Ashchurch to the Avon just south of Mitton. In the 2007 floods (pictured above) it contributed significantly to the flooding of properties and businesses, not just around the Bredon Road, but more generally in Newtown and Tewkesbury. The authors of the Catchment Management Plan suggest that in a similar future flooding event, even more properties could be flooded due to changes arising from climate change.  “There is a relatively high level of fluvial flood risk, much of it in Cheltenham, Gloucester and Tewkesbury with approximately 3,350 properties at risk in a 1% flood event.  \"In the next 50 to 100 years, it is estimated that as a direct result of climate change and urbanisation the number of properties at risk from flooding in a 1% flood event will rise to approximately 4,160”.  The proposal for the Garden Communities includes around 5,000 homes being built within the drainage basin of Carrant Brook and Tirle Brook on land north of the A46. It is suggested that the SLP will set out the vision for development during the next 15 - 20 years. I suggest that the consequences could stretch much further into the future. Once building is allowed to the East of Aston Cross, it would likely continue up to Teddington Hands. That land would be seen as ideally suited to satisfying TBC’s requirement for an additional 500 new homes each year. During the next 50 years, Tewkesbury will be expected to provide around 30,000 additional homes. At the current density of 18.9 per ha, that would require around 1600 ha of land, which is around 10 times the area of land between Aston Cross and Teddington Hands, bounded by the A46, Bredon Road, Crashmore Lane and Carrant Brook. In fact not all of the 160 ha would be available for development as a tributary of Tirle Brook runs across the middle.  Government guidance on proposals for creating garden communities stresses the importance of communities being built on a sustainable scale – with infrastructure to allow the communities to function self-sufficiently on a day-to-day basis - with capacity for future growth to meet the evolving housing and economic needs of the local area.  The proposed Aston-Fields community does not therefore qualify as a Garden Community.  At the peak of the 2007 floods, the level of the water in Carrant Brook, and its flood plain, was at least 1.8m above normal, and it continued in that state for well over a week. Building in its drainage basin can only exacerbate the situation and I doubt that it would be economically viable to incorporate effective Sustainable Drainage Systems into any planning proposals for the area.  A much better use of this land would be to heed the messages from the Environment Agency:  “ • Development/redevelopment must be managed to minimise flood risks. Methods must be sustainable over the long-term. For example, making more space for rivers through urban areas via ‘blue corridors’ (i.e. Restoring access for floodwater onto key strips of floodplain. This requires redevelopment to be limited to flood-compatible land-uses e.g. parkland).  \" • We plan to take opportunities to restore sustainable natural storage of floodwater on undeveloped floodplains, in order to reduce dependence on raised flood defences, as this is not sustainable in the long term, and to offset increasing flood risk from trends including climate change.”  When the full cost of flooding in Newtown and Tewkesbury is taken into account, that would a much better use of this land.  These are not just my concerns. Since the beginning of February 2024, a petition to this effect has been viewed over 3000 times and 270 people have put their names to it  https://www.change.org/p/help-save-tewkesbury-from-flooding",3,2,0]
["Resident","","Higher consideration of building secondary schools","It is great to look at expanding established settlements or creating new ones, and as standard these come with the usual facilities of a few shops and a primary school.  However there has been very few secondary schools built.  By increasing the housing numbers, trying to achieve a balance demographic of ages, this results in the number of families increasing and the provision seems lacking once children leave primary.  For example in Quedgeley we have the option of Severn Vale, or if you fancy the hike, there's Holmleigh. Yes there is a grammar school, however we are hearing that local children are being allocated to schools over an hour away due to lack of space. There needs to be more forward thinking solutions.",0,3,0]
["","","Home Based Business and Start Up Units","'----------------------------------------------------------------- Building strong, competitive and sustainable urban and rural economies -----------------------------------------------------------------  This objective should include not just home based working but home based businesses that require more than just a desk and computer. Often refered to as a garage start up where a space is used to make protatypes or small batches before progressing to purpose built facilities. In addition there is a crying need for small start up units rather than the larger industrial estate type units to enable a business to take a smaller growth step.",0,1,0]
["","","Measures For Objectives and Simpler Words","The lack of measurement is often a failing when presenting strategic objectives. Words that are not measurable against the final proposed plan and then actual development are just a wish list and will not help communities but will allow developers to get around the intent. I challenge the planners to say how they will measure success for each objective and if it can not be measured then change the words. Words like supporting, minimising, avoiding etc are all very well but will lead to much argument at examination and then when a strategic plan is agreed at development control.  I also challenge the planners to reduce the number of words and even the number of objectives as there is much repetition and overlap.",0,2,0]
["Resident","","Meeting the Challenge of Climate Change","I think there is an under estimation of the potential impacts of climate change especially in relation to flooding. With rising sea levels and increased precipitation due to warmer seas I suggest we need to challenge previous assumptions and mitigations. There is also insufficient consideration of the cumlative impact of development on sites close to areas that flood.  Secondly, may of the strategic developments that have been built out are currenlty increasing traffic rather than reducing it. This is because supporting infrastructure and facilities are mot being provided meaning thst people have to resort to driving further afield to access schools, hyekathcare and essential services such as Post Offices.",0,3,0]
["SLP Team","SLP Team","Meeting the challenges of climate change","* Ensure that growth contributes to decarbonisation through reduced reliance on fossil fuels and achievement of biodiversity net gain; and the delivery of zero and low carbon development that is resilient and adaptable to climate change incorporating measures to aid urban cooling and biodiversity such as green walls and tree planting. * Ensuring growth takes place in sustainable locations that minimise the need to travel and provide genuine sustainable transport and active travel options. * Making the most effective use of previously developed land, including higher density development in city and town centres and other locations well served by public transport. * Ensure development effectively integrates with existing development, and/or is a self-contained development that provides shops, services, facilities through walking, cycling or public transport. * Delivers low and zero carbon energy development, making the most effective use of renewable energy opportunities, both in new developments and off-site energy generation. * Ensure development is located in areas that are not liable to flooding, considering the implications of climate change, making effective use of sustainable drainage systems and natural flood management techniques. Ensure that existing infrastructure is adequately protected from the threat of flooding, and that existing flood defences and protected and enhanced. * Ensure development incorporates measures to reduce waste. * Ensure people can make carbon friendly choices at home by providing easy to use cycle storage, covered space to dry washing outside, space to grow food and compost.",0,3,0]
["Resident","","New settlements","The scenario for new settlements provides a chance for designing a community from a blank page. This would give the opportunity for a diverse, sustainable, well equipped and interconnected communities.  As these developments would be new towns they should be developed alongside schools, GPs, community spaces, amenities and employment. Key for success in this would be to focus on public transport to ensure that they are well connected.",3,2,0]
["Resident","N/A","Places of Worship","More place of worship should be included in the plan. If 23,000 familes are project to move into the area over the next 20 years then surely places of worship should be included in the place so those who want a place to worship will have one.",0,1,0]
["","","Plan for out of town (food and other) shopping in the Tewkesbury area","You envisage 10,000 new garden communities homes being built in the coming years, yet we already lack local supermarkets and other stores with adequate onsite free parking. Although Tewkesbury boasts an Aldi and Morrisons, many residents choose to travel the Bishops Cleave or Cheltenham to gain access to a broader range of shops.  Land-use planning should also be addressing this need, not just homes and jobs.  Similar considerations must also be given to schools and medical facilities.  Have these considerations been lost in the transition from Garden Town to Garden Communities, or were they never there?",10,1,0]
["SLP Team","SLP Team","Prioritising sustainable transport and active travel","1. Reducing the need to travel by creating real options for healthy, accessible and walkable neighbourhoods where key services are available without the need to use motorised transport;  2. Promoting the use of sustainable travel modes by improving existing and providing new frequent public transport links and safe walking and cycling routes in all new developments;  3. Reducing reliance on the private vehicle by improving access to services in rural and urban areas through new development, improved integrated transport links and supporting local and community led transport initiatives in the Local Transport Plan;  4. Creating a genuine choice between different modes of transport by integrating new development with existing networks and enhancing these wherever possible.",2,0,0]
["SLP Team","SLP Team","Promoting healthy and resilient communities","1. Delivering new developments that are supported by the necessary social and community infrastructure, including schools, open space, playing fields, community facilities and green and blue infrastructure and promote community cohesion.  2. Supporting and safeguarding village shops that serve the everyday needs of local communities.  3. Delivering new developments that are fully integrated into the green infrastructure network to allow people access to nature and green spaces to maximise wellbeing and active travel opportunities.  4. Ensure new developments create high quality living environments and prioritise health and mental wellbeing.  5. Ensure that all homes have useable functioning amenity space that allows residents the opportunity to live, work and relax outside.",1,0,0]
["Resident","","Public Transport First","Self-contained developments are a good idea in theory but I'm struggling to think of any new developments recently that provided new stores, employment opportunities and education at a scale that made sense. Mostly they are isolated islands of new single family homes.  Councils need to be focused on ensuring that public transport to new developments is reliable and sustainable. In the short term this means dedicated bus and cycle lanes and signal priority to buses at intersections.  Later on, bus lanes can be converted to tram tracks as density increases.  Rail rights of way should also be identified and protected for the long term by council, with station sites reserved. We will eventually need to connect our communities by heavy rail to tackle the climate crisis - reserving the space from the outset (or protecting old former railway rights of way) is the key to planning for the future.  We must, as a matter of priority, put pedestrians, cyclists and public transport users first over private cars.",1,1,0]
["Resident","","Service Villages","The new SLP needs to get rid of the notion of service villages. The majority of service villages are a complete misnomer because they have no services and planners/developers should not try and pretend that they have.",2,2,0]
[]
["Comments received on above suggestions"]
["Your role ","Organisation","Title ","Comment","Likes"]
["Other","The conservation of swifts and cavity nesting bird species","Brownfield land, conserving and enhancing the natural and historic environment","Improving green infrastructure within urban areas for people and wildlife by providing 'habitat' within the fabric of the buildings. For example, ensure all new development (houses, public buildings, industrial buildings, home extensions etc.) provide nesting cavities for building dependent species. Universal bricks, based on the design of a swift brick, are used by 4 red listed species (swift, house sparrow, starling and house martin), as well as much-loved blue tits and great tits and overwintering birds and insects. They are an invaluable boost to biodiversity in a built environment. BS 42021: 2022 provides full detail and should be referenced in the Local Plan (https://knowledge.bsigroup.com/products/integral-nest-boxes-selection-and-installation-for-new-developments-specification-1?version=standard). BS42021 has been endorsed by the NHBC in NF89 Biodiversity in new housing developments https://www.nhbc.co.uk/binaries/content/assets/nhbc/foundation/biodiversity-in-new-housing-developments.pdf page 42. “Fitting at a ratio of 1 nest brick per house across the development will ensure sufficient nest sites for colonial species. 3-5 can be located in one house, so helping locate them in suitable locations for access to foraging habitat. The British Standard BS42021 sets out details on nest box installation for the above species into domestic and commercial properties.”",0]
["Resident, Business owner","","Building strong, competitive and sustainable urban and rural economies","Great to see 4 about supporting home working, but doesn't it seem a bit prescriptive? If the strategic objective is to support and increase home working, I think it would be fair for more options to be on the table (e.g. economic incentives).  The \"home working\" aspect could also be emphasised as a factor in improving transportation by reducing load on existing networks.",0]
["Statutory/Specific Consultee","Woodmancote Parish Council","Building strong, competitive and sustainable urban and rural economies","The plan should drive up agricultural ecosystem development ie from farm to table (home/restaurant) or farm to other use eg willow furniture/biofuel. Particular emphasis on rules around farmshops, local produce restaurants and hydroponics based agriculture should be focus.",0]
["Statutory/Specific Consultee","Woodmancote Parish Council","Building strong, competitive and sustainable urban and rural economies","Do not allow tourist destination policies to drive up the deevlopment of second homes and airbnb. These have to be low prioity compared to delivering long term genuinely affordable housing for the employees we really need - ie nurses, teachers, police, social care",0]
["Statutory/Specific Consultee","Woodmancote Parish Council","Delivering a wide choice of homes that meet the needs of our communities","The economic forecasts supporting this SLP actually say that we don't need a lot more houses (30,000 is based on flawed forecasting) but we might need a different mix because of our aging population and smaller households. The strategy needs to be to deliver the highest priority need on a targeted basis ie genuinely affordable houses to accommodate the people to fill the jobs we desperately need ie nurses, social care. We should focus on this as the priority and deliver the additional houses for more affluent as a secondary objective. If we continue to approach the problem from the other way round, we never address the problem and housing just becomes more unaffordable.",0]
["Statutory/Specific Consultee","Woodmancote Parish Council","Delivering a wide choice of homes that meet the needs of our communities","We firmly believes in a plan for a diverse and inclusive population which respects other groups needs and everyone contributes. However, groups like travellers need to play their part in supporting and respecting other population groups before expecting land to be allocated to them and services to be provided to them without contributing to the system.",0]
["Resident","","Delivering a wide choice of homes that meet the needs of our communities","Agree with both comments from James.  It would be good to agree the target groups that housing is needed for,  truly understand their needs  and find ways to strongly encourage / incentivise developers to focus on those groups.",0]
["Resident","","Delivering a wide choice of homes that meet the needs of our communities","I think in general we need to build up rather than out -  high density housing near major employment centres like hospitals and universities. This frees up less dense housing stock for families.",0]
["Resident","","Ensure areas used for dog recreation are retained","I am a dog owner, but even I know that we need housing more than we need off-lead dog exercising spaces. People should take priority in these situations.  I do think though we should make sure development has existing green space nearby - parks and similar spaces.",0]
["Resident","","Ensuring strong and vibrant city and town centres","I would argue that reducing parking charges is working against the outcome you are trying to achieve.  Gloucester needs defined, separated corridors into the centre for public transport and active travel. Make travel from the new park and ride on the A40 near Cheltenham free into the town centres of Cheltenham and Gloucester. Easier said than done but worth considering especially if Gloucestershire takes their bus routes back into public hands like Manchester has.  The last thing Gloucester needs is a glut of SUVs and vehicle traffic, putting pedestrians at risk.",2]
["","","Ensuring strong and vibrant city and town centres","'@Ynte Lammertsma Equally, Park and Ride needs to be considered for Tewkesbury. If you are going to build  10,000 new homes in Ashchurch (or elsewhere), serious consideration needs to be given to how those residents will access Tewkesbury town centre, assuming it is going to have an appropriate range of shops and other facilities. If not the residents will likely drive 10 minutes down the M5 and use the new Cheltenham Park and Ride to access Cheltenham or Gloucester.",0]
["Resident","","Ensuring strong and vibrant city and town centres","I think we need to start promoting high-density development in our city centres. Proposed developments like the new houses to be built on the car park near Cheltenham City Centre should be mixed use and high density, not full of single family homes. Promoting low density residential will eventually lead to noise restrictions which will affect nightlife in town centres.",1]
["Resident","","Ensuring strong and vibrant city and town centres","'@Ynte Lammertsma I agree; there are also lots of empty unused buildings (shops preciously) that could be utilised. Towns have the transport networks already in place too.",0]
["Resident, Other","","Ensuring strong and vibrant city and town centres","Agree with Ynte on the parking. But Gloucester defenatly needs a lot of revitalisation in its town centre. It's just another grey city centre with nothing of value drawing people in. The docks should be a blueprint for the rest of the city centre",0]
["Resident","","Flooding -  the proposal needs to go further","Prevent Downstream Flooding by ensuring new developments have attenuation ponds. Currently, developers are just concreting over fields that previously helped to absorb excess water, and now the rain water has no-where to go which exacerbates flooding issues.  Surface water runoff is almost always the cause for downstream flooding. Attenuation of rainwater helps to slow the flow of water to a level that makes downstream drainage manage the excess water runoff.",0]
["","","Flooding -  the proposal needs to go further","'@Anne Hill I suspect the most that could be achieved from such measures would be for the developers to provide attenuation ponds for the area of land they have developed. Thus, no improvement to the current state. What the EA seek to do is provide something better than the status quo.  Watching the amount of water flowing down Carrant Brook in flood a couple of weeks ago, made it very clear to me that there was an awful lot of water to be captured from just a couple of days of not particularly heavy rainfall. The best way I can describe it, is to suggest it would likely fill a typical leisure centre swimming pool in less than a minute, and it continued to flow like that for most of a day.",0]
["Other, Resident, I work for a charity or volunteer in the area","Flood Warden","Flooding -  the proposal needs to go further","As a Flood warden of many years for Stoke Orchard and Tredington I totally support and commend this report. With help of the County Flood Management team, we installed flood gauges on the Dean and Swilgate two years ago.  I am afraid we proved what we had know for years. the Attenuation/mitigation' systems heralded as life savers in Bishops Cleeve were totally useless. At the last Appeal, i was lampooned by the Inspector so I contacted him with the proof which some Dr ....... had said was rubbish.  the Inspector refused to speak with me.  Enough said. The Environment Agency recently installed their own gauge at the Swilgate Bridge in Tredington and last week during the high rainfall area, their Flood Alert to me advised that the rise was so steep that they were convinced that their gauge was faulty. It was absolutely correct. and they are about to build 4000 houses at Elm Park all draining into the Swilgate and as yet they haven't agreed the drainage infrastructure  for those 4000 houses.  so much for the JCS SLP or whatever. Tewkesbury do not even have a drainage officer as yet! - have they?  This should be a completely separate part of the the whole SLP not tucked in behind something else.,",0]
["I work for a charity or volunteer in the area","","New settlements","The provision of libraries should not be overlooked.",0]
["Resident","","New settlements","It needs to be in appropriate places though; building thousands of new homes West of Gloucester (Highnam/Churcham area), when the only transport road network is already insufficient with only 1 crossing over the Severn at Over Bridge will be a disaster, plus this area floods which closes the A417 at Maisemore which exacerbates the problems. The B4215 is a B road in name only and is used as a short cut for lorries from the M50 heading to Gloucester and beyond.  All traffic from the Forest of Dean has to also use the A40/B4215......This is NOT an area that has the highways infrastructure to cope with these massive new developments which would be better suited where Motorways and A roads are already in place.",0]
["Resident","","New settlements","I agree building a large settlement in the west of Gloucestershire in the Highnam/Churcham area makes no sense. The routes into both Cheltenham and Gloucester are bottlenecks. Following the building of new houses at Newent etc. has caused increased congestion for traffic trying to move towards these two conurbations . This is made considerably worse in the event of any accidents or flooding. Before you can propose large settlements in any area you need to make sure the infrastructure is in place this includes both the roads, schools, drainage and sewage schemes etc. New settlements also need to be well planned not just ad hoc developments where farmers are willing to give up their land. Highnam is extremely well planned with the traffic going around the spine road and children being able to walk to school through safe pathways within this boundary.  This well designed layout would be lost if many more houses were proposed.",0]
["Resident","","Plan for out of town (food and other) shopping in the Tewkesbury area","Out of town shopping areas seem to precipitate a decline in the older town centres (eg Evesham). For this reason I don't think it's a good idea.",0]
["","","Plan for out of town (food and other) shopping in the Tewkesbury area","Do you believe Tewkesbury has the facilities (including parking), or space to create them, required to support the residents from 10,000 new homes?",0]
["Other","","Plan for out of town (food and other) shopping in the Tewkesbury area","It does not make sense in a climate emergency to get everyone into their cars to visit out of town retail parks to buy rubbish they do not really need.",1]
["","","Plan for out of town (food and other) shopping in the Tewkesbury area","'@Southam Clerk I was thinking of Tesco, Sainsburys, Asda etc. I fail to see how the residents of 10000 new homes will be able to buy the food and other essentials they need in Tewkesbury. The food shops aren’t large enough, parking is inadequate and current public transport from, for example the new housing at Barleyfields, Ashchurch is a joke. Developers may include some small shops, as in Walton Cardiff, but I doubt many residents would choose to rely on them for all their needs. This  needs central coordination from the outset.",0]
["","","Plan for out of town (food and other) shopping in the Tewkesbury area","'@Nigel Tingle Isn't there a large Morrisons in Tewkesbury also?",0]
["","","Plan for out of town (food and other) shopping in the Tewkesbury area","'@David Hall there is indeed and I have added it to the proposal. Do you think that along with Aldi, it is large enough with sufficient parking for the residents of 10,000 additional homes?",0]
["Resident","","Plan for out of town (food and other) shopping in the Tewkesbury area","'@Nigel Tingle If parking is inadequate and public transport is a joke - perhaps the solution is improving public transport and disincentivizing private car use? The council should be building out right of ways to these new developments for public transport.",0]
["","","Plan for out of town (food and other) shopping in the Tewkesbury area","'@Ynte Lammertsma Currently, at least when I last checked, there is one bus a week from Aston Cross to Tewkesbury. If you walk to the bus stop near the railway station there is a much better service. It is unclear who is going to fund a more frequent bus service beyond the railway station, especially one that residents could use for going to and from work. Also, I doubt that many will be happy to be told they should be using public transport for their food shopping. We are now in a state where (give or take) all new homes are provided with 2+ parking spaces / garages, so development roads are no longer cluttered with parked cars. I doubt that it will ever be viable for working age residents, possibly with small children, in rural areas to be totally reliant on public transport.",0]
["Statutory/Specific Consultee","Woodmancote Parish Council","Plan for out of town (food and other) shopping in the Tewkesbury area","The whole idea of sustainable locations needs to hinge on a \"local community\" and not drive up a car dependency. If a Garden Town is planned (which is a good idea if there is a genuine housing need) it should have a very high walkability index, have the services it needs for education and shopping and also be connected by non-car transport for commuting purposes. It should also be super green with a very high delivery of onsite biodiversity net gain. That will only be achieved through a landscape and ecology based plan, building around trees, incorporating natural flood measures and prioritising wildlife highways into the design.",1]
["","","Plan for out of town (food and other) shopping in the Tewkesbury area","'@James Nicholson-Smith I agree; unfortunately, that doesn’t seem to what is contemplated by TBC’s new vision for Garden Communities with homes spread across an area of land running from close to  the M5 in the west, Natton in the Southwest, Seven Bends in the Southeast, extending to the North of Northway; an area of land covering appropriately 3.5 sq miles (with an 8.5 mile perimeter).  Contrast that with the following description of what is being built in Cambridge for a population of perhaps half that envisaged by TBC.  Eddington is the first phase of the North West Cambridge Development, which is being undertaken by the University of Cambridge. The development will ultimately provide 1,500 homes for university and college staff, 1,500 private homes for sale and accommodation for 2,000 postgraduates. Community amenities include a primary school, a nursery, a health centre, a community centre and performing arts space, 100,000 square metres of academic and research and development space, a supermarket, a hotel, a senior living home, sports pitches, retail units, public green spaces, roads and transport routes, sustainable transport provision, an energy centre and district heating network. Outline planning consent was granted in 2013 and construction began that year. The University of Cambridge Primary School opened in 2015 and residents moved into the development in 2017. The community centre and performing arts space opened in 2018.  Some of the development’s innovative projects include its waste management and water collection systems. Underground chutes replace traditional wheelie bins in an innovative waste disposal system and the development has the UK’s largest site-wide water recycling system. Solar panels are used extensively in the development. The development has won numerous awards for masterplanning, planning, design, construction and sustainability. https://committees.parliament.uk/publications/8354/documents/85292/default/ https://eddington-cambridge.co.uk. Google maps Street View provides additional  insight CB3 1SE  In greater detail: The proposals seek outline planning permission, in their totality, for the following development, with details of appearance, landscaping, layout, and scale (save for the matters submitted in respect of zones A and C) reserved: • Up to 3,000 dwellings;(ClassC3 and C4) • Up to 2,000 student bed spaces; 98,000 sq.m.(Class C2) • Up to 100,000 sq.m.  new  employment floor space, of which: • Up to 40,000 sq.m. commercial employment floorspace (Class B1(b) and sui generis research uses) • At least 60,000 sq.m. academic employment floorspace(ClassD1) • Up to 5,300 sq.m. gross retail floorspace (Use Class A1/A2/A3/A4/A5) (of which the supermarket is not more than 2,000 sq.m. net floorspace) • Senior living; up to 6,500sq.m. (Class C2) • Community centre; up to 500-600 sq.m. (Class D1) • Indoor sports provision, up to 450 sq.m.(ClassD1) • Police; up to 200 sq.m. (Class B1) • Primary Health Care; up  to  700sq.m.(ClassD1) • School; up to  3,750sq.m.(ClassD1) • Nurseries; up to  2,000sq.m.(ClassD1) • Community Residential; up to 500 sq.m. (Class C3) • Hotel (130 rooms); up to 7,000 sq.m. (Class C1) • Access roads • Pedestrian, cycle and vehicle routes • Parking • Energy Centre; up to 1,250sq.m. • Provision and/or upgrade of services and related service media and apparatus including pumping stations, substations and pressure regulators • Drainage works (including sustainable ground and surface water attenuation and control) • Open space and landscaping (including parks, play areas, playing fields, allotments, water features, formal/informal open space, maintenance sheds, pavilions and support facilities)  https://applications.greatercambridgeplanning.org/online-applications/files/2B8F57871C00055CE47926F9C0EA9307/pdf/S_1886_11-Officer_Committee_Report-4506211.pdf",0]
["Resident","Church ","Prioritising sustainable transport and active travel","Transport through Cheltenham seems very convoluted and not conducive for sustainable growth of businesses. The lack of resilience of East / West travel via Over bridge remain.",1]
["Resident","","Prioritising sustainable transport and active travel","'@Andrew Smith I agree; with the Over bridge being the only way to get from the M50 (lorries use the B4215 as a short cut!), the Forest of Dean, Highnam, Churcham, Newent and surrounding areas into Gloucester and beyond, especially as this area floods, is already putting undue pressure and traffic problems, without adding to them by building thousands more houses West of Gloucester. All the traffic bottlenecks at Over roundabout.",0]
["Resident","","Promoting healthy and resilient communities","There are good examples of infrastructure funding being used to good effect.  More work needs to be done to ensure priority, and potentially through more money from developers, is given to maintain green spaces and increase public services (schools, hospitals, doctors, police, fire service, etc).  Developer infrastructure charges on green field developments should be used to cross subsidise brownfield ones.",0]
["Resident","","Public Transport First","Also build houses where the Highways infrastructure can absorb more cars more easily if needed; unlike building thousands of homes West of Gloucester that floods and already bottlenecks at the one and only Severn river crossing at Over bridge. Even better, build in Towns where the transport network is already there.",1]
["Resident","","Service Villages","Service villages cannot even cope with the residents demands as it is; people have to travel elsewhere to schools and doctors as even the villages that are lucky enough to have some facilities are already full and oversubscribed.",0]
["Other, Resident, I work for a charity or volunteer in the area","Flood Warden","Service Villages","Totally agree, his misnomer and the leverage it carries is ridiculous.  Many small villages are dying while others are being overwhelmed  with houses because the local garage garage has a shop. A ridiculous system when you look at Stoke Orchard and Coombe Hill and others. Perhaps we should close the shop at Stoke Orchard and then no more houses!!",0]
[]
["For complete comments on the Draft Strategic Objectives please also refer to 'Questionnaire Responses' sheet 'Q.5' and 'Q.5a'"]

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["Your role ","Organisation","Title","Description","Other files","Latitude","Longitude","Location","Comments","Likes","Dislikes"]
["Statutory/Specific Consultee","Woodmancote Parish Council","Allocate all AONB and Greenbelt for long term biodiversity and natural flood","Greenbelt is often degraded by landowners so that they can apply for it to be redesignated as ripe for development.  Stop this allocate all AONB and Greenbelt for significant biodiversity gains and natural flood measures.  If this land is owned by developers then planning needs to force offsite BNG and Natural flood measures on these sites.","",null,null,"",0,10,0]
["I work for a charity or volunteer in the area","Gloucestershire Local Nature Partnership","B Lines -  broad wildlife corridors that help insects","Buglife have developed B Lines, https://www.buglife.org.uk/our-work/b-lines/, ideal insect pathways running through our countryside and towns, that should be enhanced with plants that are pollen and nectar sources.  One of these B Lines runs across the Tredington / Stoke Orchard to Bishop's Cleeve area.  It would be good if any new development proposed along this broad B Line area could incorporate measures to create effective and broad East - West wildlife corridors in the development design.","",null,null,"",0,3,0]
["Resident","","Ban new wood-burners","The WHO has made clear the hazard to both human health and the environment caused by the airborne particulates emitted by wood burning stoves.   The SLP should make it clear that the time has come to stop putting these devices into new domestic builds, however 'trendy' or appealing they might be felt to be to prospective property buyers.   A planning restriction should be in place.","",null,null,"",1,3,0]
["Resident","","Biodiversity and Development","Developments and Biodiversity: Biodiversity Net Gain (BNG) will now legally be required to apply to most new developments. However, the development (or part of) that harms the existing land and nature within it needs to be restored to a commensurate level to that which is lost. Too often developers plans to restore nature as a result of a development that are submitted to TBC fall way short of actually compensating for the biodiversity loss. The removal of hedgerows and/or established trees that are a habitat for rapidly declining species, for example, cannot be replaced by the addition of a few saplings within a new housing development and the placement of a few bird/bat boxes at random locations. If there cannot be commensurate compensation for biodiversity loss at a particular site then there are facilities that TBC or developers can use to ensure BNG - for example, approach bodies such as the RSPB who have worked in conjunction with the Construction Industry Research and Information Association to produce guidelines on this and the RSPB have 'biodiversity units' that TBC can buy to help offset net biodiversity loss.  The ecological reports submitted by environmental consultants on behalf of developers locally (and paid for by the very same developers - a clear conflict of interest!) in my opinion generally fail to adequately record the biodiversity that exists at a particular site. The consultancy firm by their very nature will concentrate their efforts on trying to ascertain the presence or absence of certain key species that are protected by law (badgers, bats, great crested newts etc) and therefore could impact whether the development can proceed in it's proposed form. There is far less emphasis on the remaining biodiversity which could be substantial and locally very important - ecologists for example will invariably make a couple of short visits to a particular site to take a general overview of what they see/hear during that visit. These visits are often at the wrong time of year to adequately pick up on the breeding presence of Amber or Red Listed \"Birds of Conservation Concern\". An example of this is the recently approved expanded housing development near Rudgeway Farm, adjacent to the Wheatpieces estate and the new Bloor Homes HQ. This site has a significant population of breeding Skylarks and Yellowhammers - both Red listed species that are in very rapid UK wide population decline. The ecological report for the development completely fails to pick up on this despite the singing Skylarks being obvious to even the most casual observer on any given day in the Spring/Summer. In addition. numerous records spread over several years of breeding activity of these birds has been lodged with the Gloucestershire Centre for Environmental Records (GERC), the very same body that ecological consultants tend to consult locally for the presence of such data. I suspect that ecological consultants are requesting a narrow range of data that would not reveal general wider biodiversity of a particular area and therefore their subsequent report to the developer does not tend to adequately reflect the full extent of the biodiversity that is present. Public feedback on the presence of Red or Amber listed species at a particular site (that is not picked up the ecological consultant that works for the developer) needs to be acknowledged by TBC and more effort made to engage directly with the person or body that raises this via for example your planning portal.  Consideration should be given to notifying local residents of significant proposed land developments within a certain radius of their address and options provided for feedback. There is not enough awareness of such developments and therefore limited engagement or feedback on them on the TBC Planning Portal. In my opinion, attaching the odd random planning notice on lamp posts close to affected area is not enough. Ideas and comments tend to be posted on local website noticeboards which can be a waste of potential valuable feedback for TBC.  Linkage of fragmented habitats: Biodiverse sites within the Borough can end up being isolated in pockets of land, with the wildlife within each site becoming restricted and unable to move to a similar habitat. TBC could plan 'nature corridors' that link such sites and allow wildlife to move more freely. In effect it then becomes one larger biodiverse site. For example, hedgerow corridors linking with woodland sites.  More sensitive management of hedgerows for which TBC has a responsibility to maintain:  This includes hedges on residential estates. For example, there are several stretches of hedge on the Wheatpieces estate that are communal roosts for House Sparrows. These provide vital overnight cover for roosting birds in the winter but every year when they are flail mowed, the evergreen sections are ripped away and the height dramatically reduced. The flocks are then noticeable by their absence the following evening! Several stretches of hedge have been reduced to gappy stumps where once they were thriving. The management of these hedges should be less draconian with better communication with the the appointed contractors to achieve a more sensitive result that benefits wildlife and keeps routeways clear.  Flood alleviation - working with (not against) nature: Move away from short term knee-jerk environmental responses to supposedly try and address flooding to longer term planning that takes a more holistic, wider and cost effective approach and that benefits nature into the bargain. Too often the response is to dredge and straighten a particular stream/river channel and remove or severely reduce the bankside tree cover and vegetation. An example of this is the stream that runs alongside a \"Restricted Byeway\" close to Walton Cardiff village. It did have a really impressive biodiversity that included several species of dragonfly and birds such as Grey Wagtail used to visit. After severe dredging it is now a shell of what it used to be (a sterile, straight channel devoid of micro-habitat) and I detect no improvement in local flood alleviation. We should be restoring ecosystems not obliterating them! I would like TBC to take an approach to land management that seeks to work with nature to restore ecosystems and alleviate flooding - lets create and restore wetlands; approve tree planting and natural regeneration. There is substantial evidence now that tree planting and natural regeneration of trees and scrub can significantly reduce flooding, soil erosion and water erosion - see studies at the Pontbren Project (mid Wales) for example. Alternative environmental solutions may be needed dependent on the actual area concerned.","",51.985616,-2.1364974999999999,"51.985616, -2.1364975",0,5,0]
["Statutory/Specific Consultee","Woodmancote Parish Council","BNG focus for any new housing development outside major cities/towns","There is no excuse. We can build housing that is not only energy efficient and practical but can also incorporate extensive green rooves, rainwater harvesting greywater systems, centralised heating systems, wildlife highways and natural flood measures.  New developments should genuinely conserve and enhance the biodiversity and landscape of the areas outside towns and cities.  The planning system should not be based on meeting minimum standards because that is all the developers will ever deliver. The planning system and policy must drive a higher standard by setting a design code.  This has to be stipulated as must have requirements and not desirable.","",null,null,"",0,7,0]
["Statutory/Specific Consultee","Civic Trust","Build Carbon Neutral housing","Heating housing is a significant fraction of energy use, and passive house design makes this unnecessary. Furthermore, embedded thermal mass can be used to prevent overheating. Essential for this is ensuring that residential streets run east-west.","",null,null,"",0,11,0]
["Resident, I work for a charity or volunteer in the area","","Declare a Wildlife Emergency in Gloucester","Declaring a wildlife emergency would mean that nature would have to be considered in all council decisions.  The State of Nature report in 2023 (from Natural England and others) highlighted the fact that the UK, one of the most nature-depleted countries in the world, is still losing biodiversity. Nearly 1 in 6 species are at risk of extinction.  Whether we consider ecosystem services/ natural capital, or just the enjoyment and mental health benefits people get from spending time in nature, it is vital to conserve what we have and work to improve it. Declaring a wildlife emergency would allow a joined-up plan to ensure we can all continue to enjoy our local wildlife.","",null,null,"",0,1,0]
["Resident, Other","","Engage Local Communities","Find ways to better connect people to climate positive activities and actions. I've struggled to ever find actual advice on how to make my community a greener place. If people know how to help them they will","",null,null,"",0,1,0]
["Resident","","Green corridors","Extend tree planting between existing areas of woodland in the Winchcombe - Prestbury corridor to provide wildlife connectivity.  Replace the recent extensive cull of ash trees along the local roads with resilient UK species.  Consider reversion to formal water meadows, or even wetlands, in areas likely to be prone to flooding, particularly in the Tewkesbury area as a relatively cheap downstream flood-mitigation option and to encourage biodiversity.","",null,null,"",1,14,0]
["Resident","Gloucestershire Wildlife Trust","Include landscape connectivity into planning decisions","More robust policies around retaining landscape connectivity and a reduction in landscape/habitat fragmentation.","",null,null,"",4,5,0]
["Resident, I work for a charity or volunteer in the area","","Increase biodiversity in grass areas with less frequent mowing","There are plenty of grassed areas around Gloucester which are mowed frequently, resulting in very low biodiversity. Where there are no safety issues i.e. visibility for traffic, these could be mowed far less frequently to encourage a greater variety of plant species and hence insects. These could help to provide connection between the small isolated protected areas. Ideally, cut and collect would be used to reduce the nutrient levels in the soil so that the proportion of stronger grasses would be reduced. As well as helping wildlife, this would reduce air and noise pollution from the mowers.","",null,null,"",0,2,0]
["Statutory/Specific Consultee","Civic Trust","Make public transport more attractive","Provide comfortable places to wait for buses; undercover and heated. Existing community hubs and commercial premises can be provided with live feed displays of the progress of buses, so that customers can wait in comfort and security.","",null,null,"",1,8,0]
["Local Councillor","Hucclecote Parish Council","Put nature first!","We always think of our needs and the needs of the other animals that share this world us always seem to be secondary. This needs to change and the SLP should ensure we shift from allowing developers to get away with minimum standards on everything to having to deliver excellence and the highest standards on all aspects of their developments. The highest standards should be for nature where all existing trees and hedgerows baring exceptional circumstances have to be incorporated into developments. Green corridors to link up the green spaces left by developments should be mandatory and relocation of all species effected by developments should be done prior to any ground being broken. Excellence should also be delivered on climate change and all properties should conform to the highest possible environmentally friendly standards. Developers should also be made to deliver a higher percentage of affordable housing. Currently the emphasis seems to be on maximising profits rather than truly delivering much needed housing. Necessary infrastructure changes need to be in place prior to any homes being built. This will ensure the impact on existing communities is kept to a minimum which is something that currently doesn't happen. If we truly need new homes they need to be built in the highest possible ethical ways and they impact every aspect of every development thoroughly thought through before planning is granted. The needs of prospective home owner's cant be allowed to outweigh everything else. The system we currently have seems to brush aside communities concerns about developments. It ignores concerns on flooding, it ignores the concerns of nature, it limits as much as possible peoples chances to have their say. This needs to change!","",null,null,"",1,10,0]
["Other","","Re-Wilding","New developments should have hedging boundaries instead of fencing, rainwater harvesting and wildflower meadows.  New developments must be supported at strategic level with a new reservoir and new sewage systems.  New developments must contribute to clearing local ditches and water courses.  No open plan gardens - they must be enclosed with hedging and trees","",null,null,"",1,10,0]
["Resident","","Solar Panels","Solar panels should be on every new house. Roofs are wasted space and there is a lot of controversy over using farmers fields for them.  Also car parks should have them. I have seen these when abroad, they’re great for keeping your car in the shade whilst shopping, or dry in the rain. Rainwater could also be harvested from them.","",null,null,"",0,10,0]
["Resident","N/A","Strategy & Communication","For me, the trite answer is 'do everything in that table, and it'll all be grand!!'.  But, looking at it - we should have a strategy, which we should communicate, clearly, to all stakeholders. That should include how people can help, how they can change things, etc.  Built -  We should show people where we are, where we intend to go. We should signpost resources available to them to change their built environment - grants, guides, etc. We should make clear statements, supporting and aligned to Net Zero - 'gas boilers are going, this is how you make the transition', etc.  Natural -  Should make clear where we're going, and ask people to help - volunteers, etc.  Movement -  Make clear what's happening.  I'd like us to make a yes / no decision on e-scooters, and - if yes - look at opening up travel on them between Gloucester, Cheltenham, Bishops Cleeve - maybe Tewkesbury.  I'd like to see major footpaths - Wyvern Way / Severn Way invested in and improved.  Renewable -  We should signpost opportunities for people to 'make a change'. Grants, loans etc.  Maybe pilot activity - select a small area, install alternate energy sources, publicise??  Commit to x% of public buildings using rain water, solar power etc.","",null,null,"",1,4,0]
["Other","The conservation of swifts and cavity nesting bird species","The habitat of the Built Environment.","The Built Environment is a habitat in its own right. There are various species who are building dependent or can adapt to a built environment. Therefore the word  ‘habitat’ should be included in the list under this heading or the built environment included under the heading Natural Environment.  It is well document that closeness to nature is good for well-being and so all new development (houses, public buildings, industrial buildings, home extensions etc.) should provide nesting cavities for building dependent species.  Universal bricks, based on the design of a swift brick, are used by 4 red listed species (swift, house sparrow, starling and house martin), as well as much-loved blue tits and great tits and overwintering birds and insects.  They are an invaluable boost to biodiversity in a built environment.  BS 42021: 2022 provides full detail and should be referenced in the Local Plan (https://knowledge.bsigroup.com/products/integral-nest-boxes-selection-and-installation-for-new-developments-specification-1?version=standard). BS42021 has been endorsed by the NHBC in NF89 Biodiversity in new housing developments https://www.nhbc.co.uk/binaries/content/assets/nhbc/foundation/biodiversity-in-new-housing-developments.pdf page 42. “Fitting at a ratio of 1 nest brick per house across the development will ensure sufficient nest sites for colonial species. 3-5 can be located in one house, so helping locate them in suitable locations for access to foraging habitat. The British Standard BS42021 sets out details on nest box installation for the above species into domestic and commercial properties.”",null,null,null,"",8,10,0]
["Resident","","use new development to kick start a wider low carbon economy","Low carbon technology has been stop start for the past 25 years as various government schemes come and go. Firm clear policies that are carried through can bring a degree of certainty for the low carbon sector and allow it to thrive. For too long we have allowed developers to cut costs  and put gas fired heating into poorly insulated homes. These will all have to be retrofitted as we move towards a low carbon future. The ambition is clearly there it is following it through with development control decisions.","",null,null,"",0,1,0]
["Resident","","Water harvesting and recycling","New builds should have a water harvesting system which is then pumped into the new houses to supply toilet flushing/washing machine use etc that does not need consumption safe water.  As we face more droughts, recycling water use needs to be given more consideration.","",null,null,"",0,5,0]
[]
["Comments on above suggestions"]
["Your role ","Organisation","Title","Comment","Likes"]
["Resident","","Ban new wood-burners","Air pollution affects those with asthma and other respiratory problems, but can also cause these problems in the first place.",1]
["Resident","","Green corridors","the extensive cull of ash trees has had a dramatic and devastating effect from not only driving along the roads where it has happened but also views of the landscape from  urban areas, I know that when I used to look towards the hills from Hatherley I could not see many houses and roads that were once shrouded in trees. More tree planting.",0]
["I work for a charity or volunteer in the area","","Include landscape connectivity into planning decisions","Also, habitat destruction needs to minimised.",0]
["Resident","","Include landscape connectivity into planning decisions","Hedgehog habitat has been destroyed on Gloucester St in Wotton under Edge. Current plans to bury the open space under 6ft of rubble will effectively prevent any return of this endangered species.",0]
["","","Include landscape connectivity into planning decisions","'@Valerie  Mitchell  That’s so sad",0]
["Resident","","Include landscape connectivity into planning decisions","I completely agree with this. The Local plan should work with the Wildlife Trust and other local conservation groups to connect local green areas and increase the biodiversity between them. There are many 'Friends of' groups around Gloucester who are working as hard as they can to increase the biodiversity of wildlife in their local parks, but they can only do so much without connecting these small areas together .",1]
["I work for a charity or volunteer in the area","Gloucestershire Local Nature Partnership","Make public transport more attractive","A better bus network with more frequent, affordable and reliable buses would be a start!",1]
["Resident","","Put nature first!","I agree. The whole vision is far too focussed on the needs and wants of people. People are part of a wider ecosystem and the SLP must pay due attention to that. The focus needs to place the environment and the needs of nature at the centre of any policy. There is insufficient detail in the vision on aspects such as nature recovery for example",0]
["I work for a charity or volunteer in the area","action for swifts","Re-Wilding","New building projects often remove existing hedges and trees even when the planning consent expressly requires that they are kept. More attention needs to be paid to retaining existing and enhancing natural features.",1]
["Resident, I work for a charity or volunteer in the area","","Strategy & Communication","I like the ideas about signposting to help convert to solar, non-gas boilers etc.",0]
["Resident, I work for a charity or volunteer in the area","","The habitat of the Built Environment.","Agree with this recommendation of swift bricks.  Building with Nature standards are useful for other similar recommendations https://www.buildingwithnature.org.uk/",1]
["","Swifts Local Network: Swifts & Planning Group","The habitat of the Built Environment.","I agree with this recommendation and have experienced the use of AfS Swift Bricks in my own house as well as others - they work and their implementation as an affordable and easy solution could arrest the decline of this red-listed iconic bird.",0]
["Resident, I work for a charity or volunteer in the area","","The habitat of the Built Environment.","Swift bricks as a permanent universal nest brick for small bird species are an essential ecological measure in new developments, especially as they are given no value in the DEFRA Biodiversity Net Gain metric so need their own clear policy.  They must be installed in accordance with best-practice guidance such as BS 42021, to ensure that a sufficient number are installed in suitable locations.",0]
["Resident, I work for a charity or volunteer in the area","","The habitat of the Built Environment.","This sounds a great idea, as long as careful installation is required so that it is not just a box-ticking exercise without benefits for wildlife.",1]
["","Swifts Local Network: Swifts & Planning Group","The habitat of the Built Environment.","Design Codes & design guidance should require swift bricks in all developments including extensions in accordance with best-practice guidance, as the National Model Design Code Part 2 Guidance Notes (2021) recommends bird bricks (Integrating Habitats section on page 25, and Creating Habitats section on page 26) -  swift bricks need to be included at an early stage by the architect on drawings to be fully integrated with the design and reliably installed on site.",0]
["","Swifts Local Network: Swifts & Planning Group","The habitat of the Built Environment.","Swift bricks are a universal nest brick and significantly more beneficial than external bird boxes as they are a permanent feature of the building, have zero maintenance requirements, have improved thermal regulation with future climate change in mind, and are aesthetically integrated with the design of the building. The wildlife benefits of swift bricks are highlighted by NPPG 2019 Natural Environment paragraph 023, they are the only type of bird box which is mentioned in national planning guidance.",0]
["","Swifts Local Network: Swifts & Planning Group","The habitat of the Built Environment.","Best-practice guidance such as BS 42021 and CIEEM recommends an average of at least one swift brick per home for each new-build development. Many other local authorities are including detailed swift brick requirements in their Local Plan, e.g. Wiltshire Local Plan Regulation 19 stage, which requires an enhanced number of two swift bricks per dwelling (policy 88: Biodiversity in the built environment, page 246 - \"As a minimum, the following are required within new proposals: 1. integrate integral bird nest bricks (e.g., swift bricks) at a minimum of two per dwelling;\" https://www.wiltshire.gov.uk/article/8048/Current-consultation-Reg-19 ), and Cotswold District Council are proposing three swift bricks per dwelling in their current Local Plan consultation (Policy EN8 item 6, and paragraph 0.8.4, https://www.cotswold.gov.uk/planning-and-building/planning-policy/local-plan-update-and-supporting-information/ ), and Brighton & Hove have had comprehensive guidance in force since 2020 requiring a minimum of three swift bricks per development and two swift bricks per dwelling, so these enhanced levels should be considered.",0]
["","Swifts Local Network: Swifts & Planning Group","The habitat of the Built Environment.","Existing nest sites should also be protected and retained, as these are not given any value by the DEFRA biodiversity net gain metric calculation so also need their own clear policy. Building-dependent species return to traditional nest sites year after year, and find it difficult to locate a new site if they lose it. Mitigation should be provided if these nest sites cannot be protected.",0]

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["Your role ","Organisation","Locations","What do you think this location should be used for?","Description","Other files","Latitude","Longitude","Location","Comments","Likes","Dislikes"]
["","","Catchment of Carrant and Tirle Brooks","Flood mitigation","The Environment agency study into alleviating flooding in Tewkesbury https://environment.data.gov.uk/flood-planning/explorer/cycle-2/measure?uri=http%3A%2F%2Fenvironment.data.gov.uk%2Fflood-risk-planning%2Fdata%2Fmeasure%2F0203809030  ( https://environment.data.gov.uk/flood-planning/explorer/cycle-2/measure?uri=http%3A%2F%2Fenvironment.data.gov.uk%2Fflood-risk-planning%2Fdata%2Fmeasure%2F0203809030 )","",51.999812499999997,-2.0968125,"XWX3+W7 Tewkesbury, UK",0,3,0]
["","","Catchment of River Swilgate","Flood mitigation","The Environment agency study into alleviating flooding in Tewkesbury https://environment.data.gov.uk/flood-planning/explorer/cycle-2/measure?uri=http%3A%2F%2Fenvironment.data.gov.uk%2Fflood-risk-planning%2Fdata%2Fmeasure%2F0203809030  ( https://environment.data.gov.uk/flood-planning/explorer/cycle-2/measure?uri=http%3A%2F%2Fenvironment.data.gov.uk%2Fflood-risk-planning%2Fdata%2Fmeasure%2F0203809030 )","",51.973812500000001,-2.1469374999999999,"XVF3+G6 Tewkesbury, UK",0,4,0]
["","","Chargrove Lane","Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements","Land bordering Chargrove Lane is already rich in wildlife, birds, newts, trees and hedges quiet lane and good footpath net work. It is already well used for leisure activities by the local communities.  It could be enhanced if the old perry and mixed fruit orchards were re generated and new planting and more oak trees planted.","",null,null,"",2,6,0]
["","","Chargrove Lane","Food production, Nature recovery , Protected for its wildlife and nature , Wind energy ","Chargrove Lane should be completely protected from further development.","",null,null,"",1,6,0]
["Resident","","Chargrove Lane","Flood mitigation, Protected for its wildlife and nature , Other","Chargrove Lane and the surrounding fields represent a unique and significant contribution to the local community.  The amenity value of Chargrove Lane cannot be overstated. Significant numbers of residents use the Lane for walks, teaching your children to cycle or simply to just be in what feels like true countryside. Any building on this land would be a huge loss to the community and no level of 'landscaping' could ever replace the far reaching views across to Shurdington and Leckhampton Hill.  The land surrounding Chargrove Lane is green belt land for good reason. Up Hatherley Way represents a very definite sountern boundary to Cheltenham and prevents the creation of urban sprall towards Shurdington and Brockworth. Whilst there are some building alongside the A46 these are limited and by far the typical land use is agricutural. The area was given the higest rating in the recent JCS survey.  The land is rich in biodiversity including protected birds, amphibians and reptiles. It is also part of the Badgeworth SSSI impact zone, which is dependend upon the area for ground and surface water.","",51.877805199999997,-2.1175174000000001,"Chargrove Ln, Shurdington, Cheltenham GL51 4XD, UK",0,4,0]
["Resident","","Chargrove lane and surrounding fields","Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements","This lane and the surrounding fields are crucial for the local community. I believe there are great crested newts, bats and many other species of wildlife in this area which is enjoyed by many walkers, cyclists. The fields in the spring and summer are a blaze of wild flowers attracting many different types of insects. Safeguarding this area from future planning and development would secure hopefully the future of the wildlife population","",null,null,"",4,8,0]
["","","Chargrove Lane Green Belt - Valued Landscape","Food production, Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements, Other","Chargrove Lane is a narrow, quiet, low-traffic country lane which offers wonderful views over fields, parkland and orchards to the Cotswold escarpment and also to Churchdown Hill.  It is a much used and valued local amenity for the residents living in the extensive housing estates of Up Hatherley and is used by walkers, joggers, bikers, dog walkers and bird watchers - as individuals, couples, families and groups, including the local Up Hatherley walking and running groups.  At almost any time of the day people can be seen using the lane. Besides providing important wildlife habitats in the protected traditional orchards, hedgerows and trees, it is also a place for safe exercise and a reconnection with nature.  The Green Belt between Chargrove and Shurdington is the smallest Green Belt in the country.  It serves to prevent the coalescence of Cheltenham and Gloucester and therefore it is vital that it is not lost.","",51.883304699999997,-2.1200882999999999,"Chargrove Lane, Cheltenham, UK",0,3,0]
["Resident",null,"Chargrove Lane protect the land, object to any development","Nature recovery , Protected for its wildlife and nature ","Clearly people are passionate  area, I have commented also, my submission is to object to any development in this area due to the importance of it’s important value to all the nature that live in it, it also support people using if for their health and mindfulness. The council need to appreciate and understand how important it is to it’s local residents.  The council needs to listen to the residents.  This area should never be considered for any kind of development.  Protect what we have instead of bowing to greedy developers who have no respect for nature and the animals living in it.  Build in Brownfield Sites ONLY.","",51.876491100000003,-2.1155634000000001,"Chargrove Lane, Shurdington, Cheltenham, UK",1,1,0]
["Resident","Churchdown Hill Alliance","Chosen Hill","Nature recovery , Protected for its wildlife and nature ","The upper section of Chosen Hill (also know as Churchdown Hill) has a wonderful natural habitat - lots of wooded areas and thick cover for a wide range of wildlife. Part of the Hill was managed by the Glos Wildlife Trust as a Nature Reserve; the rest is maintained by the Woodland Trust. The land is currently in the Green Belt and has been designated as a Special Landscape Area. There are rare albino badgers on the site, foxes, rabbits, deer, slowworms and it's a haven for wild birds (for example, green and spotted woodpeckers, little owls, nuthatches, buzzards, swifts, swallows and many more.) The area known as the Tumps also has a rare undisturbed soil base that supports many important wild flowers (for example Bee and Pyramid orchids, bluebells, Stinking Iris, Common Figwurt, Bugle, Yellow Archangel, the Cuckow Flower, Cut-leaved Cranesbill and Viper's Bugloss). And there are 18 butterfly species on the Hill (including Common Blue, Gatekeeper, Meadow Brown, and Speckled Wood). All of this habitat needs to be preserved and protected into the future.  The Hill also has a strong musical heritage too - Gloucestershire’s most famous poet and composer, Ivor Gurney, wrote lovingly about the Hill. Indeed there’s even a piece of classical music dedicated to Chosen Hill. And many other composers - including Herbert Howells, Gerald Finzi, and Ralph Vaughan Williams -  have a connection to the site.  The Hill is also well located for walkers - being within rambling distance of Gloucester, and a few minutes drive from Cheltenham.","",51.869562500000001,-2.1751874999999998,"VR9F+RW Gloucester, UK",0,2,0]
["Resident","Churchdown Hill Alliance","Chosen Hill","Nature recovery , Protected for its wildlife and nature ","The upper section of Chosen Hill (also know as Churchdown Hill) has a wonderful natural habitat - lots of wooded areas and thick cover for a wide range of wildlife. Part of the Hill was managed by the Glos Wildlife Trust as a Nature Reserve; the rest is maintained by the Woodland Trust. The land is currently in the Green Belt and has been designated as a Special Landscape Area. There are rare albino badgers on the site, foxes, rabbits, deer, slowworms and it's a haven for wild birds (for example, green and spotted woodpeckers, little owls, nuthatches, buzzards, swifts, swallows and many more.) The area known as the Tumps also has a rare undisturbed soil base that supports many important wild flowers (for example Bee and Pyramid orchids, bluebells, Stinking Iris, Common Figwurt, Bugle, Yellow Archangel, the Cuckow Flower, Cut-leaved Cranesbill and Viper's Bugloss). And there are 18 butterfly species on the Hill (including Common Blue, Gatekeeper, Meadow Brown, and Speckled Wood). All of this habitat needs to be preserved and protected into the future.  The Hill also has a strong musical heritage too - Gloucestershire’s most famous poet and composer, Ivor Gurney, wrote lovingly about the Hill. Indeed there’s even a piece of classical music dedicated to Chosen Hill. And many other composers - including Herbert Howells, Gerald Finzi, and Ralph Vaughan Williams -  have a connection to the site.  The Hill is also well located for walkers - being within rambling distance of Gloucester, and a few minutes drive from Cheltenham.","",51.869562500000001,-2.1751874999999998,"VR9F+RW Gloucester, UK",1,8,0]
["Resident","","Exposed sites throughout the area","Wind energy ","Carry out a wind opportunity study and identify one or 2 optimum sites and allocate them as area for wind development. A little like TAN 8 undertaken by the Welsh Assembly Government","",null,null,"",0,1,0]
["I work for a charity or volunteer in the area","","Extra trees/rewilding","Nature recovery , Biodiversity net gain improvements, Protected for its wildlife and nature ","This triangle of grass between two roads, currently not used for anything, is big enough for at least a dozen trees, or could be left to rewild for no cost to the council. Myself and the Cheltenham Tree Group would happily get involved to fund and plant any young trees.","",51.897812500000001,-2.0373125000000001,"VXX7+43 Cheltenham, UK",0,8,0]
["Local Councillor","Hucclecote Parish Council","Field in Shurdington Road next to Perrybrook development","Biodiversity net gain improvements, Protected for its wildlife and nature , Nature recovery ","This meadow and its ancient hedgerows should be protected and enhanced to aid natures recovery. The area is already massively over developed with the Perrybrook development and the areas for nature have been massively depleted so this meadow is vital and should be retained and enhanced for nature with tree planting, low mow areas and possibly a pond to boost biodiversity even further","",51.848058400000014,-2.1408646999999998,null,0,7,0]
["Local Councillor","Hucclecote Parish Council","field next to Wheatridge Close","Flood mitigation, Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements","This is an area of grass next to Wheatridge Court which is currently included in the 3 week mowing regime that's in place. This area is used for nothing and I think it could be used for nature recovery and to enhance local flood defences. SUDS could be put in on the eastern part of the site which is close to a local water course and wildflower planting, low mow areas and tree planting could be done, maybe a community orchard?","",51.844238799999999,-2.20566,null,0,4,0]
["Resident, Other","","Gloucester City Beautification","Nature recovery , Biodiversity net gain improvements, Other","Look to \"greenify\" Gloucester City to help improve it's appeal and draw more people in for shopping and living.  Additionally look to improve mental health and air quality.","",51.864244900000003,-2.238156,"Gloucester, UK",1,1,0]
["Resident, I work for a charity or volunteer in the area","","Grass area between Abbeymead Avenue, Valerian Close and Upton Close","Nature recovery , Biodiversity net gain improvements","The parts of this area with grass could be maintained with a meadow mowing regime to increase biodiversity and provide more food for the birds that live there.","",null,null,"",0,1,0]
["Resident, I work for a charity or volunteer in the area","","Grass area outside Clock Tower Park boundary along Bittern Avenue","Nature recovery , Biodiversity net gain improvements","More of this area could be left to a meadow mowing regime, like in the park itself, to increase biodiversity and provide more habitat for wildlife around the river.","",null,null,"",0,1,0]
["Resident, I work for a charity or volunteer in the area","","Grassed areas along path from Abbots Road to Roman Road","Nature recovery , Biodiversity net gain improvements","A meadow mowing regime would increase biodiversity and wildlife habitat in this area, as well as increasing interest for local residents. Alternatively, more small trees or shrubs could be planted, especially those with flowers for pollinators.","",null,null,"",0,1,0]
["Other","","Green Belt Between Woodmancote and Racecourse","Protected for its wildlife and nature , Nature recovery , Biodiversity net gain improvements","Ancient hedgerow restoration  Reintroduction of wildflowers  Recovery of ponds and clearance of ditches  Tree planting","",null,null,"",0,3,0]
["Resident","","Green Belt Land beside Chargrove Lane","Flood mitigation, Nature recovery , Protected for its wildlife and nature ","The orchards should be restored and improved and nest boxes for birds and bats added. The hedgerows should be more carefully managed to ensure year round food sources and shelter for birds and small mammals. The fields are very low lying and prone to flooding. Areas of appropriate planting could create wetland habitats which would soak up the rainwater.   There is very little undeveloped land left between Gloucester and Cheltenham and preserving this wildlife oasis is very important to maintaining the identity of each town. Cheltenham is described as a \"centre for the Cotswolds\", the Cotswolds being a rural paradise and AONB or National Landscape. It must maintain it's green boundaries to preserve the beauty and reputation of the town which grew up due to the health benefits of it's natural environment. The health benefits of this area have been immense during Covid19 lockdowns and the populations of  Up Hatherley and Warden Hill have depended very heavily on the wonderful natural resource of Chargrove Lane and the fields towards Shurdington for physical and mental wellbeing.","",null,null,"",0,6,0]
["","","Land adjacent to River Leadon","Flood mitigation, Nature recovery ","There is a whole stretch of improved grassland alongside the River Leadon around Highnam that floods annually in the winter and so could perhaps be made into a more permanent wetland area for nature recovery. It runs alongside the old railway line/canal. Maybe potential for tree planting also?","",null,null,"",0,1,0]
["Resident","","LAND AROUND CHARGROVE LANE SOUTH OF UP HATHERLEY WAY CHELTENHAM","Flood mitigation, Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements","WILDLIFE / BIODIVERSITY NET GAIN  ThIS area already includeS an orchard with trees protected by TPO, visited by tawny owls and bats which need a green habitat preserving around them to stay viable. The land supports large mammals (foxes and roe deer). It is a hunting ground for large predatory birds: buzzards and red kites. It is visited by lapwings – a ‘Red List’ species which needs every support. I have seen a kingfisher on the stream which runs through the small Nature reserve. There are varied species of butterflies e.g. Marbled White on wildflowers in rough grass, Gatekeepers on brambles. Violets and periwinkles are currently growing by the roadside. There are magnificent mature oak trees, each supporting hundreds of species – and in very urgent need of TPO protection. A remarkable amount is surviving within conventional farming. With some nature-focused management – e.g. wildflower plantings on headlands – even more species could be encouraged. This is a rich oasis near dense housing, much appreciated. It should NEVER be considered for housing and the Councils should work to see how it can be made even more wildlife friendly.  FLOOD RISK MITIGATION  This land is needed to absorb local rainfall. Covering even part of it with hard surfaces would displace floodwater elsewhere. Quite simply, it is very, very wet land, especially around Brickhouse Farm. The document  GREENBELT FEB 2024 Reg18-Dec-HELAA-Spreadsheet-1 (1)  notes ‘surface flooding’. That is extremely obvious at the time of writing! If this land is not used for housing, it can protect local houses from the misery of flooding, and could also be managed as a specialised wildlife habitat. This would enhance both its biodiversity and recreation values!  SUMMARY  The very narrow greenbelt south of Up Hatherley Way in Cheltenham is so heavily used for recreation, rich in biodiversity and liable to flooding that it should remain and be enhanced as greenbelt, however strong the pressures from potential developers. No one can ‘offset’ or ‘recreate’ what is here already! It must not be destroyed.","",51.879331899999997,-2.1200195000000002,null,8,8,0]
["Resident",null,"Land north of Wood Lane, burrow boddington, Down Hatherley","Protected for its wildlife and nature , Food production, Nature recovery ","This area is used by many residents, it supports many species and is a haven for birds of prey, owls, deer and many rodents,foxes and bats and so many we do not see surviving in old oak trees which are known to supports all kinds of wildlife. As well as Farmington’s is a beautiful peaceful area, Greenbelt status is there to protect the land, new hedgerows have been planted by farmers, protect what is already there, nature needs all the help it can get.  Protect our Greenbelt land, it is our duty , build on brown field sites, this should be the only option going forward.","",51.9074375,-2.1914375000000001,"WR45+XC Gloucester, UK",0,1,0]
["Resident","","Land surrounding Chargrove Lane","Flood mitigation, Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements","This is designated greenbelt land, any building in this area is an encroachment on the openness of the greenbelt, it is a degradation of the greenbelt and this part of the greenbelt was given in the recent joint core strategy (JCS) surveys one of the highest ratings. Under the national planning policy development and building of homes should only be permitted under very special circumstances.  There are sustainable strategic sites available in the vicinity of the wider Tewkesbury Town area, which are outside the Green Belt. These alternative sites could make a significant contribution to Tewkesbury’s requirements and, if brought forward, would enable the urban extensions around Gloucester and Cheltenham to serve primarily the needs of those areas.  This Chargrove site was considered as a possible strategic site under the JCS, however the area was subsequently removed as a submission site. Under the EIP the inspector has not recommended this area for development.  This site is clearly visible from Leckhampton Hill an area of outstanding natural beauty & will therefore be detrimental to the view. This site is also visible from the public footpath, part of the Cheltenham circular challenge.  The land in question lies within a SSSI Badgeworth impact risk zone, the SSSI is dependent on the groundwater and surface water that flows off this catchment area.  Building on this site will cut drainage ditches for foul, storm and roads all with gravel bedding, it will divert the natural site drainage that feeds the SSSI.  The SSSI is a depression on Blue Lias clay, which fills seasonally with rain water and run-off from adjoining pasture to create the wetland habitat.  There is a potential risk of a catastrophic event wiping out with the gradual encroachment of Cheltenham's boundaries, the site has survived since its first discovery in 1890 being one of only two sites within the UK. The secondary site has suffered since 2012 and this site is now regarded as the primary site.  Rare species of bats, bird and amphibians have been noted on the site, due to its rough arable pasture and woodlands these speci have been able to establish population across this site either as a habitat or for foraging.  All UK bats eat insects. The diverse species of bats found across this site would indicate that there is an abundance of insects across the site to sustain this population.  The Conservation of Habitats and Species Regulations (2010) transposes into law in England and Wales the Habitats and Species Directive (1992). Regulation 41 makes it an offence to;  ii. Disturb a bat deliberately (disturbance includes any disturbance which is likely to impair a bat’s ability to: survive, to breed or reproduce, or to rear or nurture their young), hibernate or migrate (in the case of animals of a hibernating or migratory species);  iii. Affect significantly the local distribution or abundance of the species to which they belong;  iv. Damage or destroy a breeding site or resting place of a bat;  As we know that the site contains rare species of bat Barbastelle,Lesser horseshoe bat, Nathusius’ pipistrelle, Greater horseshoe bat and even Bechstein’s bat who are dependant on the traditional pastures, woodland and ponds to provide the insect life, removal of an abundant food source will result in the decline of wildlife on this site.  Birds  The desk study returned a number of notable bird records from within 1km of the Application Site.  Those deemed to be of note with regards to the habitats present in the Application Site include kestrel (Falco tinnunculus), linnet (Carduelis cannabina), starling (Sturnus vulgaris), fieldfare (Turdud pilaris), dunnock (Prunella modularis), skylark (Alauda arvensis), song thrush (Turdud philomelos), redwing (Turdud iliacus) and yellowhammer (Emberiza citronella).  During the course of the field surveys a few incidental recordings of notable bird species were made, including barn owl (Tyto alba), tawny owl (Strix aluco), little owl (Athene noctua), yellowhammer, buzzard  (Buteo buteo) and green woodpecker (Picus viridis).  On the RSPB Red list are Song thrush, Starling, Skylark, Linnet, Fieldfare, Red wing, Yellowhammer and Little owl, these are defined as Globally threatened  It was also noted that a high variety of predatory birds, Kestrel, Barn Owl, Tawny Owl, Little Owl and Buzzard used the site suggesting that there is a high population of small rodents on this site.  The small rodent population is also evident by the number of domestic cats who await patiently by the hedgerows to pounce on any movement in the grass.  Again the site provides enough food resources for these endangered birds to forage and nest, removal of the food source will lead to a decline in wildlife on this site.  How many of the above endangered speci are spotted in a urban environment, the answer without the inclusion of the Starling zero.  Amphibians  Great crested newt, Smooth newt, Common toad and Common frogs are noted across this site, other species may exists in the unsurveyed ponds but these have not been identified.  Again there is enough food resources and nesting habitat for these to survive, by removing established hedgerows, orchards and field boundaries and ponds will force the Amphibians into decline, there is also a risk of site contamination from the proposed users of this site.  Reptiles  A number of small reptiles have been noted across the site these being Slow worms, Common lizards and grass snakes, owing to their inconspicuous nature they tend to be stumbled across giving fleeting glances.  These reptiles seek refuge in the field boundaries hedgerows and ponds where food resources are abundant.  Again these Reptiles are protected and the removal of established hedgerows and ponds will force them into decline.  In conclusion the site has proven to be home to many diverse and endangered specie of wildlife and should be preserved as a greenbelt to maintain the established wildlife on our doorstep.","",51.876491100000003,-2.1155634000000001,"Chargrove Lane, Shurdington, Cheltenham, UK",3,8,0]
["Resident","","Leckhampton","Protected for its wildlife and nature , Nature recovery , Flood mitigation","We have areas along Hatherley Brook in Leckhampton which are already untouched and full of wildlife. An old orchard which has just been lost to a housing development. The next field along which is part of our Local Green Space is now under an application for another housing development. Protected areas are not it seems protected at all. It is all very good planning new tree planting, developing new areas for wildlife, but what we really need to do is stop destroying the ones we already have especially ancient trees and scrubland. This corridor along the Hatherley Brook also floods which affects Warden Hill and even further down at Twigworth. So my point really is stop destroying what we have, it is an environmental crime.","",51.875353999999987,-2.0865269,"Leckhampton, Cheltenham, UK",0,7,0]
["Resident","","Maintain the green belt  surrounding Swindon Village agreed in the JCS","Protected for its wildlife and nature , Nature recovery , Biodiversity net gain improvements","The area around Swindon Village identified as  green belt in the JCS should be maintained as it is a thriving hub of wildlife and I really believe this could be further improved with some investment.","",51.929312499999988,-2.0806874999999998,"WWH9+PP Cheltenham, UK",0,2,0]
["Resident","","Nature reserve","Nature recovery , Protected for its wildlife and nature ","The area of land is already home to birds of prey, deer, pheasants, rabbits, foxes and many more.  the area is affected more with flooding,  land is situated off wilding close, Tewkesbury","",null,null,"",0,2,0]
["Resident","","Rare species rich meadow which is surrounded by grassland that could be improved","Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements","There are various ancient ridge and furrow fields here used for cattle grazing which could be used for net gain. One of the fields is a very species diverse ancient meadow which demonstrates that the remaining fields could be improved accordingly. There are several neglected hedgerows that would benefit from beating up with new planting. Some hedgerows are well established with excellent wildlife value. Wildlife corridors could be enhanced. An amazing opportunity.","",51.871312499999988,-2.1523124999999999,"VRCX+G3 Gloucester, UK",0,1,0]
["Resident","","Rare species rich meadow which is surrounded by grassland that could be improved","Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements","There are various ancient ridge and furrow fields here used for cattle grazing which could be used for net gain. One of the fields is a very species diverse ancient meadow which demonstrates that the remaining fields could be improved accordingly. There are several neglected hedgerows that would benefit from beating up with new planting. Some hedgerows are well established with excellent wildlife value. Wildlife corridors could be enhanced. An amazing opportunity.","",51.871312499999988,-2.1523124999999999,"VRCX+G3 Gloucester, UK",0,1,0]
["I work for a charity or volunteer in the area","Hatherley and Reddings Cricket Club","Recreation and sports ground","Other","Our cricket ground helps support 200+ juniors and senior cricketers, from all around the local area, it is a vital part of the community and a crucial asset.","",51.876491100000003,-2.1155634000000001,"Chargrove Lane, Shurdington, Cheltenham, UK",0,1,0]
["Resident","","Rudgeway Lane running N & NE of Wheatpieces estate, Walton Cardiff","Protected for its wildlife and nature , Flood mitigation, Nature recovery , Biodiversity net gain improvements","Starts at southern section (SO 90557 31776) and ends at SO 90768 32153). Very popular with walkers, cyclists etc. Including land either side which is very prone to flooding.  Along this stretch of lane as a whole (and in immediately adjacent hedgerow/field) there is a strong populations of Song Thrush (Amber Listed) with 7-8 nesting pairs; Whitethroat (Amber listed) with 4-5 nesting pairs; Linnet (Red Listed) - 1-3 nesting pairs; Skylark (Red listed) - 1-2 nesting pairs; Reed Bunting (Amber Listed) - 1-2 nesting pairs; Yellowhammer - 1-2 nesting pairs.  Including Restricted Byeway running from SO 90766 32156 to SO 91062 32066). This is a relatively undisturbed narrow stretch running East of Rudgeway Lane. Unfortunately used by vehicles entering Chapel Farm despite its restricted legal status. High and potentially ancient hedgerow. Breeding Linnet (Red listed); Mistle Thrush (Red Listed); House Sparrow (Red Listed); Starling (Red Listed); Greenfinch (Red Listed); Skylark (Red Listed); Yellowhammer (Red Listed); Reed Bunting (Amber Listed); Dunnock (Amber Listed). Home to hundreds of Redwings in the winter.  Included wooded area on the corner of the Lane at SO 90758 32255: Regular haunt of Mistle Thrush; Treecreeper & 2-3 breeding pairs of Blackcap. Favoured site for Redwing in the wiun  Including copse at SO 90553 31875 that has mature Scots Pine. Breeding Tawny Owl (Amber Listed) - 1 nesting pair and nesting site in various years for Greenfinch (Red Listed); Starling (Red Listed) Buzzard & Sparrowhawk.  The adjacent fields flood in the winter and provide a refuge for Wigeon; Teal and Snipe.  Records of all of the above have been lodged with the Gloucestershire Centre for Environmental Records (GERC) via the Living Record portal and the British Trust for Ornithology's Birdtrack facility over the period 2018-2024 inclusive. Summary of records as follows:  2018-2024: 86 bird species from 294 site visits including the following Red Listed species: -  Swift = 19 records / Cuckoo = 17 records / Herring Gull = 49 records; Curlew = 8 records; Skylark = 143 records; House Martin = 153 records; Starling = 270 records; Mistle Thrush = 24 records; Fieldfare = 62 records; Spotted Flycatcher = 1 record; Whinchat = 1 record; House Sparrow = 291 records; Yellow Wagtail = 6 records; Greenfinch = 164 records; Linnet = 211 records; Redpoll = 5 records; Yellowhammer = 71 records.  and the following Amber Listed species:-  Greylag Goose = 26 records; Wigeon = 10 records; Mallard = 90 records; Teal = 12 records; Stock Dove = 145 records; Moorhen = 24 records; Snipe = 12 records; Green Sandpiper = 3 records; Black headed Gull = 58 records; Common Gull = 11 records; Short-Eared Owl = 1 record; Tawny Owl = 15 records; Sparrowhawk = 50 records; Kestrel = 23 records; Rook = 59 records; Sedge Warbler = 3 records; Willow Warbler = 21 records; Whitethroat = 123 records; Wren = 286 records; Song Thrush = 268 records; Redwing = 105 records; Redstart = 1 record; Wheatear = 1 record; Dunnock = 288 records; Meadow Pipit = 84 records; Grey Wagtail = 6 records; Bullfinch = 107 records; Reed Bunting = 94 records.","https://strategiclocalplan.govocal.com/uploads/8e7e4b1a-e78f-40f7-9d4a-cba3475809b3/idea_file/file/e192ace9-c798-4c32-993f-ac6ea1096cdc/20200523_085925.jpg\nhttps://strategiclocalplan.govocal.com/uploads/8e7e4b1a-e78f-40f7-9d4a-cba3475809b3/idea_file/file/83893a39-9947-4573-a2f7-ab1bca00b74d/WP_20180512_09_27_15_Pro__1_.jpg\nhttps://strategiclocalplan.govocal.com/uploads/8e7e4b1a-e78f-40f7-9d4a-cba3475809b3/idea_file/file/7f114b82-4fdc-4b34-a58f-9ac4a9830d2e/WP_20180513_09_33_54_Pro__1_.jpg\nhttps://strategiclocalplan.govocal.com/uploads/8e7e4b1a-e78f-40f7-9d4a-cba3475809b3/idea_file/file/1d6910bf-95ee-43ea-8132-db47d9038b59/20190830_162108__1_.jpg\nhttps://strategiclocalplan.govocal.com/uploads/8e7e4b1a-e78f-40f7-9d4a-cba3475809b3/idea_file/file/b601ac1d-39e8-4fad-b5ae-46607000dcea/20190901_103646__1_.jpg\nhttps://strategiclocalplan.govocal.com/uploads/8e7e4b1a-e78f-40f7-9d4a-cba3475809b3/idea_file/file/b4df08ce-2253-490c-b135-1faff14f5031/20190908_074927.jpg",51.985616,-2.1364974999999999,"51.985616, -2.1364975",0,2,0]
["Resident","","Rudgeway Lane running South of Wheatpieces estate, Walton Cardiff","Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements","Land immediately south of recently approved new housing development (Grid Ref SO90393 30735 to at least SO 90379 30226).  This is the sole remaining stretch of Rudgeway Lane, south of the Wheatpieces estate and its adjacent farmland that survives following rapidly expanding housing developments. It should be protected against further development!  This site is a local stronghold for breeding Skylarks and Yellowhammers (\"Birds of Conservation Concern\" Red Listed species in rapid UK wide freefall of populations)  and they have already lost a significant proportion of their breeding habitat with the approval of the next phase of the expansion of the Wheatpieces estate in the 2-3 fields   immediately south of the new Bloor Homes HQ.  The site is also holds significant numbers of Fieldfare and Redwing flocks and Meadow Pipit in winter and is a heavily used feeding site for Rooks collecting grubs to take back to nearby rookeries. Swallows nest in the dilapidated outhouse between Rudgeway Farm and the end of the lane.  Please feel free to consult the Gloucestershire Centre for Environmental Records for data submitted via the Living Record portal (also submitted via the British Trust for Ornithology's Birdtrack facility) that details records over the 2018-2024 period for breeding records for both of the above species. I can also provide video and photographic evidence.  The site is  63 bird species have been recorded during the period 2018-2024 from 77 completed site visits. These included the following Red or Amber Listed species :-  Red Listed Species: Swift = 13 records; Cuckoo = 1 record; Curlew = 2 records; Herring Gull = 29 records; Skylark = 60 records; House Martin = 31 records; Starling = 67 records; Mistle Thrush = 3 records; Fieldfare = 20 records; House Sparrow = 71 records; Greenfinch = 28 records; Linnet = 49 records; Yellowhammer = 58 records.  Amber Listed Species: Greylag Goose = 1 record; Stock Dove = 44 records; Moorhen = 5 records; Black-headed Gull = 25 records; Common Gull = 11 records; Sparrowhawk = 8 records; Kestrel = 26 records; Rook = 55 records; Wren = 62 records; Song Thrush = 27 records; Redwing = 24 records; Dunnock = 68 records; Meadow Pipit = 43 records; Grey Wagtail = 2 records; Bullfinch = 2 records; Reed Bunting = 5 records.","",51.973981300000013,-2.1416841,"'-51.972293 , -2.1380138",0,2,0]
["Resident","","The airport and greenbelt","Solar energy ","The airport just sits there and does little that is actually productive. If it is not to be redeveloped for something that benefits local residents who in Cheltenham and Gloucester essentially subsidize it then at least it can be used to generate some low carbon energy.","",null,null,"",1,1,0]
["Resident","","The washlands of the river Severn","Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements, Flood mitigation","The River Severn is an amazing asset within the county and is still under used and ignored. It has real potential for increasing biodiversity and being on the doorstep of 10s of thousands of people for quiet recreation. it should be promoted as a strategic BNG site and for quiet recreation in a managed way.","",null,null,"",0,1,0]
["I work for a charity or volunteer in the area, Resident","Cheltenham Civic Society","Wainlode Hill","Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements","Hill beside the Severn south of the Red Lion pub. Great potential for conservation and for nature-focused walks. Great views too","",null,null,"",0,4,0]
["Local Councillor","Hucclecote Parish Council","wooded area next to Youngs Orchard","Nature recovery , Protected for its wildlife and nature , Biodiversity net gain improvements","This area is routinely cut every 3 weeks. When it was allowed to grow it was a haven for pollinators, rodents and birds and a great boost to the areas biodiversity. My idea is to remove this area from the 3 week cutting regime and cut it just once a year with the cut and collect machine which does Clock Tower Park near by. Walkways could be cut through to allow easy access for walkers and additional planting of woodland plants could be a possibility as this would further boost biodiversity. Bat and bird boxes could also be an option!","",51.850176900000001,-2.2047637999999998,"Youngs Orchard, Abbeymead, Gloucester GL4 4RR, UK",0,6,0]
["Resident","","wooded area to the East of Elmbridge Court","Protected for its wildlife and nature , Nature recovery ","This wooded strip, I am not sure what it is called is home to Tawny Owls, Woodpecker and many other bird species. Slow worms also have been seen there. I can remember exploring this back in the 1970's and it has hardly changed since. It looks to be the last existing wooded area in Gloucester and so should be protected with the utmost URGENCY.  Richard Graham please note Elmbridge belongs to Gloucester not to some medievel town 15 miles away, you really need to fight this land grab, if you won't will LABOUR or LIB dems fight for Elmbridge?","",null,null,"",0,1,0]
[]
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["Comments received on above site locations"]
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["Your role ","Organisation","Site Location ","Comment","Number of likes for this comment"]
[null,null,"Chargrove Lane","Fully support this proposal. There is a small nature reserve adjacent to Chargrove Lane already but the area worth protecting and enhancing is greater than this. Nature recovery work would have enthusiastic support from the many local residents who enjoy this area.",0]
[null,null,"Chargrove Lane","Chargrove Lane and area bordering has a wealth of wildlife. (being lesser spotted woodpeckers, Tawny Owls, frogs, newts, bats , with the addition of the regular wildlife.  The trees (some preserved) and hedgerows have been long established. The local community love the area. From small children to the elderly. It is well used for health, well being, even bird-watching and  many other activities .This area is unique.",0]
["Resident",null,"Chargrove Lane","People are passionate about this area.  I don’t live in the immediate area of Chargrove Lane, but discovered this haven during a dog walk with my friend it is simply stunning, a peaceful haven of wildlife going about its business, this land should not even be considered for any development, the eco system is far too precious.  The council needs to see sense designate this area as a SSSI and keep it’s Greenbelt status for good, not bow down to greedy developers who have no respect for nature. Prorititise  building on Brownfield Sites only.  This is a valuable area for mindfulness and good for the sole.  Councillors need to spend some quality time in these areas to fully understand. I support this objection 100%, there are other solutions.",0]
[null,null,"Chargrove lane and surrounding fields","The current areas of greenbelt should not be encroached upon.  It is needed for many many reasons most of which are obvious.",0]
[null,null,"Chargrove lane and surrounding fields","The area is full of wildlife. It has old beautiful trees and very old hedgerows which are full of insects. One field has bee hives. (which is wonderful.) The area is also Greenbelt which is vital to protect at all costs. The local community use the lanes and footpaths for health reasons/activities which is encouraged by \"The Government\". The area needs to be safeguarded for future planning.",0]
["Resident",null,"Chargrove lane and surrounding fields","We often walk the footpath between the fields and it’s a gorgeous escape from town life. The amount of deer, birds and general wildlife in this area is amazing given its close proximity and access from suburban areas. It is clearly enjoyed by so many residents stretching from across Shurdington, Leckhampton, Warden Hill and Hatherley. The area is more than just a few fields -  it resembles, promotes and enables maintenance of good mental health and wellbeing. It should be a protected local nature reserve in its own right!",0]
["Resident",null,"Chargrove lane and surrounding fields","When I tell the 30 to 40 people who have turned up for the weekly Health Walk that we are going ‘across the fields’ or ‘along Chargrove Lane’, there is a unanimous murmur of approval.  They enjoy and value the opportunity to walk in open green spaces and see the animal and plant life, and they appreciate how fortunate they are  to have this on their doorstep.  Earmarking Chargrove and the adjacent fields as a location for climate and nature recovery would be recognition of the importance and rarity of such a site.",0]
["Resident",null,"Chargrove Lane protect the land, object to any development","Chargrove is all Green Belt land on the southern side Up Hatherley Way, the very road designated to provide the limiting boundary for any urban development.  This application in no way demonstrates the required “very special circumstances” needed in order to allow building on Green Belt land. Chargrove Lane is unique around Cheltenham, unspoilt by development & traffic on the edge of the already numerous Up Hatherley housing developments. This application, if permitted, would irrevocably destroy a priceless piece of rural countryside together with numerous trees & hedgerows, all home to many species of wildlife.  A large number of these trees are currently protected by a tree preservation order & include a rare surviving traditional Perry orchard that has protected ‘Priority Habitat’ status and is also included on Gloucestershire’s Historic Environment Record.",0]
["Resident",null,"Chosen Hill","Chosen Hill and the proposed development area adjacent to the balancing ponds is a NO-GO for developing this should remain as a nature reserve and arible farmland. The hedges are constantly being cut down by the highways people and need to be left as nature wants-what the hell is wrong with this Government and local councils is all this coppicing and tree removal. Is it just to keep the inefficient CHP incinerator that was positioned in the heart of Gloucester producing its measly output?",0]
["Local Councillor",null,"Gloucester City Beautification","Greening Gloucester- in Spain some town councils have created small gardens by demolishing buildings no longer needed. Streets have been redesigned with trees and seats, with local traffic diverted elsewhere. In a warming climate, cool green spaces are vital. Regarding the possible developments north of Gloucester, the flooding is only going to get worse, and Gloucester is vulnerable to decisions made by Tewkesbury District. Lack of planning forethought- primary school in Minsterworth closed quite recently- yet look at the proposals for that village! Roads unable to support traffic volume already. No local centre yet in Minsterworth so all trips require a car journey. River crossing into Gloucester inadequate.",1]
["Resident, I work for a charity or volunteer in the area",null,"LAND AROUND CHARGROVE LANE SOUTH OF UP HATHERLEY WAY CHELTENHAM","This greenbelt land is indeed heavily used as a recreational area by residents of densely populated Up-Hatherley and beyond.  There is a variety of field paths crossing the area and these and Chargrove Lane are used by runners, walkers, dog walkers, families.  It enables access on foot to the Cheltenham Circular footpath and to footpaths in the wider Cotswolds AONB via Shurdington Hill.  It also forms part of a corridor used by Cotswolds wildlife, including deer and many birds",2]
["Resident",null,"LAND AROUND CHARGROVE LANE SOUTH OF UP HATHERLEY WAY CHELTENHAM","Would be devestated to see houses built on this wonderful area - so rich in nature - we should be preserving this not destroying it. Much used areas by families and walkers. Please reconsider!",2]
["Resident",null,"LAND AROUND CHARGROVE LANE SOUTH OF UP HATHERLEY WAY CHELTENHAM","Completely devastated if this wildlife haven is destroyed. For health reasons walking in a semi rural area is much needed. Without access to this beautiful area so many walkers, runners, dog walkers and nature lovers would be deprived of a daily dose of fume free exercise. It is green belt and one that would be missed by most local residents. In addition there is so much wildlife that is reliant upon this area, deer, birds & horses would be lost. So much wildlife is red listed and destroying this would be adding to their decline.  Please reconsider this decision for the sake of all residents, people & wildlife!  Please allow us a respite and place to walk",2]
["Resident",null,"LAND AROUND CHARGROVE LANE SOUTH OF UP HATHERLEY WAY CHELTENHAM","I have lived in this area for 30 years & I would be mortified & devestated if Cold Pool Lane is destroyed for housing. It is a beautiful, outstanding, nature rich area that myself & many other local residents use daily. I can walk my dogs just a couple of minutes from my house & be compketely immersed in nature, seeing deer, birds, sheep, horses & many other creatures on a daily basis. It is used regularly by many walkers, dog owners, runners & cyclists & is a great benefit for people's health & wellbeing. Practitioners are always telling us to get out into nature as it's great for our health,  but how can we do this if they are taken away from us by the house builders? Where will all of the beautiful flaura & fauna go that is displaced by this. I regularly have hedgehogs, foxes, deer & copious amounts of birds visiting the field at the end of my road....where will they all go? We must protect this vital area that is their home, & has been for thousands of years. The area is prone to flooding, as we have seen this winter.....where will all of this water go? This green area removes carbon from the air, & in particular the exhaust fumes from the busy Up Hatherley way.....what will replace this vital activity. Certainly not more cars, tarmac & brick houses, that's for sure! There are plenty of other brownfield sights that must be developed before we even consider looking at precious greenbelt areas like this.",0]
[null,null,"LAND AROUND CHARGROVE LANE SOUTH OF UP HATHERLEY WAY CHELTENHAM","LAND AT CHARGROVE LANE  At the last Tewkesbury structure plan the Planning Inspector Elizabeth C.Ord stated that “Cheltenham has a limited land supply and Tewkesbury should NOT place its housing around Cheltenham when it has unallocated village supply”. Cheltenham has NOT increased its land supply and Tewkesbury again seek to place its housing around Cheltenham.  The issue of adding to Tewkesbury housing in Cheltenham is down to infrastructure, schools being senior or junior are already operating using temporary classrooms, children are being bused to Gloucester schools. I spent my secondary education in portacabins which were freezing in the winter and boiling hot in the summer, yet in 2024 we still accept that children can be educated under this standard. Cheltenham has just completed a new secondary school with a capacity of 900 and Tewkesbury wish to allocate more housing on Cheltenham. The proposal for 1763 houses which could equate to an additional 3,000 children to be educated and this is on top of the estates already being constructed or already being given permission. An appointment to see a doctor in Cheltenham is running at one month all signs of overcapacity and undersupply of the infrastructure to match.  Tewkesbury has many unallocated villages where there is NO assignment of housing in this plan, for example Tirley, for village schools, bus services, broadband etc the basic lifelines of these villages is being ignored. The introduction of new housing breaths demand and drives change to upgrade infrastructure, no one is going to invest in new or upgrading infrastructure without demand. Covid has led to a decline in bus passenger chiefly because people are now working from home, this adds to the decline in rural bus services. The planners are losing the opportunity to build communities around new housing, community centre, Doctors and convenience store, bringing these outlying villages into the modern age. The Green Belt provides a separation of Cheltenham from outlying conurbations and should be respected for the reason it was created and Tewkesbury’s outlying villages need to take some of the strain prior to any Green Belt being released.  CHARGROVE LANE land should not even be considered for development as the run off supplies the water and nutrients that feed the Adder’s-tongue Spearwort at Badgeworth nature reserve which now is the only stronghold of this specie as the only other site being Inglestone Common, south Gloucestershire was down to its last plant. The Adder's-tongue Spearwort is a specialist of open wetland habitats, where it is dependent on poaching and seasonal inundation to supress competing plant growth and to create bare unshaded pond margins. It favours temporary ponds on grazed commons and roadside greens. It is a poor competitor and therefore requires extremely intensive grazing, or similar disturbance, to control emergent vegetation growth. Adder’s Tongue Spearwort is listed as Vulnerable in the Red Data List of Great Britain and is protected by law as a section 41/42 Priority Species. The principle causes of decline have been intensification of farming practices, infilling of ponds, artificial regulation of water levels, loss of grazing and nutrient enrichment. Adder’s Tongue Spearwort is intolerant of competition, without clean unpolluted water, intensive disturbance and control of competitors it is quickly lost from a site. The land around Chargrove lane has not been intensively farmed and 80-90% has been left to pasture of sheep or cattle with the remainder being used for seasonal crops. It can be seen that the land drains slowly as extensive ponding of surface water occurs that help to maintain a wetland environment.  The escarpment being limestone is porous and acts as an aquifer absorbing rainwater and this is evident by the number of brooks and streams that run off this escarpment and Severn Trent’s reservoir on Leckhampton hill. The landscape is derived from the retreating glaciers that laid down a Charmouth mudstone formation consisting of grey mottled brown clay with laminations of grey fine-grained sand. The landscapes act to attenuate and percolate run off from the surrounding escarpment and land, this effectively acts like a sponge in retaining water, similar to pouring water onto an incline this gathers at the bottom of the hill in seasonal ponds. A large number of these seasonal ponds can be viewed on 1800, OSI maps numbering over 40 and which are not fed by any brooks or streams. This area should be classified as an Areas of Special Scientific Interest (ASSIs) that feeds the only thriving site of this specie and by considering to build on the land adjoining this site will drive this specie into extinction.  The land forms part of the greenbelt and that has provided security for this site, one cannot artificially create a landscape that has evolved over thousands of years.",2]
[null,null,"LAND AROUND CHARGROVE LANE SOUTH OF UP HATHERLEY WAY CHELTENHAM","Chargrove Lane is like an oasis amongst the relentless creep of residential development and must be protected.  A significant number of people use it for walking and cycling as an escape from the nearby traffic and urbanisation. It provides a priceless resource for their health and mental wellbeing. This value must not be underestimated.  There are so few places around Cheltenham as tranquil and capable of providing an instant mood boosting effect to so many people, as Chargrove Lane.",1]
[null,null,"LAND AROUND CHARGROVE LANE SOUTH OF UP HATHERLEY WAY CHELTENHAM","I am amazed that with so much evidence to support the preservation of Chargrove and it’s surrounding area that it’s even being considered for housing.  We are constantly having to fight for the survival of this beautiful, tiny piece pf green land which in turn is so vital to the survival of it’s many rare species, has SSSi status and great historical interest.  The area surrounding Chargrove has been extensively built on over the last 30 years and this tiny piece of land that is so well loved locally is all that we have left and most importantly all that the wild life that it supports have left for their survival.  It should be preserved for ever more so that it’s wildlife can continue to flourish, and for the good of local community and beyond.  Not turned into yet more  housing which in time will be uninsurable and unwanted due to inevitable flooding as our climate continues to  change due in part to never ending building for short term gain.  It's such a shame that builders are queuing up to desecrate our green land in a bid to maximise their profits but so reluctant to convert brown sites and existing and unused buildings for housing instead.",0]
["Resident",null,"LAND AROUND CHARGROVE LANE SOUTH OF UP HATHERLEY WAY CHELTENHAM","As a regular recreational user of Chargrove Lane and the signposted walks in the area for 40 years it would be a travesty for any building or development to be allowed there. The lane is extensively used by local residents for walking, cycling, dog walking, jogging etc. I have seen residents from a nearby care home being pushed in their wheelchairs by their carers for them to enjoy the fresh air and sights and soundsof nature.",0]
["Resident",null,"Land surrounding Chargrove Lane","Terrible that planning on this site would even be considered. The surrounding area has been hugely built on, many people travel to this area as one of the last remaining nature areas.  Nature should be incorporated into every new housing development which sadly is not the case, we need to fight for our rural spaces.  This area is part of an SSSI, Chargrove nature reserve is will have bio diversity connection to Badgeworth nature reserve- animals need save spaces to move between to thrive. There was recently a campaign to save the last remaining ancient orchard of Hatherley Pear, such a shame to then demolish local history and tradition for yet more bland houses.",0]
["Resident",null,"Land surrounding Chargrove Lane","A development of over 1700 houses on this site would be terrible for the local area. Within the area is a nature reserve and SSSI which clearly would be damaged as a result of being island's surrounded by development. The area has seen much development and creeping urbanisation, however the area of Chargrove Lane is a wonderful rural zone rich in biodiversity and a great place for local residents to walk in and enjoy. Development here would cause considerable unavoidable damage and the area must be protected.",0]
["Resident",null,"Land surrounding Chargrove Lane","The building of more houses in the area would be a big problem, both environmentally and socially. I walk down Chargrove lane most days and over bordering fields using public footpaths. It is a haven for wildlife and regularly see all sorts of animals that would simply disappear if building was allowed. Development here would cause considerable unavoidable damage and the area must be protected. To be able to walk from my house and be in a semi rural area within 5 minutes is one of the main reasons we moved to the Up Hatherley area 25 years ago.",0]
["Resident",null,"The airport and greenbelt","The Airport site supports a lot of Aerospace related business and is a fundamental package of land that keeps Cheltenham and Gloucester separate. The lands are probably owned by Tewkesbury which is bizarre, how can a situation exist where Tewkesbury call all the shots? The airport used to host motor cycle events and car shows in the distant past why not make the airfield multi purposed again? It should not be built on. Previous generations have always protected the value of a local airport nad now with its fourth green runway located along Cheltenham Road East we could see Long haul flights taking off soon.",0]
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["For complete comments on 'Locations for Climate & Nature' please also refer to 'Questionnaire Responses' sheet 'Q.9 Are you aware of any land that could be identified for environmental purposes, such as wildlife / biodiversity net gain, recreation, flood risk mitigation, cooling and shading, carbon storage and food production?'"]

{"sheet":"Jobs & Retail","index":9,"n_rows":19,"n_cols":8,"rows_kept":19,"cut":false,"hidden":false,"merged":[[18,0,20,4]]}
["Jobs and the Economy "]
["Your role ","Organisation","Title","Description","Comments","Likes","Dislikes","Additional comments"]
["Statutory/Specific Consultee","Woodmancote Parish Council","Innovative Rural Economy","The planning system needs to attract more innovative approaches to agriculture. In particular the use of hydroponics, solar powered systems, biofuel, and different greenhouse based businesses need to be encouraged to take up underused agricultural land near settlements rather than allow this land to be used for millionaire mansions and second/holiday homes.  We need to focus on a local agricultural based ecosystem where produce is grown, turned into food that we eat and delivered to our tables as locally as possible whether through grocery stores, local produce baskets, farm shops, pop up restaurants and \"local produce restaurants\".  NB Sixth Carbon Budget suggests that we need to reduce our meat/dairy consumption by 30%. therefore more innovative plant based food solutions are required to \"pull\" residents to achieve this. We need our rural economy to do this.  In fact millionaire/second/holiday homes need to be downgraded to the lowest priority of accommodation in the planning priority hierarchy.",1,4,0,"Fully support all of that..."]
["Resident","N/A","Draft Vision Extract","The Draft Vision says -  \"Investment in training, skills and development will have attracted and retained a younger workforce and provided new premises and flexible workspaces to support a flourishing circular economy in both urban and rural areas. Inward investment, innovation and growth in key sectors including, amongst others, cyber and digital-tech, food/agri-tech, advanced engineering and tourism will have been fostered.\"  I commented that we need a younger workforce while retaining and reskilling those already here.  So - what needs to happen.  We need a strategy - what do we want. Do we specialise?? Do we diversify??  How do we move towards that. Does the Cyber Park in Cheltenham play a role?? Is it recognised?? Do we know the plans of big employers in our area?? Are we attractive to them??",0,1,0]
["Resident","","Planning town centres for 2040 living","Unfortunately the whole planning process is too focused on building lots of homes when the whole forecast need is almost certainly heavily overstated. Planning Policy needs to address a much bigger question over the next 20 years - what will our town centres need to be like to meet the needs of 2040 living. This needs to take account of increased automation and therefore much higher levels of productivity meaning more leisure time. However working less of the week will almost certainly mean lower earnings. Therefore more working people unable to afford to buy or rent in Cheltenham.  Bricks and mortar retail is on its knees saddled with wrong space that is too exensive (rent and business rates). Losing Cavendish House is a real shame and just turning it into housing - will not be the answer.  Hospitality might be the answer but not if that is unaffordable for the next generation.  Entertainment might also be the answer but that will have to be a circular economy if its going to be sustainable ie locally employed people entertaining those with leaisure time to fill.  What residents want is a proper vision on this major question and then policies that will deliver that vision. The developers will definitely NOT have a long term vision and banks will only fund dead certain plans.",1,2,0,"Defenatly agree that this part is missing."]
["Local Councillor","","Planning should be looked at by area not plot at a time","More houses should only be considered after looking at the road infrastructure as churchdown is gridlocked as more houses being build on the exit roads and only being looked at for the site and not the inpact it has on the village as a whole.  6 schools with students being bussed in and parents dropping off the students brings some many more cars to the area, we only have 1 Dr surgery and 1 Dentist we need to consider transportation before more housing for 1000 homes that will bring a further 2000 cars or more.  We sadly lost our train station years back but would now be useful again to get to Cheltenham and Gloucester Town centres, and just adding a cycle path is just no enough for the people of churchdown, they need exit routes  as there aren't many jobs with in churchdown to sustain a workforce, so therefore they must travel out for work, the enviroment of cars sitting in gridlock serves no one....highways must consider more roads before more house to be allowed 😢  our community our village and our resident deserve a better solution to this issue.",0,1,0]
["Resident","","Housing density as opposed to Employment business","Gloucester & Cheltenham should look at their own plans and divorce themselves from this SLP planning review. Tewkesbury has no rights to swallow up outlying land so that it can use it as a development buffer to protect itself.  Gloucester has no real jobs so many people here commute long distances. Why build more houses for rich people from London to make matters worse? The infrastructure is creaking now. The key is to build small houses around major employers this reduces commute times and allows for shared public transport. Where has new industry set up in Gloucester for example? Very few large companies have, what is here already existed.  It is perhaps under a new name, maybe a few smaller businesses have appeared but its not significant.  I think we need an SLP review of the Local Government, Councillors and Boundary Commission wallers, looks to me ripe for weeding out the dead wood and saving some money.  Not one person owns up to producing this SLP and its associated documents, no one has approved it from Tewks Borough Council (TBC) or the City or County Councils.  Its just like dealing with a lot of Dino's set in their arcane ways, never to change, never to think about saving money, just spend the budget as quick as you can, or you wont get the same next year.  the most annoying part is that this has been produced by TBC probably at great expense and its a bunch of C**p to be honest.  TBC if you want to build houses do it in your neck of the woods, Ashchurch MOD looks a good bet now get out of Elmbridge and Barnwood and Longlevens",0,1,0]
[]
[]
["Retail "]
["Your role ","Organisation","Title","Description","Comments","Likes","Dislikes","Additional comments"]
["Resident","","Town centre utilisation","Review local planning regulations to encourage, promote and permit the conversion of the numerous unused upper storeys of town centre buildings (often above shops) to flats affordable and suitable for key workers and young people.  Prevent purchase of the above by non-residents for profit.  Encourage the number of small businesses, rather than chains, for either redundant large retail spaces (that could be divided up into specialist 'markets') or small shops. Give reductions in business rates to 'destination' location shops that are not suitable for internet shopping (eg. fishmongers, bakers, artisan producers).",0,6,0]
["Statutory/Specific Consultee","Woodmancote Parish Council","Densification","One of the scenarios is for greater densification and this will clearly deliver the most sustainable solution. This does not mean tearing down the listed buildings. It should look at encouraging more apartments to replace larger suburban sites (3-4 sites) and there is no real reason why these cannot be both affordable and environmentally friendly.  Its only developer greed that prevents this from happening.  Planning policy should be setting design standards that include roof/balcony terraces, green rooves, grey water harvesting, centralised heating systems.  The planning department needs to be more ambitious in terms of setting higher standards and enforcing them.",1,3,0,"Affordable and social housing seem similar but deceptive,we need more of both instead of new large shopping developments"]
["Resident","","Getting there","Town centres need to be easy to get to if people are going to use them. Better public transport, more cycle ways and less expensive car parking will bring them in.  There are empty shops and buildings which should be priority for redevelopment. Rate reduction might incentivise this. Acting to encourage absent owners to do something with these properties eg Healings Mill in Tewkesbury seems vital to regeneration.",0,1,0]
["Resident","N/A","Clarity Is What's Needed","How could the Strategic and Local Plan best enable change and encourage investment to support our city and town centres to adapt, evolve and thrive?  The answer here is clarity, isn't it?? Being able to say, clearly, to existing and prospective businesses / employers / investors \"Our strategy for our city and town centres, until 2040 (or further) is <x>. To enable this, we are committed to improvement of transport links into these places, population growth of <y>, £Z funding is committed to this, we will ensure planning approvals are focussed on supporting these aims wherever possible' is key, is it not??  How can the Strategic and Local Plan protect and encourage essential shops, services and facilities in villages and rural areas?  Again - clarity - make a statement on what must be sustained within villages and rural areas, and be clear on what will be done to support that - grants, business rate reviews, funding, etc.",0,1,0]
["Resident, Other","","Cavendish House","There should be a serious look at what happens to Cavendish House in the long term. For such a huge and beloved space it would be a waste to see it either go to a generic high street commercial chain or just made into flats.  Perhaps a space for monthly pop up businesses to sell their products? Looking at local produce specifically. The weekly market has always been a bit mediocre and giving it a dedicated space inside that rotates will keep people coming back.",0,1,0]
["Resident","","Convert empty commercial properties into residential properties","There are many empty commercial properties in Gloucester City Centre, partially due to the convenience and popularity of online shopping. I believe we should convert empty commercial properties into residential properties, and perhaps extend some the buildings upwards to increase their capacity. By doing so, we will increase footfall within the City Centre, which will have a positive effect on the remaining local businesses and increase the demand of new local businesses. Urban green infrastructure could also be incorporated to improve the quality of life for the residents, beautify the City Centre, and increase the potential of carbon capture.",0,2,0]
[]
["For complete comments please also refer to 'Questionnaire Responses' sheet 'Q.18' to 'Q.22'"]

{"sheet":"Infrastructure","index":10,"n_rows":25,"n_cols":8,"rows_kept":25,"cut":false,"hidden":false,"merged":[[24,0,26,4]]}
["Your role ","Organisation","Q.23 What types of infrastructure do you consider are most critical to be delivered alongside new development?","Q.24 Given their size, if strategic scale new settlements were to form part of the SLP, what accompanying infrastructure would be necessary? ","Q.25 What key services and facilities do you consider most important in deciding if a rural settlement is a suitable location for new homes and other forms of development?","Q.26 Should the SLP safeguard sites or routes for longer term infrastructure projects?","If answered Yes, please can you explain why? ","If answered No, please can you explain why? "]
["Local Councillor","Down Hatherley Parish Council","Education Health and green spaces","Schools and doctors and reducing speed limits","Keeping green spaces","Yes ","Future proofing ",""]
["Resident","","Roads and amities","well maintained Roads, brooks, and rivers to reduce flooding","a mixture of types of housing especially social housing as many young people cannot afford the high rends/mortgages today","Yes ","So the the infrastructure does nt take away some of the history of our land",""]
["Business owner","","ROAD CAPACITY RURAL ROADS A46 M5 JNCT 9","ROAD UPGRADES A46 DEFINATE AND NEW M5 JNCT 9 - RURAL ROADS INCAPABLE TO HANDLE TRAFFIC GROWTH","ROAD ACCESS AND CAPACITY ","Yes ","TRAFFIC GROTH THROUGH EMPLLOYENT WILL ALWAYS  BE A FACTOR",""]
["Local Councillor","Up Hatherley Parish Council","Raid network, cycle ways, health surgeries schooling","Schools, health facilities, parks, adequate roads  to cope, rail network","Flood surveys, public transport and road networks","Yes ","when new residents move into the now areas transport MOST be adequate. people will always want their own methods of getting anywhere so cars, rail and public transport is essential. Its no real use having public transport to large shopping malls and parks as any large purchases require personal transport to get things home",""]
["Resident","","Sustainable public transport and walking and cycling options. \nAccess to GPs and dentists. \nFlood management","","","Yes ","",""]
["","","Education, health, community shared space (pre-school groups, arts and craft etc, U3a, council/police/welfare), green space (sports facilities / dual use flood plain). Centralised waste handling, grey water collection and reuse.","Education, health, community shared space (pre-school groups, arts and craft etc, U3a, council/police/welfare), green space (sports facilities / dual use flood plain). Centralised waste handling, grey water collection and reuse. Roads to provide access to strategic centres and motorway/transport hubs.","Healthcare and education facilities need to be easily accessible. Rural settings traditionally have poor public transport. Assuming that continues to be the case, access to retail centres within 20 min car journey. Tewkesbury in its current state is unlikely to provide an attractive retail centre for routine food shopping. Issues include: traffic congestion, parking, lack of major brands (Sainsburys, Asda, Lidl, Full-size Tesco).","Yes ","Highways need to be planned rather than an afterthought. Eg permitting Dobbies has constrained options for an A46 bypass. 10,000 homes are contemplated for the Ashchurch area yet no provision has been made for how the residents will access work/schools/shops - The A46 will not cope. JCS recognised this, but the problem is not addressed in the draft Garden Communities charter.",""]
["Resident","","Transport, education, medical","Roads, schools, health","Highways, schools, health","Yes ","Don’t understand the implications",""]
["Resident","","Transport","New roads","Highways","Yes ","New junction fm m5 needed to Teddington hands roundabout",""]
["","","Correct road infrastructure with wider estate roadways with adequate parking for as a minimum three parking spaces per household. Early building of Doctor's surgeries, Schools where required rather than build these towards the end","Better access would be required from the M5 currently J9 is becoming a pinch point especially when the motorway is closed as this is the only current option for traffic. Building more homes etc will increase the impact of this pinch point","All areas will need to be considered with all key services being developed and improved","Yes ","Too often developments are allowed hich will impact and prevent future planned developments. If road widening is required set aside that land now and prevent any development on it until a final decision is made whether to progress or cancel the development. ",""]
["","","","","","Yes ","",""]
["Resident","","transport, health","Schools, roads, health services, recreational facilities,","Highways, health. Also the fact that the town and surrounding villages are impacted by flooding more and more each year.","Yes ","",""]
["I work for a charity or volunteer in the area","","","All of the above plus cycleways and footpaths. Country roads are often too dangerous for cyclists and pedestrians. ","Good public transport links, cycleways and footpaths. Local health services, shops and community spaces. ","Yes ","Better planning, makes sense to plan logically",""]
["Resident",null,"We need to provide what the people in the development need, locally, don't we?? school(s), shop(s), health resources, open space, appropriate public / green transport capacity, digital connectivity, etc.","At strategic scale, they would need 'what a city or town needs' wouldn't they?? All the relevant services - schools, police, health, waste management, etc.","Appropriate local health, education, retail capacity. Connectivity to other centres. Online capacity.","Yes ","Because that feels to me the route to strategic direction & growth, as opposed to chaos. ",""]
["Resident","","education, green spaces, digital","schools especially secondary, road junctions designed to cope with the extra load, nearby doctors surgery, play spaces for young children","education - depending on the location and what is nearby, transport links, shops that provide the essentials for food. There needs to be outdoor facilities for children and young adults as living in rural area can have less options and access to doing fun things ","Yes ","There will always be a demand for housing but decent infrastructure is also a big requirement, so if all available land space is allocated to housing, where does the infra go? ",""]
["Resident","","Adequate roads, education, health","All of the above","Health, roads and public transport","Yes ","Building cannot simply take place just because a farmer chooses to sell land.  Developments we have already seen and those already approved simply do not have the infrastructure in place.",""]
["Resident","","Bridleways and equestrian crossings of our roads.  as rural areas are built on.  I used to live in a rural area now if I ride I get stones thrown at me, verbal abuse and dog attacks.","community centres for teenagers,  health centres and dentists","highways","Yes ","highway networks are unable to cope",""]
["Resident, I work for a charity or volunteer in the area","","Education, health, transport, digital, off road cycle access","education, health,public  transport, off road cycle access, recreation","public transport and off road cycle access, schools, doctor","Yes ","infrastructure projects are expensive and it is a waste of money if they are impacted by other developments. Long term vision is required.",""]
["Resident","CPRE Gloucestershire","Transport","More roads","Transport","Yes ","",""]
["Resident, Other","","Green and Digital. However they are all very important","Health and schools followed by recreational ","Key service: education and repair\nFacilities: community and recreational ","Yes ","",""]
["Resident","","Schools, health, transport ","New schools, doctors surgery, hospitals","Education,  health and recreation ","Yes ","",""]
["","","Depending on the size of the development (with consideration for the size of existing developments and of potential future developments particularly near boundaries with other local authorities), then all of the obve infrastructure is critical! ","Health services, community services e.g. a meeting place, shop, recreation place. Sufficient education provision that families can walk to (primary level) and sufficient public transport services for older schoolchildren and those wanting to get into the towns and cities","Digital infrastructure for home workers, local access to food shops, clean transport provision (electric car charging, public transport)","No ","","I don’t understand the implications to answer the question but it won’t allow a don’t know response"]
["Resident","","Active forms of travel (walking cycling) plus Green and Blue infrastructure","schools, public transport, active travel provision, health services and minimal       private vehicle/road provision","health, education. retail and public transport","Yes ","You do not want to build on and potentially sterilize strategic infrastructure assets",""]
[]
["For complete comments please also refer to 'Questionnaire Responses' sheet 'Q.23' to 'Q.26'"]

{"sheet":"Type & Tenure","index":11,"n_rows":20,"n_cols":9,"rows_kept":20,"cut":false,"hidden":false,"merged":[[0,7,0,8],[19,0,21,4]]}
["Your role ","Organisation","Title","Description","Comments","Likes","Dislikes","Additional Comments"]
["SLP Team","SLP Team","Affordable homes","Today’s young people will soon be looking for jobs and starting families of their own, without necessarily wanting to move away from their roots. They will need somewhere to live, work and send their own children to school in a way that if affordable. In June 2023 the Office for National Statistics reported that the average UK house price was £288,000, well beyond the reach of many.  The affordability of rural housing is a particular challenge with recent analysis by the National Housing Foundation reporting that social housing waiting lists grew by 31% in the three-year period up to 2022, compared with a 3% increase in urban areas.  How can the SLP ensure that there are enough affordable homes for people?",2,0,0,"One of the problems is that a lot of older people are living in family sized houses when the family have left. In a democratic state you cannot force people to move but by providing more suitable accommodation folk might be persuaded to down size. This links in to provisions for the elderly and handicapped.","The affordability ration for the area is 8 when the target is 4. I believe this value of an average dwelling compared to average earnings. The suggestion that simply building more houses will reduce prices and therefore the affordability ratio is nonsense. The definition of an \"affordable home\" includes one that is 20% below the market price. I dont know how local that comparison is but suspect its not policed either. I suspect if there are 10 houses on the developmnet, they are priced above the local average anyway because they are new and 2 of the houses are smaller and 20% below the other 8 to tick the box that they are affordable. If anyone disagrees - ask yourself this question - are the banks are going to lend money to people to buy homes that will go down in value? The more workable strategy is for planning policy to give preference to projects - especially city centre brownfield regeneration to housing association funded developments where there will be wide ranging property types that are affordable ie 4 x average earnings or the rental equivalent. These need to serve the workforce that we need in the area that the government is not willing to pay decent salaries to."]
["SLP Team","SLP Team","Housing for older and disabled people","The SLP will need to ensure that the needs for housing for older and disabled people are addressed. National planning guidance sets out advice on the different types of specialist housing designed to meet the diverse needs of older people, which can include:  · Age-restricted market housing.  · Retirement living or sheltered housing.  · Extra care housing or housing-with-care.  · Residential care homes and nursing homes.  Other models of housing include co-housing, which are created and run by residents, allowing people to live with others with similar needs and desires.  The SLP will similarly need to consider the need for accessible and adaptable housing to enable disabled people to live more independently and safely, with greater choice and control over their lives.  How can we ensure the SLP plans for the needs of older and disabled people?",1,0,0,"I'm glad to see this need has been identified. There should be varied options for retired people and those who are wishing to downsize, to move forward into the next phase of their lives. Choice is often limited to bungalows and communal living, it would be good to see more imaginative accessible single-storey buildings with gardens."]
["SLP Team","SLP Team","Student accommodation","Within our area there are three further education establishments: the University of Gloucestershire, the University of the West of England and Gloucestershire Royal Hospital. Outside of the area, but in close proximity, is Hartpury University and College. There have been recent investments, for example the conversion of the former Debenhams building in Gloucester City Centre as a new campus for the University of Gloucestershire. This is due to open in September 2024 and once fully open, will provide brand new teaching facilities for 4,500 students. To support the growing student population there have also been significant new student accommodation developments, including Pitville student village in Cheltenham and Blackfriars in Gloucester.  Through the SLP, it’s important to support the delivery of new student accommodation to meet the needs of the growing universities and further education establishments. However, this form of accommodation tends to be used by students in their first year, with private sector housing used for later years. This can cause problems with the loss of family housing to student lets and issues arising from the loss of character of an area.  How can we make sure the SLP welcomes students but gets the balance right?",1,0,0,"The accommodation is mainly used by first year students because it is not available for the majority of the student population. Maybe if there was more student accommodation available there would be less pressure on private rented housing"]
["Resident","","More Social housing and low cost housing","We need a verity of housing suitable for both the young Adults and for the elderly to be able to mix. A good mix community helps and supports each other.  As Tewkesbury in in a high risk of flooding, consideration should be taken in to ensure that horses are built to with stand flooding ie they could be built on stilts so they main house is above the flood levels.  All houses should be able to have sola panels installed on the houses to reduced carbon in the atmosphere.",0,2,0]
["Resident",null,"Broad Spectrum Requirement","I suppose it's obvious - but we need the right amounts, of all of the right types of housing, available at the right time, at the right price.  Easy, eh??  I'm interested - if national planning policy makes this clear, does our local plan provide for this, and are we delivering against that?? If not, what do we need to do differently in the future??  Student accommodation - for example - there's a lot which has been built in Gloucester - is that within the plan. Is is provided publically or privately?? Is it affordable for students, does the cost of it stop some people being students??  For me -  We need more housing which is affordable for people who are struggling.  We need to ensure that all housing is of decent quality.  We need to ensure landlords are behaving appropriately.  We need housing for all demographics.  We need housing which helps us look after each other and fosters communities.  We need to ensure our housing supports the move to Net Zero.  We need housing which promotes the ability to work and live locally - remove the commute.",0,1,0]
["I work for a charity or volunteer in the area","","Housing for everyone","The housing crisis we have been experiencing over recent years is a disgrace and governments (central and local) should be ashamed that they have allowed this to happen. In Cheltenham there has been a lot of house building over recent years, However, the majority of these developments have been high end. What we need is housing for everyone, whether that be for purchase or rent. Cheltenham will not be a decent place to live if only rich people can afford to live here. We need more social/affordable housing - we certainly need to stop developers getting around the rules on % of affordable homes they should be building in larger developments. I'm sure that this is not within the remit of the Plan but people living in extremely poor quality private rented homes have no hope of getting a council or housing association home and are therefore forced to continue to live in awful conditions. Councils everywhere have failed miserably in meeting targets on social housing. We also need new build affordable housing for purchase and/or private renting. Particularly affordable for young people wanting to get onto the buying ladder or just wanting to stay in Cheltenham where rents are ridiculously high and buying a property is impossible for young people starting out in life. As for where housing developments should be - they need to be near existing housing and infrastructure and plans should ensure that the support services such as schools and health facilities are also put in place.",0,1,0]
["Resident","CPRE Gloucestershire","Affordable homes","More affordable accommodation vital in rural areas to keep them alive",0,1,0]
["Resident","","Mrs G E Smith, Churchdown","When the green belt was implemented in 1948 it was to protect the needs of that time. Those needs have changed dramatically, but the green belt has not, Of recent times large amounts of housing have been built,or are planned to be built, on valuable farmland, whilst very little housing has been allowed within the community, where it is needed  Within the community there is an excellent infrastructure of schools ,modern GP Surgery, Dentist, good shops, a bus service, cycle lanes, footpaths and good road links.  Every age group is represented, but many Seniors who wish and need to stay within the community, have limited options for downsizing, which would be beneficial for them , BUT also for those families who wish to upsize.  With intelligent tweeking of the Green Belt housing for these Seniors could be provided, for the benefit of the whole Community, without any extra provision of infrastructure, other than an improved bus service on Parton Road.",0,1,0]
["Resident","","Housing, the Government and the builders.","We need more accommodation that suits peoples needs and finances, be it rental or purchase. Also differing types and sizes of accommodation. Builders will not offer this as it does not fit their planned builds to achieve on-site profits utilising any site to maximum development. So it requires government intervention and dictate, like social housing. Councils are limited in how they can force builders to built housing for local needs as opposed to developers schemes.",0,1,0]
["Resident","","Provide a wide range of housing types and tenure","House builders tend to build for a very limited market. Young people especially need a secure, efficient housing where they want it currently now one is delivering for them. Tenure has always been difficult to address through the planning process but more houses need to be to rent and through other tenures. Self build while a niche needs to be accommodated.",0,1,0]
["Resident","","Brownfield regeneration","Houses must be build on brownfield sites before any other considerations. Gloucester city centre, needs regeneration, more money spent, lower rents. High rents is why it has died the council know this, they helped it happen by building out of town shopping centres. What are your plans for the regeneration of the city centre? if houses are to be built it must be apartments and starter homes. Building homes to cater for the needs of rich outsiders is not what we want, we dont want to be building big houses to cater for the overspill from the Cotswolds as there is limited availability in housing out there in the wilderness.",0,1,0]
["Youth Engagement ","Youth Engagement ","housing for people","We need more houses for homeless people of people in school college and university."]
["Youth Engagement ","Youth Engagement ","Higher density housing.","Having single family homes on the outskirts is all well and good but it does not serve people who cannot afford a car to get into the centre. They  are also no good for people who do not need the space. Cheltenham needs more terraces with tightly packed houses but with lots of green space and good connections to the town centre. New areas should also have mixed use areas and local shops so you do not have to travel far to get to cafes and basic shops."]
["Youth Engagement ","Youth Engagement ","Affordable housing","More affordable housing for tho who don’t earn much, or a studying etc."]
["Youth Engagement ","Youth Engagement ","Affordable houses","I think houses today are getting very expensive and less eco friendly, the house prices should be decreased a bit so there will be less people on the road and to make them more eco friendly we should add more solar panels with more eco friendly benefits."]
[]
[]
[]
["For complete comments on this topic please also refer to 'Questionnaire Responses' sheet 'Q.14' "]

{"sheet":"G&T","index":12,"n_rows":8,"n_cols":6,"rows_kept":8,"cut":false,"hidden":false,"merged":[[7,0,9,4]]}
["Your role ","Organisation","Should sites for traveller communities be provided as part of large developments for housing and/or employment?","Please tell us why you choose that answer","Are there any other ways that sites for traveller communities could be met in our area?","What site characteristics and locations would be most suitable for different traveller communities?"]
["Local Councillor","Staverton PC.","Yes","By including traveller accommodation in large developements, it would reduce planning applications on greenfield sites and protect the green belt.","Not sure","Not sure"]
["Resident","N/A","Not sure","I would think these sites should be placed where they best meet the needs of those communities - I am unsure on whether this is as part of a large development or not. The communities should be engaged.","They could be placed away from large development, if that was the right answer - provided the appropriate facilities were available.","I don't know - I'm not part of one of those communities. They should be asked.  They have specific, possibly complex needs. \n\nI would like to think that, where possible, they can feel appropriately integrated with the broader community.  "]
["I work for a charity or volunteer in the area","","Not sure","I'm not sure that traveller communities would want to be part of a large development. If they were they would need to be on the periphery. On the other hand the closer they are to facilities such as health and education the better.","cheltenham doesn't have a traveller site nearby. Where land becomes available for development on the edge of towns (e.g the CBC ex nursery site on Old Gloucester Road). Obviously there would need to be good links to other services.","Sites for any travelling community can look untidy. So green the sites with trees. etc to make them as attractive and acceptable to neighbours as possible."]
["Resident","CPRE Gloucestershire","Not sure","","",""]
["Resident, Other","","No","","",""]
[]
["For complete comments on this topic please also refer to 'Questionnaire Responses' sheet 'Q.15' 'Q.16' and 'Q.17' "]

{"sheet":"New Homes","index":13,"n_rows":10,"n_cols":6,"rows_kept":10,"cut":false,"hidden":false,"merged":[[9,0,11,4]]}
["Your role ","Organisation","Q.12 Should the Strategic and Local Plan use the local annual housing need calculation from the Standard Method?","Q.12a If no, please set out what you consider the councils should use instead.","Q.13 Should we build more homes or fewer homes than the government's Standard Method?","Q.13 What reasons or constraints do you think there are there for building more/fewer homes than the Standard Method?"]
["Resident","","Yes","","",""]
["Resident","","No ","The ability of the local infrastructure to support additional housing ( availability’s of schools, doctors and dentist without the need to travel).  Transport links and the effect that additional housing will have a main routes into towns and city’s during times of flooding, minor roads being not suitable for the volume and size of the traffic.","Build fewer","Green fields are being taken over for houses and solar farms, it won’t be long before the country will be unable to feed and support its population. You can’t take it back when it’s gone."]
["Resident","N/A","Not sure","","Not sure","Specific 'non-standard' changes in population size, I would assume. Creation of a new town, relocation of significant employer, etc. I am not aware of these changes in this area, but they may exist."]
["Resident","CPRE Gloucestershire","Not sure","","Build fewer",""]
["Resident, Other","","Yes","","",""]
["Local Councillor","Minsterworth Parish Council","Not sure","","Build the same amount as the Standard Method","inadequate infrastrucure"]
["Resident","","Not sure","","Build more ","objectors"]
[]
["For complete comments on this topic please also refer to 'Questionnaire Responses' sheet 'Q.12' 'Q.12a' and 'Q.13' "]

{"sheet":"Scenarios","index":14,"n_rows":49,"n_cols":4,"rows_kept":49,"cut":false,"hidden":false,"merged":[[48,0,50,4]]}
["Scenario","Comments","Participants","Votes"]
["Scenario 1 Urban concentration",4,36,96]
["Scenario 2 Urban extensions",2,22,41]
["Scenario 3 Urban extensions, avoiding green belt",2,33,72]
["Scenario 4 New strategic settlement",3,26,64]
["Scenario 5 Rural dispersal",6,19,37]
["Scenario 6 Sustainable Transport",4,34,87]
[]
["Youth Engagement "]
["Scenario 1 Urban concentration",0,2,6]
["Scenario 2 Urban extensions",0,2,3]
["Scenario 3 Urban extensions, avoiding green belt",0,2,6]
["Scenario 4 New strategic settlement",0,2,6]
["Scenario 5 Rural dispersal",0,3,7]
["Scenario 6 Sustainable Transport",1,5,14]
[]
[]
["Comments on scenarios from portal"]
["Your role ","Organisation","Scenario","Comment"]
["Resident","","Scenario 1 Urban concentration","I am supportive of the Urban Concentration approach. This strategy is in line with our objectives to fulfil housing demands, particularly in key areas like Cheltenham and Gloucester. Concentrating on high-density developments is pivotal for reaching these housing targets, and it also contributes to the vibrancy of our urban centres. Nonetheless, it is vital that this development strategy is underpinned by policies that prioritise high design quality in denser projects, ensuring that the increase in density doesn't detract from the visual and functional appeal of the urban landscapes."]
["","RTPI","Scenario 1 Urban concentration","Gloucestershire Young Planners express support for the Urban Concentration scenario. This approach aligns with the priority to meet housing targets, specifically in Cheltenham and Gloucester. High-density development not only facilitates the achievement of these targets but also enhances the vibrancy and footfall within urban centres. It is essential, however, to couple this with a policy framework that emphasises high design quality for higher density development projects. Such a policy would ensure that while density increases, the aesthetic and functional quality of urban spaces is maintained or enhanced, contributing positively to the urban fabric.  In this context, it is crucial not to overlook the importance of green spaces within these urban areas. Green spaces play a pivotal role in placemaking, offering essential environmental, social, and health benefits. They are integral to creating high-quality, sustainable urban environments, balancing built density with natural elements, thereby enriching the quality of life for residents and visitors alike. Their inclusion in urban planning is vital to the overall success and liveability of our urban settlements."]
["Resident","","Scenario 1 Urban concentration","It's vital that all brownfield sites are developed before greenfield sites are used to protect the natural world and reduce crime in the cities and towns. This approach will reduce journey times for people to access shops, etc. The utilities are already present."]
["Resident","","Scenario 1 Urban concentration","Urban Concentration would involve developing within Gloucester and Cheltenham. This would rejuvenate city centres and use some unused previously developed sites.  Transport links are already there and road networks too so this is a good option in my view."]
["Resident","","Scenario 1 Urban concentration","I believe this is the best of the six scenarios.  This plan will put the least pressure on Gloucestershire Highways as it won't significantly increase the number of roads and it will reduce the use of vehicles as public amenities are within walking distance or a short bus ride for the residents.  This plan will have a positive effect on the economy of local businesses, such as shops and restaurants, due to increased footfall. Increasing the density of population in urban settlements will inevitably increase the demand of local businesses.  This plan will also significantly impact our declining wildlife population, and many species are already rapidly losing their natural habitats due to new housing developments. If wildlife is at all a consideration, we ought to leave as much land as we can for nature.  Green spaces can easily be incorporated in urban settlements. I have seen it put into effect in Singapore, which very much improved the quality of life for the residents and also beautified the urban areas. Their urban green infrastructure types are parks, community gardens, green roofs etc. Urban green infrastructure also has a positive effect on wildlife population."]
["Resident","","Scenario 2 Urban extensions","The Urban Extensions strategy receives strong backing from me. This plan effectively merges new development with existing urban areas, making good use of existing infrastructure and facilities like retail areas, schools, and other services. The areas surrounding Cheltenham, particularly Bishop Cleeve and Shurdington, are ideal for such extensions. The goal here should be the merging of these settlements, as they are already seen as part of the larger Cheltenham area. The majority of this land is also in Flood Zone 1, making it more suitable for development than other areas in the county.  As a result, we propose a reassessment of the Green Belt policy in these areas to allow for necessary residential and commercial developments. However, it's crucial to preserve certain Green Belt areas to avoid the merging of Cheltenham and Gloucester. Expansions of this scale will require comprehensive transport strategies to accommodate increased demand and aid in achieving sustainable development aims."]
["","RTPI","Scenario 2 Urban extensions","The Gloucestershire Young Planners are in strong favour of the Urban Extensions proposal. This strategy integrates development with existing urban settlements, effectively utilising available infrastructure and amenities such as shops, educational facilities, and other services. Particularly, Cheltenham, along with nearby settlements like Bishop Cleeve and Shurdington, presents a prime opportunity for such extensions. The aim should be to merge these settlements together, as Bishop Cleeve and Shurdington are already widely regarded as part of the broader Cheltenham region. Furthermore, most of the land between Cheltenham and Bishop Cleeve/Shurdington falls within Flood Zone 1, which is not the case for other parts of the county, making it more suitable for development.  As such, we advocate for a re-evaluation of the Green Belt policy between these settlements to facilitate essential housing and commercial developments. Nonetheless, we recognise the necessity of maintaining some Green Belt areas to prevent the merging of Cheltenham and Gloucester. Of course, significant growth of this nature would necessitate the development of comprehensive transport plans to ensure the adequacy of the road network and public transport systems, thereby supporting the increased demand and contributing to sustainable development goals."]
["Resident","","Scenario 2 Urban extensions","The review and significant modification of the Green Belt in the region is essential to achieve the sustainable developments that are desperately needed. This revision is particularly vital in the context of the Urban Extensions strategy, which I wholeheartedly support.  The areas surrounding Cheltenham, notably Bishop Cleeve and Shurdington, are prime areas for such extensions. Integrating these settlements, already seen as part of the expansive Cheltenham region, is a logical step forward."]
["Resident","","Scenario 3 Urban extensions, avoiding green belt","I have reservations regarding this scenario, mainly due to its potential to hinder reaching the required housing targets. The current Green Belt policy might significantly restrict economic growth and have adverse effects on social aspects, especially affecting the housing accessibility for younger people. A balanced approach, harmonising the need for housing with the preservation of green spaces, would be more effective."]
["","RTPI","Scenario 3 Urban extensions, avoiding green belt","Gloucestershire Young Planners have reservations about this scenario, primarily due to its potential limitations in achieving the required housing targets. The current Green Belt policy could act as a significant constraint on economic growth and affect social outcomes, particularly for younger demographics struggling with housing accessibility. A more pragmatic approach may be required to balance the need for housing development with the preservation of green spaces."]
["Resident","","Scenario 3 Urban extensions, avoiding green belt","The Green Belt is small and the diagram is misleading. It was designated Green Belt for good reason. Merging of the towns by uncontrolled urban sprawl would damage all of them by destroying their unique identities. This would likely have a negative impact on economic growth by downgrading the value and attractiveness of each town. Green spaces are insufficient for wildlife corridors and the loss of Green Belt land would have irreversible effects on wildlife."]
["Resident","","Scenario 4 New strategic settlement","While not outright rejecting the idea of new strategic settlements, I see this approach as less desirable than others, such as urban extensions. Urban extensions provide a more sustainable growth route, utilising existing infrastructure and minimising the requirement for extensive new constructions. Urban extension maintains community integrity. On the other hand, new settlements demand considerable investment in infrastructure and risk fragmenting services and communities. If new settlements are to be considered, it's crucial to provide detailed transport studies to ensure they are viable and sustainable."]
["","RTPI","Scenario 4 New strategic settlement","Gloucestershire Young Planners support in principle the concept of new strategic settlements, however, we are mindful that other scenarios such as urban extensions offer favourable benefits such as a sense of community continuity and supports existing urban economies. Nevertheless, it is a strategy we support as long as they harness sustainable credentials and look at ways in which to reduce carbon emissions, enhance green infrastructure and biodiversity, and promote socially inclusive communities.  Strategic settlements provide an opportunity to deliver significant housing and employment related development to meet the future needs of all three local authorities without putting considerable pressure on existing services and facilities in existing settlements. It is recognised that such developments require considerable investment in infrastructure to ensure existing networks are not at overcapacity and comprehensive transport evidence will need to be provided to support this development scenario. However, delivering new settlements provides the opportunity to design and deliver new infrastructure that would not only support emerging and existing communities, but pave the way to achieving a net zero carbon future."]
["Resident","","Scenario 4 New strategic settlement","The garden town east of Ashchurch is the preferred option of the new strategic settlements. This will enable sustainable planning linked to the existing network of the motorway and railway line. This provides opportunities for innovative ideas."]
["Resident","","Scenario 4 New strategic settlement","The Highnam / Churcham triangle suggestion is absolutely NOT a suitable area for this size of development.  a. The traffic this development will generate will be disabling for the parish and area as a whole, causing major problems on our road network. Local commuters experience major traffic problems already in and around the Highnam and Over areas (B4215 & A40) and this development will dramatically increase these issues. This development would add at least 8,000 extra vehicles to the 10,000plus currently travelling daily along to and from Gloucester, the M5, Cheltenham and Ledbury. The highways infrastructure is not fit for purpose and is frequently hit by flooding from run-off and the River Severn bursting its banks. The A417 Maisemore road has been closed due to flooding at least 4-5 times already this year and that has a massive detrimental knock on effect pushing even more traffic onto the B4215 and A40 going from Highnam towards Gloucester. It can take at least 30 minutes even on a good day to get from Highnam to the Over roundabout and that should really only take 3 minutes. Add in 8,000 extra vehicles and flooding and it is a disaster.  b. Prime arable land would be lost.  c. This option only identifies land in the TBC area, and doesn’t share the responsibility with Gloucester and Cheltenham. Development West of Gloucester is fraught with so many complications and we only have 1 river crossing so everything bottlenecks as it is - without any further developments.  d. This Highnam/Churcham development would have a huge detrimental impact on local biodiversity, increasing  the possibility of flooding and water run-off risks not to mention the impact on climate with the increase in vehicular transport.  e. The scale of this development could not be integrated into the community but would obliterate it due to its sheer size."]
["Resident","","Scenario 5 Rural dispersal","I support the Rural Dispersal approach in existing rural settlements. These areas have the potential to contribute to the housing supply. However, this development must be governed by clearly defined settlement boundaries and the identification of suitable land for growth. This method ensures that the development is sustainable, appropriate to the context, and aligns with strategic planning goals, whilst respecting the unique characteristics and capacities of rural communities."]
["","RTPI","Scenario 5 Rural dispersal","Gloucestershire Young Planners support the Rural Dispersal concept, particularly in existing rural settlements. There is potential for these areas to increase housing provision. and employment related development, helping to manage affordability and job prosperity. The Young Planners recognise that rural communities must thrive as without opportunities for increasing growth in these locations, deprivation will increase. However, the growth must be proportionate to existing rural settlements to retain and enhance sustainability.  This can be underpinned by proposing settlement boundaries which sensitively respond to the limits of the settlement itself but do not restrict further growth throughout the plan period [and policy that supports contextually responsive design approaches in these locations]. The approach will ensure that development is sustainable, contextually appropriate and aligned with strategic planning objectives, whilst also respecting the character of rural settlements."]
["Resident","","Scenario 5 Rural dispersal","The Rural Dispersal would enlarge existing communities where capacity for existing infrastructure and resources, like the schools, Doctors etc is already at over capacity, as in Highnam. They also lack a good transport network, so would not be cost effective. In Highnam, being a service village, development has already occurred and continues to receive development. It is already at the point of the infrastructure not coping with demand. The roads are already too busy, the school is over capacity and local children have to travel fair distances to a school by car. This goes against developing a good carbon footprint. The B4215 which is a B road in name only, but much more like an A road; cannot cope as it is - large lorries use it as a 'cut through' to Gloucester from the M50 as a short cut, and have to compete with the many commuters travelling over the Severn at the only point they can (The Over roundabout) whilst also competing with farm tractors and machinery, as this is a rural area with many farms. The road network serving and passing through Highnam village is already beyond saturation point. This also creates road safety concerns, adversely affected also by excessive speeding along this section of road.  The narrow Two Mile Lane is increasingly being used as a main access thorough fare between the B4215 and the A40, taking far more traffic than it was ever designed to do.  The Highnam community can only expand so much before features which residents cherish and identify with are either compromised or are at risk of being destroyed. Life in Highnam has already been severely compromised following the construction of the 88 house development and the proposed additional 95 house development will exacerbate this further. Major new development “upstream “at Newent exacerbates this. The village should not expand further.  The current network of services to the existing community (gas, electricity, domestic water, surface and foul water drainage, telephonies, broadband etc.) are already at full capacity. Service outages, leaks and general breakdowns are a regular occurrence. This creates serious constraints on additional development, the provision of which would take this beyond breaking point.  Surface water flowing off the new  housing development at Lassington Reach is already creating downstream flooding problems through Highnam Court and beyond through Minsterworth to the River Severn.  Significant additional development would seriously compound this.  Highnam has  important heritage assets (Church of the Holy Innocents, Highnam Court etc.), a traditional landscape patchwork of field hedgerows and boundaries, woodlands, together with plentiful wildlife.  This would be lost if the village was further developed with biodiversity severely compromised.  The majority of people in Highnam of working age travel elsewhere for their employment. This is not sustainable in the long term if we are to reduce our carbon emissions by cutting down on car journeys. More development is only going to put more cars on an already overstretched road network. Therefore an upgrade and provision of additional buses would help provide more sustainable modes of travelling.  I am concerned at the potential loss of good quality, productive farmland surrounding Highnam which greatly contributes to our need for food security and helps maintain local bio diversity.  HIG010: Land to west of Highnam (remainder of the field) and Rodway Golf Club are both totally unsuitable areas for development for each and every reason stated above. HIG011: This open farmland has no discrete means of access for development, lies in established open farmland, and has no intrinsic merit for alternative use development. HIG006, 007 and 013: These sites straddle Lassington Wood, an important wildlife, leisure and amenity facility much enjoyed by residents. These sites are all totally unsuitable for any form of development, indeed HIG006 lies on the crest of a prominent hill and landscape feature, and HIG013 largely comprises steeply sloping, unstable land."]
["Other, Resident, I work for a charity or volunteer in the area","Flood Warden","Scenario 5 Rural dispersal","I do understand the reticence of some to Rural Dispersal, almost a kind of not around her you don't, but I still live in a rural settlement where I was born 76 years ago. I have acted as Flood warden for many years, offically since 2007,  I have been on the Parish Council for 40 years, my father 35 years before me, both of us acting as Chairman for a considerable length of time. Our village is heralded as a linear village - yippee - however, 10,000 cars drive through every day and here are no pavement for most of that,  so finally very few talk face to face over the garden gate. Events for the Church and the Gardening club etc, are populated by visitors in cars from elsewhere. DO NOT get me wrong, I love my village BUT, with a by pass, yes there would have to be development around the periphery of the village, we could return to sanity. the two roads which are used to escape J9 misery in the morning and the evening would have junctions on the by-pass. We could make the much heralded \"Linear Village \" a Conservation area with all that entails, one or two would not be happy as that might reduce their \"Commercial activity from home\" but the extra houses would allow us a new sewer pumping system, possible a return to a village shop so no jumping in the 4 litre 4x4 to get a bottle of milk.  (We know what it entails, we  - the Parish Council, opened the only  Community Run store in the Tewkesbury Borough Council area back in 2014 - godsend in Covid times.  )  We coul have a nbew bridge - promised by GCC Highways in 2008 - still waiting,  New Storm Water system. blocked in 2007 and took 12 years for Severn Trent to repair. We have a Village School which is 75% capacity. We have two Churches in our 2000acre Parish both unique and   ready for an influx of parishioners. SO I say hands up for rural dispersal. Properly designed  this has so much to commend it.  We ahve to consider Global warming, smaller development areas are easier to mitigate. Bishops Cleeve with its 400 + extra houses provides a storm level which is out of control.  One Environment Agency officer recently remarked - \" we weren't aware of the amount of run off from Bishops Cleeve.  Two weeks ago the E.A Flood alert stated \"we consider that our gauge has risen at a rate which suggests  a fault with our equipment.\" please disregard. WRONG and yet the Planners have already agreed another 4000 house upstream and the drainage infrastructure is not agreed yet!!  No to major urbanisation which we in the rural areas pay for. Rural dispersal every time."]
["Resident","","Scenario 5 Rural dispersal","this scenario would be at to the detriment of the rural settings and create complex transport requirments with limited ability to support climate goals. I am in favour of limited, controlled support for these communities not this wholesale approach, especailly as it will not solve our overallvhousing needs."]
["Resident","","Scenario 5 Rural dispersal","I believe this is the worst of the six scenarios.  This plan will require many more roads, and Gloucestershire Highways is already struggling to adequately maintain existing roads.  This plan will not help the economy of local businesses. With many settlements of sparse population, the footfall will also be sparse for local businesses, such as shops and restaurants.  This plan will also significantly impact our declining wildlife population, and many species are already rapidly losing their natural habitats. I live on a housing estate in Innsworth and there isn't much wildlife around. However, because there is a large housing development underway nearby, a badger found itself in my garden last year. If wildlife is at all a consideration, we ought to leave as much land as we can for nature."]
["Other, Resident, I work for a charity or volunteer in the area","Flood Warden","Scenario 5 Rural dispersal","'@Ploy Culley , I understand the feelings your feelings, however, along the path of the M5 in particular and all Motorways in general, during the design and build stage back in the 1960s many local roads were used for access and hence were widened from Country lanes. This has now resulted in rat runs through rural villages. we get 10,000 vehicles each day. many speeding as they are late for work. That pattern is reproduced in so many villages within 15 miles of each M5 junction . I sat on a Rural Forum for several years of Parish Council Chairman  with our Councils situated along the M5 corridor.   Each of us noted serious traffic problems but as we were small and insignificant  we achieved very little.  If we agreed and recognised the problems each of us could accept a sufficient number of properties to provide a by-pass, so the original village could return to peace but also get a community Hall and a village shop.  We did it in our one village in the Parish but sadly due to lack of foresight we didn't get the by- pass which was suggested.  However we now have a Community spirit and the shop and the Community centre. But due to no bypass, both villages h get 10,000 vehicles each day due to the J9 and J10 situation . It is getting progressively worse.  I was born here. at that time we could play hopscotch in the road. now no-one walks up and down the road - far too dangerous.  Ecology, watch the wild life that follows the motorway as a  green corridor - from Badgers to Red Kites.  They soon learn."]
["Resident","","Scenario 6 Sustainable Transport","The Sustainable Transport scenario is a good option. Enhancing transportation options, particularly those that are environmentally friendly such as bicycle paths, is key in modern urban planning. Coordinating housing development alongside such transport infrastructures can significantly lower carbon emissions and elevate the living standards of residents. Areas like those between Cheltenham and Bishop Cleeve, supplemented with new cycling paths, serve as ideal examples of locations for housing development alongside initiatives for sustainable transport."]
["","RTPI","Scenario 6 Sustainable Transport","Gloucestershire Young Planners are supportive of the Sustainable Transport proposal. Enhancing transport options, particularly eco-friendly ones like cycle paths, is crucial in today's urban planning. Integrating housing development with such transport infrastructure can significantly contribute to reducing carbon emissions and improving the quality of life for residents. Areas like the land between Cheltenham and Bishop Cleeve, alongside new cycle paths, are prime examples of where housing development can be located with sustainable transport initiatives. In order to effectively implement this strategy, it is imperative to review the green belt boundaries. This adjustment is essential to make room for these new developments, aligning with our sustainability and transport objectives. Furthermore, collaboration with key stakeholders, including the county council, is paramount. Their involvement and support will be crucial in delivering these schemes."]
["Resident","","Scenario 6 Sustainable Transport","Sustainable transport reduces air pollution, promotes better health and enables people to be more connected. A mass transit system from Gloucester, through Cheltenham to Tewkesbury would reduce car usage and could promote cyclability along the route."]
["Resident","","Scenario 6 Sustainable Transport","Sustainable Transport option links areas of good transport networks, promoting more sustainable travel, and reducing carbon emissions from transport. In my option, this is suited more to Urban areas where the transport networks are already there - NOT areas like Highnam which would only put more traffic on the roads."]
["Resident","","Scenario 6 Sustainable Transport","This option includes Whaddon which is not a proven sustainable option. The Active Travel England submission to Stroud DC on the Taylor Wimpey Whaddon planning application is critical on the scope for Whaddon to be sustainable. Stroud Road will not support safe cycling nor will Naas lane."]
["Youth Engagement ","Youth Engagement","Scenario 6 Sustainable Transport","This is a far better proposal than all the others as it does not require people in new areas to own cars. Cheltenham has too many cars. The last thing it needs is houses on the outskirts or in rural areas which will require people to drive in if they wish to access the full services the towns and city provide."]
[]
["For complete comments on the scenarios please also refer to 'Questionnaire Responses' sheet 'Q.28.a' and 'Q.29'"]

{"sheet":"Pros & Cons","index":15,"n_rows":224,"n_cols":6,"rows_kept":224,"cut":false,"hidden":false,"merged":[[223,0,225,4]]}
["For complete comments on the pros & cons of the scenarios please also refer to 'Questionnaire Responses' sheet 'Q.28' and 'Q.28.a'"]
["Scenario","Place of residence","Your role ","Organisation","Do the pros and cons identified for this development scenario form a fair and accurate assessment?","Which one(s) do not and what are your reasons?"]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","No","Not convinced it would lead to increased journey lengths relative to other options "]
["Scenario 1: Urban Concentration","Cheltenham","I work for a charity or volunteer in the area, Resident","","Yes",""]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","No","In Cheltenham and Tewkesbury.....  We should look to a balance of housing and commerce in urban areas, aligning to the need across age groups.  Therefore, increasing \"green\" use of transport.    Therefore, I disagree with \"Increased journey lengths.....\" and \"Limited opportunity to deliver climate change....\""]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","No","Disagree of cons: \n1. Likely harm the setting - High density can actually add to the character of an area, if designed to a high standard. High quality buildings do not harm heritage assets, poorly design buildings do. \nPotential Strain on existing social and community - Any increase in housing would be a strain on existing services. That is why when more buildings are constructed, more needs to be provided for a growing population. Regardless of where they are built in the county. "]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","No","Cons all are disagreed with. A well designed mixed development high rise scheme can best meet the demands of residents for housing, with sustainable transport. Best opportunity to deliver climate mitigation through reduced energy consumption, rainwater harvesting, and district heating and cooling schemes. But residential unit density needs to be significantly higher than present than current."]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Business owner","","Yes",""]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","No","It would not increase journey length. No data to back this assumption up. Why would it harm important heritage assets? It would surely improve the character of the urban area especially in areas of brownfield or derelict land and areas of existing poor development. Sympathetic and imaginative design can enhance the urban environment. Better opportunity to deliver climate mitigation than in greenfield areas with bigger overall impact on residents already in urban areas e.g air quality improvement from reduced commuting in/out. Repurposing existing buildings uses far less carbon than building from scratch. Demolition should be avoided to reduce use of new concrete."]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","No","Preserving green belt areas is so important for the population this should be weighed more heavily than other factors. I care less about the preservation of heritage sites than access to nature and conservation of wildlife and nature because we are in a climate and nature emergency. Why hasn't the climate benefits and the health benefits of this been listed as a pro. "]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","No","Add increased flood risk to the cons. "]
["Scenario 1: Urban Concentration","Gloucester","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Gloucester","Resident, Business owner","","Yes",""]
["Scenario 1: Urban Concentration","","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Gloucester","Resident","","Yes",""]
["Scenario 1: Urban Concentration","","Resident","","No","Loss of employment space, increased journey time,"]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Gloucester","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Tewkesbury Borough","I work for a charity or volunteer in the area","Winchcombe Walkers are Welcome","No","The road infrastructre is already there and travel movements have not been considered."]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","Yes",""]
["Scenario 1: Urban Concentration","","Resident","","No","The last three bullet points in cons should be highlighted in bold. Harm to the character of the urban area is certain not likely, there is not limited opportunity to deliver climate change measure/ community infrastructure this would have a negative impact on these. Also the strain on community infrastructure/ schools/ health facilities is a potential it is a certain. High population densities in city centres are widely associate with poverty, high levels of crime and anti social behaviour."]
["Scenario 1: Urban Concentration","Gloucester","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Gloucester","Resident","","No","Missing a few Cons. Its More free housing for illegals. Tesco Quedgeley is also already creaking with the amount of people it has using it. The council has already ruined Hempsted when it was once a lovely quiet village. Never mind the fact the roads aren't built to cope, made worse by the ridiculous cycle routes being installed. As for the city centre, that is in ruins. We need shops. Or a decent outlet similar to cribbs causeway to bring visitors to the city first before considering more housing and people on creaking infrastructure. "]
["Scenario 1: Urban Concentration","Cheltenham","Student","","Yes",""]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","No","I am not sure the increase journey lengths would happen as if done properly there would be a mixed development neighbourhoods so it jobs could actually be closer. Less commute distances also should might be less journey lengths.\n\nLimited opportunity to deliver climate change mitigation measures also dont make much sense. Its easier to deliver a green project by it self in the green belt rather than in the middle of a building development.\n\nThere will always be an increase in existing social and community infrastructure anywhere they build housing. Build more infrastructure \n\nPros could be a better community feel. If people are cycling and walking and using things in their local community rather than community a long distances to access places they might care more about their local community "]
["Scenario 1: Urban Concentration","","Resident","","No","Cons are excessively negatively presented - 1, 3 to 7 appear intended to dissuade rather than accurately reflect scale of impact"]
["Scenario 1: Urban Concentration","Gloucester","Resident",null,"Yes",""]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Business owner","","Yes",""]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","No","The basic map shows development between Gloucester and the floodplain. However the floodplain directly abuts the urbanised areas. Development to the west of the urban centre in Gloucester would lead to flooding."]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","Yes",""]
["Scenario 1: Urban Concentration","","","","No","Cons I feel are overly negative. Unclear con regarding increased journey lengths. Harm to heritage assets is not, I think, 'likely', and can be avoided."]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","No","Cons:\nIncreased journey lengths...residents would be concentrated nearer to employment opportunities; plus many employees have the opportunity now for hybrid work, including working from home part of the week.\nLimited opportunity to deliver climate change...climate change mitigation measures can be delivered by reduced commuting times, centralised services such as heat networks from CHP or ground source heat pumps."]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","Yes",""]
["Scenario 1: Urban Concentration","","I visit the area for work, but I live elsewhere","","No","If we build in the city i do not see how this could increase journey lengths, but this may be because i was unaware the city was outside the SLP? I imagine with more people in the city, there would be more traffic unless we make non-carbon forms of transport e.g. bikes easier and safer to use in the city. This would negate then the point about limited opportunity to deliver climate change mitigation - surely there are a range of ways to address this? "]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 1: Urban Concentration","","Resident","","Yes",""]
["Scenario 1: Urban Concentration","","Planning agent or developer","Newland Homes","Yes",""]
["Scenario 1: Urban Concentration","Gloucester","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Gloucester","Resident, Other","","No","In the cons. I don't see how it can harm the heritage of the areas or limited opportunity to deliver climate mitigation measures."]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Other, Resident, I work for a charity or volunteer in the area","Flood Warden","Yes",""]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 1: Urban Concentration","Cheltenham","Resident","","Yes",""]
["Scenario 1: Urban Concentration","","Resident","","No","The pro's"]
["Scenario 1: Urban Concentration","","Resident","","No","Potential strain on existing social and community infrastructure, such as schools and health facilities.\nThis is true wherever new housing is provided so is not a con specific to this scenario.  In fact if new schools and health facilities are built along with new housing  then existing residents nearby can also benefit."]
["Scenario 1: Urban Concentration","Tewkesbury Borough","","","No","I agree with the pros. High density urban development is the most sensible option for sustainable development if we want to mitigate climate change. I disagree with some of the cons namely the increased journey times, harm to heritage buildings, limited opportunities for climate mitigation and strain on existing infrastructure. These would seem to be things that with good planning, shouldn’t be a con, and certainly no more a con than if development happened anywhere else. It may mean that large detached houses won’t be available in this scenario, but there are plenty of those in existence already and urban development would seem to provide a better opportunity to provide dwellings suitable for an ageing population"]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","No","should be discussing intelligent use of brownfield in conjunction with strategic urban extensions. dont dismiss urban regen as difficult. think holistically. removal of green belt avoided to maintain separation and identity of settlements"]
["Scenario 1: Urban Concentration","","Resident","","No","The plan is biased upon development in and around gloucester and cheltenham, lets have a plan the builds shed loads of houses around tewkesbury town as well call it scenario 7"]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Business owner","L3Harris","Yes",""]
["Scenario 1: Urban Concentration","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Cheltenham","I work for a charity or volunteer in the area, Resident","","Yes",""]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Local Councillor","Highnam with Hawbridge ward TBC","Yes",""]
["Scenario 2: Urban Extensions","Cheltenham","Resident","","No","For Cheltenham and Tewkesbury....I find this balance incorrect.   We should prioritise building in urban areas, utilising existing green transport rather than build on green belt and then having to extend public transport out to new areas.  I believe all the pros to be biased and not balanced."]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Business owner","","Yes",""]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","No","You have not listed the important cons of impact on wildlife, increased flooding, the loss of green spaces having an impact on residents mental health and physical health. Extension isn't necessary to improve public transport or walking or cycling so why is it listed as a pro of this particular plan. Most of the pros kissed are not unique to this type of development.  I'm deeply opposed to this as a plan. "]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","No","Where are improvements to existing highways and flood prevention?"]
["Scenario 2: Urban Extensions","Cheltenham","Resident","","No","Remove Mass rapid transport as there is unlikely to be space for implementation along existing transport corridors. Add a con of increased flood risk on urban watercourses such as Hatherley brook and river chelt. Add a con of increased pressure on public services e.g. leckhampton GP surgery. Add a con of negative impact on biodiversity and net zero ambition as the concrete, vegetation clearance and travel associated with urban creep has a significant carbon impact. Add a con of reduced public access to green spaces / green belt impacting health and wellbeing"]
["Scenario 2: Urban Extensions","Gloucester","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Gloucester","Resident, Business owner","","No","Cons - building these satellite developments would increase the number of car users and require many more roads, which would increase costs on local government, increase pollution, and increase congestion."]
["Scenario 2: Urban Extensions","","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Gloucester","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Gloucester","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Cheltenham","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Tewkesbury Borough","I work for a charity or volunteer in the area","Winchcombe Walkers are Welcome","Yes",""]
["Scenario 2: Urban Extensions","Cheltenham","Resident","","No","Not all cons have been highlighted - more road usage and existing infrastructure have not truly been considered."]
["Scenario 2: Urban Extensions","Gloucester","Resident","","No","Added Con: Would require significant investment into infrastructure, especially increase public transport and road structures to avoid more congestion"]
["Scenario 2: Urban Extensions","Cheltenham","Student","","No","development on the side of the town will most likely be motivated by housing and will inevitably end up being more semi detached houses with no real draw to new areas. They do not provide new value to the existing Cheltenham town. They will end up being poorly connected by transport as the demand to travel to these areas will be low as it is unlikely these new areas will have enough density and retail to call for mass rapid transit."]
["Scenario 2: Urban Extensions","","Resident","","No","Introduction and points raised are clearly biased in favour of this option. \n\nThis indicates a pre-determination within the consultation \n\nThe pros & cons need to be re-considered from a neutral / objective perspective if the consultation is to be valid and effective "]
["Scenario 2: Urban Extensions","Gloucester","Resident",null,"Yes",""]
["Scenario 2: Urban Extensions","Cheltenham","Resident","","No","Preservation of Green Belt land is essential."]
["Scenario 2: Urban Extensions","Cheltenham","Resident","","No","New developments built in the green belt never seem to differ from single family housing. I havent seen any medium/high density buildings in the outskirts of cheltenham.\n\nMedium/high density buildings provide ample opportunity to have built in commercial space on the ground floor.\n\nThe buildings do get built but the amenities don't. There is a lot of oppotunity to do things but the only thing that normally happens is low density, car centric development is built "]
["Scenario 2: Urban Extensions","","","","No","Cons do not mention the additional strain on existing services which are unlikely to be improved, especially regarding transport. Overly positive and not balanced."]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","No","No large range of available sites in Tewkesbury due to flooding issues. No facilities to meet the needs of this increase in population, doctors, schools and dentists are already overstretched. Tewkesbury already has its fair share of social housing."]
["Scenario 2: Urban Extensions","Cheltenham","Resident","","No","Transport - roads are already becoming more and more congested. High quality public transport is not affordable and unlikely to be chosen over car use. \nLoss of greenfield land is bad for wildlife and people. Pollution will increase, health of the population will decline and mental illness will increase due to the lack of green space and the loss of defined community boundaries."]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Gloucester","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Gloucester","Resident, Other","","Yes",""]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Other, Resident, I work for a charity or volunteer in the area","Flood Warden","No","The Present headlong dash with supposed planned development has forgotten the one serious input. The people living there. We have watched Bishops Cleeve grow at a ridiculous speed.   No Community spirit - why - no Community ethos.  OMG we need schools- where we have used all the land?  oh well one meeting I attended he schools officer considered it was fair that 4/5 years olds could walk 3 miles to school in morning and 3 miles home in the afternoon. He didn't look as if he walked 100 yards!  I attended along with 7 others the discussion last night on Town and Village centre planning.  The gentleman talked solidly for 35 minutes and never once mentioned Community quality of life.  it is no wonder there are serious problems of gangs culture when nobody has a sense of ownership with their  Community. As Chairman of the Local Parish Council we built out 16 acres of  Brown Field  Land. with a Community Centre in the Middle and a Community Shop.  We, the Parish Council handed the Community Centre over to a residents committee to give them ownership!!  People have souls, People have feelings. Planners seem to forget that.  they just dictate where people should live.  WRONG"]
["Scenario 2: Urban Extensions","","Resident","","No","The sites suggested do not fit well into the area or with transport infrastructure. \nThe Tewkesbury site is reliant on the A46 and the M5 but does have a railway option. \nBoddington is just Robert Hitchins pushing their development and is nearby to the Cheltenham N W 4000 housing and the West Cheltenham Cyber park housing. \nThe Whaddon site has only Stroud Road, a congested roundabout and no east west links other than country lanes. It fails to connect to the adjacent Tuffley. Bus, cycle and pedestrian options are add-ons not designed to improve or even work well. The use of a narrow country lane and single lane railway bridge is a desperate attempt to try to access facilities west of the railway line.\n"]
["Scenario 2: Urban Extensions","","Resident","","Yes",""]
["Scenario 2: Urban Extensions","","Resident","","No","Again the development is UNFAIRLY concentrated around Gloucester and Cheltenham lets have scenario 7 where all the houses are built around Tewkesbury town centre - THIS IS BEGINNING TO LOOK LIKE ITS BEEN COBBLED UP BY TEWKESBURY TO PROTECT TEWKESBURY"]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Business owner","L3Harris","No","Potential loss of higher quality agricultural land for food production. The flip side of this is that poor quality agricultural land could be transformed. Potential loss shouldn't happen if the land is appropriately assessed before its developed. "]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 2: Urban Extensions","Tewkesbury Borough","Resident","","No","There is no mention of carbon impact comparison between urban concentration and urban expansion.  Urban extension uses far more carbon than concentration in terms of new build, transport distances, infrastructure etc."]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Cheltenham","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Cheltenham","I work for a charity or volunteer in the area, Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Cheltenham","Resident","","No","It is strange to present this as a standalone option in this way.  It should explicitly state that it should reflect prioritising existing urban areas.  Only if urban area cannot be found then use urban extensions (non-greenfield).  This has to be the best option and should provide the required housed capacity.  The Councils should incentivise build in urban area and dis-incentivise building on greenfield sites.  This should be done through developer contributions to infrastructure.  Currently, it is cheaper and easier to build on greenfield sites."]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Resident",null,"No","Need specifics , actualities and not consultant speak.Nationally it is exactly the same.Where and when not maybe or ifs and buts."]
["Scenario 3: Urban Extensions, avoiding the Green Belt","","Other, Statutory/Specific Consultee, Resident","The Leigh Parish Council","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","","Resident","","No","the green belt is farmed so last con does not make sense. does not mention brown field and does not take into account of all the agricultural land which now have supermarkets on them. Aldi at Reddings, Morrisons at Metz Way etc etc"]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Resident","","No","Where are provisions for extra school places, enhanced highway and flood defences? "]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Cheltenham","Resident","","No","Remove reference to mass transit - there is insufficient space on existing travel corridors for its implementation. Add to cons loss of public access to green space impacting health and wellbeing. Add negative impact on biodiversity and increased carbon emissions due to vegetation clearance and carbon emissions from concrete and travel. Add increased flood risk due to building on green space e.g. Hatherley brook and river chelt. Add increased pressure on public services, e.g. leckhampton gp"]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Cheltenham","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Gloucester","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Gloucester","Resident, Business owner","","No","Cons - Increased car traffic, and subsequent pollution and congestion."]
["Scenario 3: Urban Extensions, avoiding the Green Belt","","Resident","","No","Public transport is severely lacking as are access to good quality public services in Tewkesbury and surrounding area. This need will not be met in line with the build and would lead to major problems for the area. Let alone the issues of flooding reducing the road network during those times leading to a massive tailback issue on key routes"]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Gloucester","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Resident","","No","Current infrastructure (schools/transport/ medical) in the area would not be able to cope with increased population influx. \nIncreased journey lengths.\nLoss of agriculture land.\nGreater impact on areas already affected by flooding "]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Gloucester","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Cheltenham","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","I work for a charity or volunteer in the area","Winchcombe Walkers are Welcome","No","CON Current infrastructure is not considered, roads, schools medical facilities would need upgrading. "]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Gloucester","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Gloucester","Resident",null,"Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Cheltenham","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Cheltenham","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Other, Resident, I work for a charity or volunteer in the area","Flood Warden","No","Once more, the planners disregard the flood plain and the effect on Urban development on downstream communities. As a Flood warden for many years working through the 2007 floods 2012, 2014, 2019  2.20 flood and the recent 6 month period totally unheard of before, get so angry as Authorities keep planning in areas where the effect of urbanisation affects downstream  Communities. Our own Parish  now had Flood gauges which show rainfall effect 30 minutes after the rain 2 miles away. Attenuation - it does not work.  The whole system needs re-working. This SFL pays very little heed to the effect of mass urbanisation on  Flooding and traffic in rural areas."]
["Scenario 3: Urban Extensions, avoiding the Green Belt","","Resident","","No","The sites suggested do not fit well into the area or with transport infrastructure. \nThe Tewkesbury site is reliant on the A46 and the M5 but does have a railway option. \nBoddington is just Robert Hitchins pushing their development and is nearby to the Cheltenham N W 4000 housing and the West Cheltenham Cyber park housing. \nThe Whaddon site has only Stroud Road, a congested roundabout and no east west links other than country lanes. It fails to connect to the adjacent Tuffley. Bus, cycle and pedestrian options are add-ons not designed to improve or even work well. The use of a narrow country lane and single lane railway bridge is a desperate attempt to try to access facilities west of the railway line."]
["Scenario 3: Urban Extensions, avoiding the Green Belt","","Resident","","No","The sites suggested do not fit well into the area or with transport infrastructure. \nThe Tewkesbury site is reliant on the A46 and the M5 but does have a railway option. \nBoddington is just Robert Hitchins pushing their development and is nearby to the Cheltenham N W 4000 housing and the West Cheltenham Cyber park housing. \nThe Whaddon site has only Stroud Road, a congested roundabout and no east west links other than country lanes. It fails to connect to the adjacent Tuffley. Bus, cycle and pedestrian options are add-ons not designed to improve or even work well. The use of a narrow country lane and single lane railway bridge is a desperate attempt to try to access facilities west of the railway line."]
["Scenario 3: Urban Extensions, avoiding the Green Belt","","Resident","","No","Increased journey lengths as housing and economic growth etc.\nThis was not shown as a con in the nearly identical option 2.  How can the fact that this option avoids green belt make such a difference?  You have said (correctly) under Pros that this plan places employment opportunities within walking and cycling distance of the new residential areas.  How can that be an economic growth con?"]
["Scenario 3: Urban Extensions, avoiding the Green Belt","","Resident","","No","Another scenario that leaves Tewkesbury untouched, jeez this is getting boring - hands off green field, hands off green belt scrap the plans they are crazy"]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Business owner","L3Harris","Yes",""]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Resident","","No","its not clear that this option would be supported by high quality transport infrastructure"]
["Scenario 3: Urban Extensions, avoiding the Green Belt","Tewkesbury Borough","Resident","","No","Greenfield development is easy development for developers but carbon intensive. Where is the carbon impact analysis? Soil carbon, traffic carbon, new build and new infrastructure carbon is ignored. Ecologically and enviornmentally far worse than urban concentration. "]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident","","No","I think the pros are highly dependent on certain other scenarios being met. The cons are equally vague. For example ‘will lead to worsening housing unaffordability’. How are you quantifying that? Why will investment in rural shops and services not be supported? Is the requirement for preparation really a con? I feel this is very misleading. "]
["Scenario 4: New strategic settlements","Cheltenham","I work for a charity or volunteer in the area, Resident","","Yes",""]
["Scenario 4: New strategic settlements","Gloucester","Resident","","No","The last three points of the Pro’s column are all ‘could happen’ but realistically never happen. We saw this with the new build development in Lassington reach in Highnam 5 years ago -  improvements to transport, access to schools, medical care (Highnam Pharmacy), this hasn’t happened. My neighbour within the new builds could not get their child in Highnam primary school or the neighbouring one in Tibberton. They actually moved house in the end. I understand that Highnam nursery and the pharmacy are at capacity too. \n\nThe traffic into Gloucester is a nightmare during rush hour, and you can imagine what it was like last week when Maisemore AND Longford flooded, and the traffic from Maisemore, Ashleworth, Hartpury etc all had to divert through Hartpury and Highnam in order to get to Gloucester or Cheltenham. \n\nWe cannot keep ploughing new build developments into locations where there is not infrastructure to support them. Highnam is desirable because of a few reasons, and one of them being its green spaces which now look like they are all subject to planning being approved.\n\nAs a 26 year old I don’t believe the issue to be supplying enough houses, it is mortgage interest rates and inflation."]
["Scenario 4: New strategic settlements","Cheltenham","Resident","","No","I believe this is the second best option to developing brownfield urban areas.  This provides an opportunity to provide a high quality development with generous (to allow for future extensions) infrastructure.  It is important that shops, schools, services and facilities are well supported and managed to make the development a success.    I think this latter sentence challenges statement \"Investment in rural shops, services and facilities would not be supported\",  The councils (taxpayers) should not be left to pick up the pieces from the developers."]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident",null,"Yes",""]
["Scenario 4: New strategic settlements","","","","No","I believe the pro's and con's have been written in a way that is inaccurate and designed to sway a decision to build on greenbelt land"]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident","","No","I think it is totally wrong to suggest that building the garden town will help with flood water management. Those fields visibly collect water and where will this go if they are built on? Tewkesbury is increasingly at risk of severe flooding as it is because of climate change, so to suggest building more on sites that flood is absurd - surely the problem will be worse. \nYou can't suggest building on green land and then list \"green spaces, biodiversity net gain, climate change mitigation\" as pros of this strategy - it can't be true. Planting a few trees and bushes in a housing estate around a green and calling it a green space fails to understand how barren this would in terms of biodiversity. \n\nI agree it would really disadvantage the shops and business and the town centre in general.  and urge you not to continue with this plan. "]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident","","No","The proposal for development on TBC/ Forest of Dean boundary has already been roundly rejected.  Why is this reappearing? "]
["Scenario 4: New strategic settlements","Gloucester","Resident","","Yes",""]
["Scenario 4: New strategic settlements","","Resident","","No","In the ‘pros’ it is not enough to say ‘could’. Definite ling term support and commitment needs to be made in order for any successes. Improved public transport, access to health care facilities etc need to be part of the plan which goes beyond a ‘could’ scenario otherwise already stretched facilities will break for everyone. These areas have been planned along already stretched toad networks. All it takes is for flooding, a major rta or road closure and the road network comes to a complete standstill now, let alone with additional much bigger communities."]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Local Councillor, Resident","Boddington Parish Council ","Yes",""]
["Scenario 4: New strategic settlements","Gloucester","Resident","","Yes",""]
["Scenario 4: New strategic settlements","Tewkesbury Borough","I work for a charity or volunteer in the area","Winchcombe Walkers are Welcome","No","Vitality of town centres has been lost due to out of town developments in Cheltenham and Tewkesbury."]
["Scenario 4: New strategic settlements","Gloucester","Resident","","Yes",""]
["Scenario 4: New strategic settlements","Gloucester","Resident",null,"Yes",""]
["Scenario 4: New strategic settlements","","","","Yes",""]
["Scenario 4: New strategic settlements","Cheltenham","Resident","","No","Building more homes should require the development of the single carriageway A40 between Over roundabout and Longford roundabout. It's a missing link in the A40 causing congestion."]
["Scenario 4: New strategic settlements","Cheltenham","Resident","","Yes",""]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident","","No","I do not understand why the options for new settlements at either Boddington or Churchdown/Highnam are being considered when Tewkesbury Garden Town has been approved and is already in the planning process.\nThe Churchdown/Highnam settlement option is completely unsuitable as all employment opportunities would be to the East of the River Severn causing even greater pressure on the already congested A40 and the single River Severn road crossing at Over roundabout and therefore would definitely not 'provide or enhance bus/rail services ... promote active travel by walking and cycling'. This development option was proposed a few years ago and dismissed out-of-hand by the Forest of Dean council after significant local opposition. This option should not be considered in this plan as it includes land which is located within the boundaries of a council who are not part of this SLP."]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident","","No","This is a very bad idea; any development West of Gloucester puts more strain on the already too busy roads, and if at Highnam/Churcham, there are no opportunities to provide or enhance other means of travel - there is not the infrastructure there. \nIt is well known that this side of Gloucester suffers from bad flooding and consequent road closures - already this year the A417 Maisemore Road has been closed several times due to flooding and this has a knock on effect - diverting traffic to the B4215 & A40, both of which are already suffering from too much traffic from the M50 and the Forest of Dean. The B4215 is a B road in name only and getting from Highnam to the Over Roundabout in the mornings can take at least 30 minutes from the bottleneck of traffic and it should only take about 3 minutes.  Building 4000 at Highnam/Churcham would be disastrous.\nThere is not the space to enable sites to incorporate more infrastructure without severely damaging the ever dwindling agricultural land and green countryside spaces. The current schools, doctors and other facilities in rural locations cannot support any more people. Already people are having to drive to other areas to take their children to school and this is only going to increase the already bad traffic on the roads west of Gloucester.\nThere is only 2 bridges that go over the River Severn -  one near Bristol and the other here at Over Roundabout west of Gloucester. The traffic, when it builds up due to flooding and increased car usage effectively 'cuts off' the Forest of Dean - there is no other way for them to get across the river other than at Over. It is an absolute nightmare already. \nBuilding around Highnam is building on Greenbelt! We do not want to lose our rural and agricultural heritage."]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident","","No","No mention of the new M5 junction which will likely cause chaos if going through Tewkesbury. Sure this needs to be considered before allowing people to raise concerns or offer opinions. We need all of the facts."]
["Scenario 4: New strategic settlements","","","","No","This area is very busy with traffic passing through to south Cheltenham/Gloucester, development would not be easily supported here. This proposal doesn't reflect the actual usage of the area."]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 4: New strategic settlements","Gloucester","Resident, Other","","Yes",""]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Other, Resident, I work for a charity or volunteer in the area","Flood Warden","No","Once more the same assumptions are being made with reference to flood mitigation. The land suggested East of Tewkesbury is drained through the Isborne, The Carrant and the Tirle, The Carrant and the Tirle  caused untold millions of pounds worth of damage in 2007 and since to Tewkesbury and the surrounding  Communities. The Isborne decimated Toddington and Sedgeberrow and other local Communities.   Major areas of urbanisation causes untold problems in drainage and that one will be totally traffic locked by the A46.  Who designs this stuff. I have spoken at  several major Junction 9 Conferences  since 2009 and still they keep building alongside the A46.  spread the houses around local villages so they can have small rural shops to provide car  free shopping.  Do the planners ever get oit of their offices. the Gentleman running the online discussion last night admitted that he has given up leaving his house at lunchtime to pop into Tewkesbury to get a coffee - it takes him longer than an hour and he lives in the town! Come on!"]
["Scenario 4: New strategic settlements","","Resident","","No","Good assessment, but the spread of housing and employment needs to be more widespread to reduce travel and enable to have housing with people able to live locally.\nCould enable better sustainable options. Improve environmental concerns."]
["Scenario 4: New strategic settlements","","Resident","","No","Investment in rural shops, services and facilities would not be supported.\nThis is equally true of Scenarios 1, 2 & 3.  Why have you singled out Scenario 4 for this criticism?  You could equally make it a Pro that rural shops, services and facilities would not be overwhelmed by Scenario 4 (or 1, 2 & 3) "]
["Scenario 4: New strategic settlements","Tewkesbury Borough","","","No","The pros don’t seem to be particularly strong or relevant. More importantly both the Boddington and Highnam locations are situated in or surrounded by the governments flood risk zone, with the current road infrastructure seeming unlikely to be suitable for large scale development"]
["Scenario 4: New strategic settlements","","Resident","","No","do not support this - another crazy tewkesbury town gets untouched scheme. looks to me like Gloucester and Cheltenham need to tell Tewkesbury to take a hike lets go it alone, it makes sense"]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Business owner","L3Harris","Yes",""]
["Scenario 4: New strategic settlements","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","Cheltenham","Resident","","No","I think this option should be adapted to encourage \"worker cottages\", ie limited to 2-3 bedrooms, and not upmarket 4-5 bedroom houses.  I think the last couple of pros could be adapted.  Pitched this right this could be part of the mix alongside driving urban development first."]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Resident","","No","Where are the:  essential planning / costing for provision of highway access, utilities, drainage, flood protection, extra school places?"]
["Scenario 5: Rural Dispersal","Cheltenham","Resident","","No","There appears a bias to protection of rural character and community over the protection of green belt and peri urban areas between these pro and con lists"]
["Scenario 5: Rural Dispersal","Gloucester","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","Gloucester","Resident, Business owner","","Yes",""]
["Scenario 5: Rural Dispersal","","Resident","","No","It would also lead to potentially more localised flooding as more land is built upon exasperating an already growing situation. "]
["Scenario 5: Rural Dispersal","Gloucester","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","Cheltenham","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","Gloucester","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","Gloucester","Resident",null,"Yes",""]
["Scenario 5: Rural Dispersal","Cheltenham","Resident","EDF","No","Cons 2, 5 not applicable if areas are chosen correctly and you assess impact correctly."]
["Scenario 5: Rural Dispersal","Cheltenham","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","Cheltenham","Resident","","No","Destroys rural identity, increases car usage, may hollow out city centres."]
["Scenario 5: Rural Dispersal","Cheltenham","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Resident","","No","Pros:\nThere are few 'choices for people to live and work in the countryside' and this scenario will only create longer commuting times and increased road traffic with resulting increased noise and air pollution.\nThe houses that will be constructed by property developers will be typical 4-bed detached homes which will not 'make a significant contribution to providing affordable housing in rural areas'."]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Resident","","No","This would NOT safeguard the greenbelt - it would harm it.\nThis would NOT support rural communities - our communities are already over run and Highnam has no capacity for any more people to join either the local school or Doctor's surgery - both are at full capacity. All this would do is mean more people have to rely on cars to get to other schools and GP's and that is going to make much worse an already awful traffic issue on the B4215 and the A40 west of Gloucester.\nThere are more choices for people for employment and easier travel in the Urban areas, NOT the rural.\nAffordable housing won't be helpful if people have to travel miles in their cars just to get to a school or a shop or a GP or work. \nAll this option does is harm the already overpopulated small rural areas, loss of countryside and prime agricultural land and puts more and more cars on an already over used road network.\nWill NOT be able to support or provide the infrastructure needed or have suitable transport links."]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Resident","","No","I feel the pros and cons in all of these options are weighted in favour of avoiding rural areas. Point 1 in the cons can be added to all of the options. I feel this plan would work well in rural areas. It spreads the load and makes it more affordable for families to live in pleasant surroundings. "]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","","Resident","","No","Issues of providing affordable housing in rural areas, this seems unlikely to be achieved through the plan and not a benefit of the suggestion. Many more negatives than positives of the idea."]
["Scenario 5: Rural Dispersal","Cheltenham","Resident, I work for a charity or volunteer in the area, Planning agent or developer","","No","I think that visually the cons of above list are too plentiful against the pros. Rural housing/dispersal is a desirable part of the solution to improve the issue of housing delivery across the districts though it is not the only solution and all of the various scenarios, urban consolidation/sustainable transport/new strategic settlement etc, should be seen in the round when combined in a synergic way.  \n    Increasingly, as the Affordable Housing Manager for GRCC, I see first-hand the approaches from proactive Parish Councils to help future proof their communities for a sustainable future; however, these approaches can too easily be stifled by the restrictiveness of exception site policy, financial cost, and NIMBYism. Rural dispersal as a SLP objective can and should be the way forward. \n    Firstly, delivering new rural housing schemes will preserve the rural economy and infrastructure (including, but not limited to, social care, rural transport, primary schools, pubs, Post Offices, and village stores). Many of the jobs I have listed are lower socio economic employment options which make affordability a problem in rural areas so schemes should be affordable-led in the first instance. If we can appropriately develop new schemes premised on smaller house types then commute times are reduced sustaining existing services as well as providing a foundation for future sustainable growth. This ties in well with the green agenda and TBC's declaration of both a climate and ecological emergency.\n     Secondly, all sections of society irrespective of settlement size, should carry collective responsibility for the long-term future of their district. A rural dispersal policy will encourage villages to be proactive in planning decisions and build a dynamic rural community. Rural communities risk stagnating over the coming years with an aging population and increasing age segregation between urban and rural population unless an interventionalist approach is taken to stop this. Communities and settlements, irrespective of size, should be empowered by the SLP to be part of the solution for growth. Communities should be supported through robust community engagement to understand routes to delivery: (1) SME Developers on Market Led Schemes; (2) Registered Providers on Rural Exception Sites; (3) Community Led Housing Groups.\n     Finally, a more dynamic and varied rural housing market of newly built smaller type properties will enable the existing built environment (larger detached, boutique and executive style homes so often found in places of rural affluence) to be used for their intended purposes – for families. Were smaller, downsizing properties to be built then this would encourage better utilisation of larger homes to their potential. "]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Other, Resident, I work for a charity or volunteer in the area","Flood Warden","Yes",""]
["Scenario 5: Rural Dispersal","","Resident","","No","Sound points but rural communities also need new smaller developments to enable them to survive and prosper. \nThe spread of new housing needs to be proportionate to the size of existing communities and not over-size or dominate the original conurbation. "]
["Scenario 5: Rural Dispersal","","Resident","","No","Additional Con:\nUnlikely to place many new homes within practical walking or cycling distance of the new residents' place of work."]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Resident","","No","From what we see from the sites put forward in our area, development seems to be being encouraged in a way that could totally change and degrade the way of life for thousands of residents, deplete the green belt and impact on special landscape areas. It's not just about redundant sites and buildings - massive tracts of agricultural land are being considered. Development on this scale would change the character of rural settlements forever and just add many more car journeys to our roads, and create surface water run off problems and more. From a developer point of view, green belt projects are much easier than brownfield, but are hugely damaging to our precious landscape. The sites assessments use the term 'potentially developable' - how much time has really been spent on careful site specific investigation, as opposed to a broad brush desk top study. 'Potentially developable' is the beginning of a very slippery slope indeed."]
["Scenario 5: Rural Dispersal","","Resident","","No","this is the option to re-house rich londoners and outsiders while destroying our countryside- looks like Tewkesbury Borough Council are incompetent- do not agree with this scenario "]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Business owner","L3Harris","Yes",""]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 5: Rural Dispersal","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Resident","","No","I disagree with the final con. How are you quantifying the ‘general’ needs of the rural economy? This isn’t clear."]
["Scenario 6: Sustainable Transport","Cheltenham","Resident","","No","\"Coalescence of Cheltenham and Gloucester...\" and first con do not reflect the loss of town/city/village identities as building along the transport links joins together towns and villages.  I don't like this option."]
["Scenario 6: Sustainable Transport","Gloucester","Business owner","","Yes",""]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Resident","","No","Consider an option to construct a new railway station at Kingsway and develop the area to the east.\nConsider urban concentration  / extension around Ashchurch train station."]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Resident","","No","There will always be a bottleneck of traffic on the A40 as it passes to south of Highnam.  Where is the strategic thinking of building that  'other Missing Link\" - a new bridge over the Severn to between Gloucester and say, Lydney? "]
["Scenario 6: Sustainable Transport","Gloucester","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Gloucester","Resident, Business owner","","Yes",""]
["Scenario 6: Sustainable Transport","Gloucester","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Cheltenham","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Gloucester","Resident","","No","Con Coalescence of Gloucester and Cheltenham. I think this strategy could be undertaken without this effect if it is planned well. "]
["Scenario 6: Sustainable Transport","Cheltenham","Student","","Yes",""]
["Scenario 6: Sustainable Transport","Gloucester","Resident",null,"Yes",""]
["Scenario 6: Sustainable Transport","Cheltenham","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Cheltenham","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Resident","","No","There is NO viable options other than cars on the already too busy B4215 & A40 road and public transport networks. So this option would do nothing to mitigate or enhance sustainable travel. Lorries already use the B4215 as a shortcut from the M5 to Gloucester and beyond and are competing with Farm traffic and commuters from the Forest of Dean and all villages west of Gloucester trying to get to Gloucester and beyond to work and schools. There is NOT the network west of Gloucester, particularly as it is made worse by flooding every year and that is only getting worse.\nThis option does NOT meet the needs of the rural economy and we do not have the capacity for any more development in rural locations without great cost to our countryside and agricultural heritage."]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Gloucester","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Gloucester","Resident, Other","","Yes",""]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Other, Resident, I work for a charity or volunteer in the area","Flood Warden","No","I disagree with the list of pros and cons unless I have misunderstood the suggestions. The idea of developing in bite size areas along the main road and rail routes seems eminently sensible.  These need not be in large urbanisation units but extension of existing settlements to provide the potential for regional shopping areas for groceries and everyday consumables.  When we built out Stoke Orchard we opened the only community run shop in the TBC area but it needs another 300 houses to make it viable. during Covid lockdown  it was fabulous.  The problem comes when  rural road through rural communities are used from Mass Urbanisation areas-  Tewkesbury, Ashchurch, Bishops Cleeve to Cheltenham, Gloucester etc (Avoiding Junction 9) when single track rural roads get 3000 to 5000 vehicles each day, drivers trying to avoid roads blocked by  over developed residential areas.  Major roads should be house free, IE residential areas have their own system access in major roads in one or two places and not house drives on to major roads.  Biggest problem is that the traffic infrastructure is never designed or built before the houses. It is always catch up.\n   Who would ever design  motorway  junction in the middle of the town.  they didn't Junction 9 was designed in 1945,  but planners have successively built around it with a usable alternative infrastructure.  just look at the number of traffic lights and junctions between J9 and Aston Cross.\nAnother situation the A40 crossing the A 38 at Longford!  These are all examples of past design systems like this  SLP. No vision, no understanding."]
["Scenario 6: Sustainable Transport","","Resident","","No","Agree with all the above but it does not cover all the pro's and con's.\nAlso has Staverton (Chelt Glos) Airport been considered for housing and employment beyond present use.\nNot suggesting it is a good idea, but again has pro's and con's.\nPlus -\nThe sites suggested do not fit well into the area or with transport infrastructure. \nThe Tewkesbury site is reliant on the A46 and the M5 but does have a railway option. \nBoddington is just Robert Hitchins pushing their development and is nearby to the Cheltenham N W 4000 housing and the West Cheltenham Cyber park housing. \nThe Whaddon site has only Stroud Road, a congested roundabout and no east west links other than country lanes. It fails to connect to the adjacent Tuffley. Bus, cycle and pedestrian options are add-ons not designed to improve or even work well. The use of a narrow country lane and single lane railway bridge is a desperate attempt to try to access facilities west of the railway line."]
["Scenario 6: Sustainable Transport","","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","","Resident","","No","no this is not what the people want, go back to the drawing board, involve the public at an early stage not when they have barely a week to respond to a SLP planning document- you people can just move on we have to live here so hands off Tewkesbury"]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Business owner","L3Harris","Yes",""]
["Scenario 6: Sustainable Transport","Cheltenham","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Resident","","Yes",""]
["Scenario 6: Sustainable Transport","Tewkesbury Borough","Resident","","No","Sustainable transport options are already available but residents don't often use them due to the car ownership culture and safety concerns. Urban concentration, car free city centres, car clubs and re-opening trainlines and stations would help. Mass transit is a pipe dream until there is massive redesign of existing infrastructure but there is no funding for this in Glos. Living close to where you work helps with sustainable transport so housing should be concetrated where jobs are."]
[]
["For complete comments on the pros & cons of the scenarios please also refer to 'Questionnaire Responses' sheet 'Q.28' and 'Q.28.a'"]

{"sheet":"Additional Scenarios","index":16,"n_rows":12,"n_cols":7,"rows_kept":12,"cut":false,"hidden":false,"merged":[[11,0,13,4]]}
["Your role ","Organisation","Title","Description","Comments","Likes","Dislikes"]
["Resident",null,"A Blended Approach","Seems very likely - as indicated by the voting exercise - that a blend of scenarios will be adopted.  So, my additional scenario is simply an acceptance that we cannot follow one path, we need to follow a blended approach.#  For me - as I voted - that is probably a focus on Urban Extension, New Strategic Settlement and Sustainable Transport, with a small element of Urban Concentration.  Presumably there is uncertainty around budgets etc. so this kind of approach ought to provide some flexibility??",2,2,0]
["","","Urban Extension Avoiding Greenbelt and Sustainable Transport","This is obviously bringing together the options 3 and 6. Experience to date with the Stroud District Local Plan examination which is currently paused given the mess it is in with regard to strategic road infrastructure and new settlements suggests that any plan that relies on wishful thinking hundreds of millions to sort out motorway junctions etc is likely to fail. The challenge I wish to make is to not take what can often be seen as the easy option of new strategic settlements and work to improve the current urban settings, extend those sympathetically and use and build along the strategic transport infrastructure that already exists and that can be improved for more modest sums. Can planners meet this challenge?",0,1,0]
["Resident","","development scenarios and smarter thinking.","The scenarios put forward and voting suggests an 'either or' situation. What should be stressed is that intelligent options can be used in tandem. For instance, urban regen combined with limited urban extension plus reconnected sustainable transport corridors. Repairing unsightly brownfield land is key to repairing and making our towns fairer places.  For developers, tearing up the green belt is the easy option - open clean sites where the same dull residential housing typologies proliferate and ruin the identity of rural settlements and cherished landscapes. Scale is everything - some of the sites described as 'potentially developable' are hugely out of scale with the rural settlements they neighbour.  (Take Southam, for example, where the suggested sites indicate a potential doubling in size of the village!!) Developers should actually be encouraged and compelled to think far more imaginatively and deploy a much broader range of contextural, sustainable and higher density typologies on cleaned up brownfield sites and urban extensions (as is encouraged widely by our European neighbours), and actively prevented from damaging the green belt by filling the gaps between historic settlements with nondescript and inappropriate 'estates'. We deserve cleverer thinking from those who would seek to profit from development.",0,1,0]
[]
["Comments received on above suggestions"]
["Your role ","Organisation","Title ","Comment","Likes"]
["Business owner","L3Harris","A Blended Approach","I do agree with the above but I think there would also be benefit in incorporating the re purposing of old building (industrial or residential) as mentioned in the Rural Dispersal scenario. Rural communities don't have to be forgotten. A blended approach is definitely the logical way forward.",1]
["Resident",null,"A Blended Approach","'@Rachel Hands  - good call...",0]
[]
[]
["For complete comments on the additional scenarios please also refer to 'Questionnaire Responses' sheet 'Q.27' and 'Q.27a'"]

{"sheet":"Rural Settlement Hierarchy","index":17,"n_rows":16,"n_cols":4,"rows_kept":16,"cut":false,"hidden":false,"merged":[[15,0,17,4]]}
["Your role ","Organisation","Are there any places not currently identified in the rural settlement hierarchy (below), which could/should be included? ","What places could/should be included in the settlement hierarchy?"]
["Local Councillor","Highnam with Hawbridge ward TBC","Yes","Brockworth, Churchdown Innsworth Twigworth"]
["Other, Resident, I work for a charity or volunteer in the area","Flood Warden","Yes","I base my suggestion on 40 years of Parish Council and 76 years living in the same village.  Until I retired from the Parish Council 12 month ago, been part of a rural forum of Chairman of 6 Rural Parish Councils situated between J9 and J10. We formed the forum some 3 years ago as it was evident that our Parishes were being used and abused with excessive traffic and very little support from Highways., Severn Trent, the Borough Council and other authorities as we just were not big enough.  My own village Tredington , heralded by many  as a Linear village, has a bridge over the Swilgate that is crumbling and has been condemned by  Atkins after a survey - no railings one side for 8 years, just a few red plastic hole guards. 2 weeks ago the water was 8 ft deep and swirling dangerously close to that bridge ,  Severn Trent took twelve years to repair a blocked storm water pipe that flooded numerous properties in 2007 etc etc etc. If we were included in a rural dispersal, we could have by pass, then create the old village road as a Conservation area, remove 10,000 cars each day from some of the finest 14th century properties in Gloucestershire, and give a heart back to the Community.  We are not the only village like this which is not a service village but has high traffic and high storm water and yet absolutely NO status.  IT is wrong, we have a Village school which is at 75%  on role,  land totally ing nearly 400 acres has been allocated as  Solar farms one in place and one to be built in our Parish of 2000 acres. we have  the M5 numerous gas and water mains of the national grid the main North South Railway line yet our little village has been condemned to death by the SLP. that is NOT right as it is isn't righ with so manyrural communities which would  benefit with 100 houses or so and a by pass to alleviate the problems of Junction 9 and Junction 10, the A 40 and the A417. Planners shut their eyes and ears but the damage in our rural communities is real. we need to grow to stay alive.  We need to grow to bring young people into our creaking ageing communities."]
["Business owner","L3Harris","Yes","Within service villages: Apperly and Hasfield and Chaceley"]
["Resident","","No",""]
["Planning agent or developer","OBK Land & Planning","No",""]
["Resident","","No",""]
["","","No",""]
["Resident","","No",""]
["Student","","No",""]
["","","No",""]
["Resident","None","No",""]
["Resident","","No",""]
["Resident","","No",""]
[]
["For complete comments on rural settlement hierarcy please also refer to 'Questionnaire Responses' sheet 'Q.30' and 'Q.30a'"]

{"sheet":"Additional Comments","index":18,"n_rows":28,"n_cols":7,"rows_kept":28,"cut":false,"hidden":false,"merged":[[23,0,25,4],[27,0,27,2]]}
["Your role ","Organisation","Title ","Comment ","Comments","Likes","Dislikes"]
["","","Plan for and Deliver Transport Infrastructure Ahead of New Homes","Tewkesbury Borough Council’s vision for the Tewkesbury Garden Communities includes 10,000 new homes being built, during the next 20 years, centred around the village of Ashchurch; predominantly on greenfield-land close to the A46, east of the Cheltenham - Birmingham railway line which divides the village.  The draft Programme Charter for the Garden Communities envisages development beginning in 2026.  Tewkesbury Borough Council, Gloucester City Council and Cheltenham Borough Council Strategic and Local Plan (SLP) considers afresh the development strategy for the area, in particular, whether it should continue to be based on the settlement hierarchy envisaged by the Joint Core Strategy, which it will supersede. Six distinct scenarios are presented and it is expected that the final strategy will be a combination of different elements from those options. Thus, it is by no means certain that the Tewkesbury Garden Communities will form part of the final SLP.  It will not be until early 2026 that the Regulation 19 consultation on the pre-submission draft SLP is expected to commence. Only after that is completed can the plan be submitted to the Secretary of State for independent examination and approval.  As detailed planning for supporting infrastructure for the Garden Communities can only be finalised once the SLP has been approved, there is considerable concern about the aspiration to commence construction of new homes as early as 2026.  For the reasons discussed below, the provision of adequate supporting infrastructure must be a key component of any development of the scale envisaged for the Garden Communities.  A traffic survey last July, showed that the residents of the 150 recently completed homes at Barleyfields, Ashchurch, undertook 90 car journeys on the A46 towards Tewkesbury on a weekday morning, between 07:00 and 09:00.  The capacity of the A46 towards Tewkesbury is limited to under 950 vehicles per hour constrained by the single carriageway design of the Ashchurch rail bridge and the adjacent residential developments.  There are already approvals to develop 1640 homes west of the railway line, in and around Fiddington. Many of the remaining 8360 Garden Community homes are destined to be built in the vicinity of Ashchurch and Pamington. To date, land with capacity for around 8500 homes has been identified in the areas of the proposed Aston-Fields and Seven Bends Garden Communities.  If the residents of these new homes were to demonstrate similar travel patterns to the Barleyfields residents, additional road infrastructure, with capacity approaching 3 times that of the current A46, would be required to link the new homes to the M5; employment in Ashchurch, Northway, Newtown and Tewkesbury and beyond; and the shops and other amenities provided by Tewkesbury.  Last year, it was announced that there is unlikely to be funding to deliver a bypass for the A46, from Teddington Hands to the M5, before 2036. Currently, during the morning and evening peak travel periods, the A46 operates at around 90% of capacity. Without a bypass to carry the A46 traffic from the midlands to the M5, in conjunction with new roads to carry local traffic from existing and proposed new homes towards Tewkesbury and beyond, Ashchurch would soon be gridlocked for much of the working day.  Government guidance on proposals for creating garden communities stresses the importance of demonstrating that they support economic growth and include provision for the timely delivery of necessary infrastructure. It also emphasises the importance of communities being built on a sustainable scale – with infrastructure to allow the communities to function self-sufficiently on a day-to-day basis - with capacity for future growth to meet the evolving housing and economic needs of the local area.  It should be clear from the above, that the provision of the A46 bypass is key to the successful delivery of the Tewkesbury Garden Communities programme. Gloucestershire County Council expects to consult on the routing of the proposed bypass this summer. Tewkesbury Borough Council should seize this opportunity to work with Gloucestershire County Council on the routing of the bypass and then plan the locations of new business opportunities with adequate access to the bypass and essential connectivity to the new homes.  Tewkesbury Borough Council should not be contemplating approving building this number of new homes without first addressing the issues of exactly where employment, education, medical and other key facilities will be located, and planning for and working with partners to deliver travel links with adequate capacity.  The current situation, whereby planning permission can be granted for residential development without supporting infrastructure being in place, must not be allowed to continue.  These are not just my concerns. Since the beginning of December 2023, a petition to this effect has been viewed over 8000 times and 540 people have put their names to it  (https://www.change.org/p/help-save-ashchurch-from-gridlock  ( https://www.change.org/p/help-save-ashchurch-from-gridlock/dashboard ) ).  Detailed calculations in support of the above conclusions are in the attached document.",9,3,0]
["Statutory/Specific Consultee","Woodmancote Parish Council","Flawed Forecasts underpin a very poor plan process","We understand that some form of standard methodology is required BUT that standard methodology needs to be underpinned by sound forecasts and sensible conclusions. The current forecasts are based on old data and unrealistic principles like fertility rates of 2.1 when we are actually experiencing 1.6. this means that instead of the population growing by 5% it will fall by 20%. Life expectancy is also overstated and this also drives up housing need. the standard method also suggests addressing an affordability problem by simply building houses more than you need. When the affordability ratio is great than 8 (ie house prices are 8 x average income) when the target is 4 x average income, building more 4 bedroom houses will not address the problem.  Finally the high forecasting depends on more Governmnet jobs when the plan is to reduce costs and drive up productivity.  Talking of productivity, sectors like high precision engineering and cyber security are driving up productivity fast and its entirely probably that increased growth in these sectors will occur with no increase in job numbers.  The summary of the forecast says it all. \"We have chosen the highest forecast because its the closes to the previous forecast need\" what sort of a forecasting system is that.  Local government needs to propose a targeted plan based on delivering genuinely affordable houses that are owned and managed by housing associations over the long term to meet the needs of the key workers the area needs to employ.",2,3,0]
["Resident","","Complete disregard for existing residents","I have lived peacefully at my property for 35 years.  I was not informed of a huge new development adjoining my property until it had been given planning approval.  The houses are built less than 10 meters from my stables and muck heap. I have never had any consideration from the council.  If I were to ask to build stables near to the houses it would be refused. I am being forced out of my family home.  It is no longer possible for me to keep my animals at my home.  My family and my life have been put in danger by this development.  The treatment I have received is disgusting.",2,1,1]
["Resident","","Minsterworth development","I would like the following comments and questions to be considered and in relation to the development taking place in Minsterworth.  Development is taking place around local footpaths, what is happening to preserve these footpaths and their access for the community?  What will be done to support local health services? They are already at capacity, will new infrastructure be put in place?  Are tree perseveration orders being considered for existing trees? such as the oak tree on the land near the village hall and Ellis Bank Lane.  What is being done to support fibre connectivity to properties? New builds, such as those on Ellis Bank Lane, do not have access to this infrastructure.  Where news trees have been planted on newer build estates, however, they have not been cared for, as seen on Ellis Bank Lane. What is being done to address this? or what will be done?  Consideration should be made for the sustainable development of villages and the development of resources such as parks with suitable, accessible equipment for children and their families.",0,1,0]
["Resident","","Lack of forethought regarding proposed development along A40 West of Gloucester","Please find attached an excerpt of the response from the Chairman of  Highnam Parish Council.  I completely agree with the points made in this document regarding the significantly increased traffic congestion, air pollution and flooding risks associated with any development West of Gloucester along the A40.  I would respectfully ask that these be seriously considered and reflected upon during the analysis of the responses as part of this initial SLP consultation process.",0,1,0]
[]
["Comments received on above suggestions"]
["Your role ","Organisation","Comment left under","Additional Comment","Likes"]
["Resident","","Plan for and Deliver Transport Infrastructure Ahead of New Homes","The current proposal seems to demonstrate a lack of thought about GP services. The surgery in Bredon, and indeed the ones in Tewkesbury do not have anything like the staff or premises space to take on this number of new patients. GPs are always an afterthought rather than being part of these applications. Even if they were to build a new surgery as part of the scheme, getting people to staff it is incredibly hard at the moment. Gloucestershire is not immune to the NHS workforce planning crisis with many local GPs heading towards retirement or reducing their hours as a result of the impact of the current workload. .",2]
["","","Plan for and Deliver Transport Infrastructure Ahead of New Homes","'@Jim  Ropner I couldn’t agree more and thank you for making the point.  Building a Garden Community is so much more than building more homes. As the Government guidance makes clear, proposals must enable ‘the communities to function self-sufficiently on a day-to-day basis’.  I would like to see similar words included in Garden Communities Programme Charter. Admittedly it does talk about having focal points for each of the 6 communities and new health facilities, primary and secondary schools; but it also suggests that each Community is likely to be delivered by different developers from 2026 onwards.  May be I am wrong, but I believe there needs to be a master plan for the Communities that lays out the locations of medical, education, employment, shopping and all the other aspects of life that will make the communities self-sufficient. Surely, it is the responsibility of TBC to commission and own such a plan which should be subject to public scrutiny before or after engagement with the authorities that will be responsible for delivering the services. Timing of the delivery of these facilities will be key to the success of the Garden Communities programme. All this must be done before developers can plan and build the homes.  There was such a plan for Tewkesbury Garden Town, when the MOD land was expected to be available, but I am not aware of anything similar for the Garden Communities.",0]
["Resident","","Plan for and Deliver Transport Infrastructure Ahead of New Homes","Totally support the above statement and Tewkesbury Borough Council must prioritise infrastructure before allowing further housing development In the Borough. The whole concept of a Garden Town in the Tewkesbury area is flawed and recent flooding indicates the muddled thinking of developing housing where the water table is at ground level. Climate change and rising sea levels spell disaster for new homes in the future.",2]
["","","Plan for and Deliver Transport Infrastructure Ahead of New Homes","'@Angela Brown as I said to Jim below,  I couldn’t agree more and thank you for making the point.  Regarding flooding,  I have no idea idea about the downstream effects of 10,000 new homes on or close to the flood plain, but I can see no good coming from it for residents north of Gloucester (Longford, Sandhurst, Maisemore, Over, …).",0]
["","","Plan for and Deliver Transport Infrastructure Ahead of New Homes","We already have a Local Plan for our village (Woodmancote). What reassurances can you give us that the wishes of the village will always take precedence over the aspirations of unscrupulous developers?",2]
["","","Plan for and Deliver Transport Infrastructure Ahead of New Homes","'@James Lever None, I expect ☹️",1]
["","","Plan for and Deliver Transport Infrastructure Ahead of New Homes","I also full support the above statement. I couldn’t agree more with @Angela Brown and @Jim  Ropner’s comments above.",1]
["","","Plan for and Deliver Transport Infrastructure Ahead of New Homes","We have had various consultations over the last 25+ years about upgrading or re-routing the A46 but nothing actually gets done. At one time we were led to believe that TBC would not allow any further development in and around Ashchurch until the A46 problem was resolved but development continues apace. With the proposal of 10K homes now to be built, the traffic congestion that will occur doesn't bear thinking about. A new bypass badly needs to be built ( to M5 Junction 10 ?) before substantial building works are started. Planned infrastructure must be in place for a co-ordinated scheme to work. I completely agree with the comments already made regarding building on land with a very high water table and for the requirement of health services to cope with such a large increase of local population especially considering how stretched existing service are at present.",1]
["","","Plan for and Deliver Transport Infrastructure Ahead of New Homes","'@Stuart Payne Thank for your support. My comments on the risks from flooding are here: https://strategiclocalplan.citizenlab.co/en-GB/ideas/flooding-the-proposal-needs-to-go-further",0]
["I work for a charity or volunteer in the area","","Complete disregard for existing residents","I sympathise, and agree, the sdc seems to have little concern for existing human residents or endangered species. They are proposing to raise the level of adjoining land by burying it under 6ft of builders rubble. This is completely unnecessary for the proposed housing development and only increases their build costs. It also destroys the existing hedgehog population and will be overbearing to the neighbours, only a metre away. The water runoff alone will create problems. And for what? Who gains from this pointless project?",0]
["Resident","","Complete disregard for existing residents","The Rural Dispersal option would enlarge existing communities where capacity for existing infrastructure and resources, like the schools, Doctors etc is already at over capacity, such as in Highnam. They also lack a good transport network, so would not be cost effective.  It is already at the point of the infrastructure not coping with demand. The roads are already too busy, the school is over capacity and local children have to travel fair distances to a school by car. This goes against developing a good carbon footprint. The B4215 which is a B road in name only, but much more like an A road; cannot cope as it is; large lorries use it as a 'cut through' to Gloucester from the M50 as a short cut, and have to compete with the many commuters travelling over the Severn at the only point they can (The Over roundabout) whilst also competing with farm tractors and machinery, as this is a rural area with many farms. The road network serving and passing through Highnam village is already beyond saturation point.  The current network of services to the existing community are already at full capacity. Service outages, leaks and general breakdowns are a regular occurrence.  Surface water flowing off the new  housing development at Lassington Reach is already creating downstream flooding problems through Highnam Court and beyond through Minsterworth to the River Severn.  Clearly, significant additional development would seriously compound this and new developments built on or next to flood plains are only going to exacerbate the problems..  Highnam a traditional landscape patchwork of field hedgerows and boundaries, woodlands, together with plentiful wildlife.  This would be lost if the village was further developed.  The majority of people in Highnam of working age travel elsewhere for their employment. This is not sustainable in the long term if we are to reduce our carbon emissions by cutting down on car journeys. More developments is only going to put more cars on an already overstretched road network.  Development would mean a loss of good quality, productive farmland surrounding Highnam which greatly contributes to our need for food security and helps maintain local bio diversity.  Stop turning our rural villages into Town extensions!",0]
["Resident","","Flawed Forecasts underpin a very poor plan process","By the way - I dont pretend to be an expert here but cant help thinking that the planning policy team wont be expert statisticians either and if we just end up blindly following forecasts where the underlying assumptions are not properly understood or challenged nor are those forecasts regularly reviewed (and I mean every 2 years) then the whole plan could be wrongly conceived.",2]
["","","Flawed Forecasts underpin a very poor plan process","I'm not sure I fully agree with some of the interpretation of the data, raised in the above Post, but the fundamental point that these forecasts need to be scrutinised in detail and the planning policy team need to understand whether the underlying assumptions and data are current and accurate and whether the final forecast that is being used in the rest of the planning process is the appropriate in all the circumstances. Ultimately, the whole plan’s objective is built on these forecasts and I agree that these need to be not only good forecasts but also reviewed regularly and fed back into the housing need.",0]
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["For complete comments please also refer to 'Questionnaire Responses' sheet 'Q.31'"]
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["Please note - The SLP team received one further submission but the authour did not give permission for the comment to be summarised, split into the relevant questions or sections, or displayed in any alternative way. This comment can be viewed on request from the SLP team. Please email info@strategiclocalplan.org"]

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["Comments received via email via Gloucestershire Wildlife Trust campaign"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\nOur natural environment is vital to human existence. We can't pollinate most of our crops without insects, for example.\nI would like to stand in support of any new local planning that is done including prioritised rooves that line up and face optimally for solar panels (and that they're fitted with options for batteries as a matter of course) and encourage developers to include aspects like hedgehog holes in fences and use minimal concreted areas /hard standing- partly for carbon and partly for flood/water management and allowing biodiversity.\nFood chains, and connections to nature have been shown to improve mental health which is on a downward trend. Please take this issue incredibly seriously (although I know many in council do)"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\nMost people that live here really care about the planet and nature.  We all want somewhere that is a green and beautiful place to live.  Our children and grandchildren will be left with problems that were not caused by them.\nStop using weedkillers on the streets.  Cut verges and open grass areas less or leave a border on the edge.  Plant more street trees.\nDevelopment on green field sites leads to loss of habitats for wildlife.  People will enjoy the buildings more and feel more connected to nature."]
["\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\nBeing in nature and having easy access to nature helps my mental health and physical wellbeing.\nEnsure housing developments have green spaces and areas for nature to thrive throughout is essential. Many are built as a tarmacked road network and do not consider green areas for both the community and nature. Ensuring that nature has space to thrive also would be beneficial, within a housing development.\nThis will be beneficial both for the community and the climate. Planning needs to be done with long term thinking."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe are part of nature on earth - it provides us with a sense of belonging when it is nurtured. If it is damaged it damages us in turn both physically and emotionally. Children at this particular time need to connect with nature for a balanced emotional upbringing.\n\n\nMandating the inclusion of swift bricks and bat bricks on all new house and industrial builds. These will act as an intimate link between the natural environment and the as built environment. See also the suggestions being formulated under the umbrela of the LNRS required as part of the Environmental Bill.\n\n\nBecause as people we need to belong to our world and that world is the natural world. In the 1960s and 1970s the so called Brutalist movement was in its ascendancy. This was an egotistical movement that did not care about people living in that environment. It was a failure causing great human suffering. If todays development does not take account of nature in a serious way it will become the second wave of the Brutalist movement with the same devasting results for people and other animals."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment is what sustains everything. People are part of an ecosystem, not separate from it and the decisions we make have implications for all life.\n\n\nThere should be no building in the countryside except in very rare circumstances. Development should be restricted to brownfield sites. Second home ownership should be restricted so that our villages can thrive and reduce the need to for new housing\n\n\nWe have a serious biodiversity crisis in the UK in addition to the Climate Crisis. Wildlife needs space and to be left undisturbed."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe are the custodians, not the owners of our countryside and need to protect it\n\n\nOnly build on brownfield sites and pass legistaion to re-purpose redundant office space above shops in high streets for low-cost flats - residents only!"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nSo much of the hedgerows, meadows and woodland have been lost to make way for large fields that can accommodate massive farm machinery and, in the past few years, green field sites are being used for housing development.  These green areas are not just vital for native flora and fauna but also for the communities who live here. It is very sad to see a rural area being transformed into a more urban (or, at least, suburban) area which diminishes the habitats upon which wildlife depends.\n\n\nThe first thing is to make brown field sites a priority when planning applications for housing development are submitted and also to avoid cutting grass in public spaces during the late Spring months. Also, councils could sow wild flower seeds in any green space where they can grow eg grass verges, edges of parks. Covering former grassland with concrete and tarmac exacerbates the problem of flooding in areas prone to becoming waterlogged during periods of heavy rain so this is also something that should be taken into consideration when granting permits for any commercial or residential development.\n\n\nNature can survive, indeed thrive, without humans but we cannot  survive without nature and if we continue to destroy natural resources and ignore the fact that our actions will continue to accelerate the negative effects of climate change then we will have to face the consequences."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe are fortunate to live in an area with easy access (at present) to green and open spaces. We realise how important this is to both our physical and mental health\n\n\nPrevent ribbon development when reviewing plans for housing developments.\n\nEnsure that natural feature, trees, hedges etc remain in situ.\n\n\nTe natural world faces a catastrophe with human degradation of the environment. This will rebound on the human species."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIncreased feeling of well-being, humans and animals living in harmony.  Better for everyone and everything.\n\n\nObvious really, but be very careful not to develop on well known flood plains.\n\n\nWe need to share the natural environment with all creatures already here among us."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nMany people use the local walks around our area for wellbeing and exercise. We have a local first school\n\n\nBetter litter picking services. More repairs to potholes in roads. Better up keeping of paths for walkers. More protection of SSSI areas and more and strict rules building on green belt land\n\n\nTo prevent flooding in local areas. To continue to protect and encourage wildlife and to conserve already vulnerable habitat and species in development areas"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nFor wellbeing and of course to help nature\n\n\nNew build to include swift bricks etc. A policy for minimum sized gardens but not postage stamp size. Green spaces, trees and water. Stop the destruction of habitat before and after planning.\n\n\nSo it can work that we can co exist."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt improves health and wellbeing.Green fields and trees are so much better for mental health.\n\n\nStop building on green belt areas and flood plains,. Build and improve brown belt areas. Develop empty buildings instead of new builds!\n\n\nMental wellbeing and exercise in green areas.Provide natural habitats for wildlife."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nUK is now the most nature-depleted country in Europe and reports suggest around 60% of our wildlife has gobe and we have only 3% of the wildflower meadows we had 50 years ago. Ultimately we all depend on natural system for our survival.\n\n\nCouncils should not release rural land which supports wildlife for building and where building is permitted, developers should be required to put aside a portion of the area for tree planting and/or rewilding.\n\n\nWe are part of nature and rely on natural cycles to maintain a stable sustainable environment and we are already falling short."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nPhysical and mental well-being, control of climate( wetlands lock in carbon) Eco green economy benefits\n\n\nEncourage sustainable developments that use natural resources.\n\n\nYou can’t beat Nature! e.g. flood barriers only divert water somewhere else, dredging creates faster water movement and erosion of banks. Wetlands soak up water like a sponge with extra benefits for wildlife and carbon capture"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt’s well known that having access to natural spaces is crucial for good wellbeing, lowering stress and strengthening coping abilities.\n\nBeing able to see, hear and support wild life has a huge positive effect on our physical, mental and emotional wellbeing. It is imperative that future generations have the opportunity to grow in an environment with clean air, water and soil whilst enjoying a diversity of wildlife and plants\n\n\nTo involve communities, via schools, groups, neighbourhoods etc. in the planning for developing strategies that support wild life as well as meeting our needs\n\n\nPlanning that supports and works with the natural environment makes for a healthier and more vibrant community, fostering a greater connection with the natural world and each other, reducing stress and all its associated negative effects.\n\nEnvironmentally, chopping down trees, changing water courses and general destruction of habitat has had disastrous effects leading to flooding and loss of species with all its knock on effects"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nHumans are mammals; we are part of nature. Nature provides us with many services, for free, ranging from pollination of crops, birds and flowers to enjoy and space to exercise. Non-human species have as much right to exist as we do, so we must give them space.\n\n\nDon't mow roadside verges more than once a year. Minimise pollution. Demand developers install SUDS, renewable power generation, bird boxes, plant trees and shrubs etc."]
["I support Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency.  This will  provide new momentum for and better integration of nature into the Strategic and Local Plan.\n\n\nIt is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt's essential for our wellbeing\n\n\nNew developments to include eg green corridors, hedgehog highways, swift & bat boxes etc\n\n\nOtherwise, development falls short of the high quality living environment we have a right to expect."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe are a part of nature not separate from it, so we all need to embrace and care for the environment\n\n\nMore fines for littering and more action taken to rid the scourge of littering\n\n\nSo that we have a healthy environment to live and share in"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThere is plenty of evidence to show that the natural environment improves wellbeing\n\n\nCouncils could take advice from the specialists- Gloucestershire wildlife trust, RSPB and other environmental agencies.\n\n\nTo keep an ecological balance of flora and fauna. To improve air quality. To improve living conditions for people."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI’m surprised we are discussing this!  The natural environment is absolutely crucial for everyone, including all wildlife.\n\n\nUrban and inner city rejuvenation ie building of all kinds to be built on disused sites, refurbish neglected buildings and recommission empty buildings for housing and business.\n\n\nBy leaving nature alone, biodiversity thrives and a thriving natural environment makes economic and societal sense eg mental and emotional health"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe need to prioritise wildlife immediately. We have been ignoring the importance of wildlife and the benefits it brings to our world. We will soon loose all that is wonderful about wildlife and nature because we keep destroying it. Wildlife adds so much to this world, we should not be taking it away.\n\n\nPlants more trees, less ugly terrible houses. Put more money into conservation, work with local wildlife trust. Get youth into helping preserve wildlife.\n\n\nAs above. Nature and wildlife is not something that can be grown quickly, it is more important to preserve and help wildlife."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe have to protect nature as a deliberate act, once it is gone it will not come back\n\n\nProtect natural habitats and make more nature spaces accessible to all\n\n\nNature was here first. We need it. Not only for life but for our well-being\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nAccess to nature is good for physical and mental health, reducing the burden on the NHS and improving the health of our communities. Removal of our natural spaces is bad for us as well as the environment.\n\n\nCouncils should consider developing and encouraging community engagement and volunteering to create small scale nature sanctuaries in our neighbourhoods, whether they are new or established. Every natural space, however small, is good for us and our local natural environment.\n\n\nWe have to try to stop the declines in bird and wildlife and also protect our natural spaces for flora and fauna, so any developments have to put back at least as much as they take out of the natural world."]
["\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature is a human right and everybody should have access to green spaces, it's great for mental health and clarity, for physical health and for metaphysical health\n\n\nStop building on greenbelt, create nature highways, biodiversity habitats. Stop cutting trees down"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause without it being healthy we cannot as a species flourish either\n\n\nPut it before profit! Or even better invest in a profitable future with renewables and hold Defra, Ofwat and The Environment Agency to account at last!"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI walk in  farmed countryside every day with my dog and see the contrasts with life and no life in hedgerows and crops.  The soil is the foundation for everything.\n\n\nI am willing to contribute more money to caring for nature as I do to wildlife trusts.  Encourage those who can but may be too old to 'work' to fund those who have the energy.\n\n\nBecause it is all interrelated and has evolved over centuries. We know what worked in the past!\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is not a luxury but a necessity to give us hope for the future.\n\n\nMake sure that any new development talks to environmental bodies.\n\n\nIf it does not, then any new development will fail because the balance is not there.!"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nOn a personal level I love being out in nature, it's good for my health. On a large scale if we don't look after our natural world we will destroy everything that we depend on to live.\n\n\nStop using weedkiller in our towns.\n\nDon't allow development on land which is already rich in wildlife.\n\nThere is little point in planting trees and creating habitat if we are still ripping out long established ones.\n\nCreate connected landscapes for wildlife, it can't survive in isolated pockets.\n\nSort out sustainable transport to reduce congestion and pollution.\n\n\n\nOur wildlife is in trouble. Every time new housing developments go ahead, wildlife habitats are ripped out. We need to work with what we have so that existing features are incorporated in developments. This is also important for people to have proper natural areas around where they live, not artificial green areas designed by the developers, which have little wildlife value.\n\nWe are also creating serious flooding problems and this needs to be a priority when building."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause it provides visual beauty and helps well being\n\n\nCouncils own lots of land that can be better used for nature and helpful trees and plants. They just need identifying .\n\n\nTake nature away and there will be no harmony"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nSpace for mental health and wellbeing\n\nEnsuring that our native species are not lost in generations to come.\n\n\nGreen corridors for wildlife linking up habitats\n\nNot voting for more housing development\n\non land where red listed birds are located.\n\n\nI would like to see an example of this?\n\nWhen the new Spitfire homes development in BC was planned i campaigned for hedgehog highways in the new builds. This has never hapened although the developers assured everyone it would.\n\nDevelopers need to stop developing new builds on green belt land"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nfor the health and wellbeing of everybody in the community\n\n\nUtlilise Natural Solutions for Flood Management, prioritise good quality diverse outdoor space for all communities\n\n\nTo ensure high living standards for people and wildlife in the area"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWithout the natural environment we wouldn't be here. It benefits the community in so many ways, from health to vital resources.\n\n\nDon't cut us off from nature. We are part of nature and solutions can be found through utilising and preserving the natural world. It's a partnership. Nature provides.\n\n\nBecause without nature we wouldn't be here. I want to live in a community that prioritises a circular economy, a world where waste is minimised and connections, wellbeing and sustainability are prioritised. Our natural resources are not infinite.\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nGreen space and wildlife is what keeps me and my family healthy and happy. It is the most important thing in my daily life.\n\n\nRecord/catalogue all trees and hedgerows to ensure they are protected from unnecessary felling and removal in conjunction with new planting. Try and engage with all farmers and landowners to provide areas that are left wild for nature.\n\n\nWe are still losing species at an alarming rate. This needs not just to be stopped but to be reversed. Nature needs to be top of the agenda for every project."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nOur natural environment is important for our ecosystem, our wellbeing and our children's futures\n\n\nI am lucky where I live is rural and has plenty of walks however they are often over grown and not maintained which can deter people from using them\n\n\nLiving on the outskirts of Ledbury it is frightening the rate of new houses that are being built even outside of the town boundary now, which we cannot see how this works in harmony with nature"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature is all connected and we are part of it. We have to live in harmony with it and interact with nature to remain healthy with clean air,sustainable farming and food. We need to care for or create more natural areas in cities and involve the community for their care. People who are involved take more pride and interest in their environment.\n\n\nCity parks and open spaces in cities with community involvement. Less building on unspoilt natural areas. Brownfield development. Insulate homes. Less cars.\n\n\nIf nature is destroyed our health and well-being suffers too."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nPhysical and mental health is enhanced by nature. The environment needs preservation. Nature should be free to everyone to enjoy and easy to access.\n\n\nEliminate weedkiller being used. This is detrimental to every creature.\n\n\nBecause we are encroaching on nature habitats more and distroying the environment. Preservation of nature helps prevent flooding, improves air quality, helps with slow down global warming etc..."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nMany living things are in decline and being impacted by climate change. Alarmingly the number of pollinators in peril has increased. Without these many plants including food products will fail.\n\nMuch of our soil has been degraded by intensive farming and pesticides.\n\n\nReduce pesticide use in farming.\n\nKeeping natural hedgerows and plant many more native trees.\n\n\nDevelopment often means destruction of wildlife habitats, attention must be focused on using native plants and keeping hedgerows which act as wildlife corridors and habitats"]
["\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature is vital for human wellbeing & it's appreciation is vital for the world itself\n\n\nProtection of natural surroundings enhance both housing & workspaces\n\n\nProtection of nature should be of paramount importance in developments, for the wellbeing of the people who will live or work there"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIts not important, its essential.\n\n\nJust leave space for nature, its not rocket science.\n\n\nPersonally I think that's 'Plan B.' Human development is always a compromise, we actually have to value primary natural habitat."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt should be imortant to everybody, with more and more building on fields and floodplains green spaces are disappearing quickly.\n\n\nWhile i understand the need for more housing, developers should be made to prioritize nature more in their plans. Solve the issues such as flooding at the site rather than pass the problems down river.\n\n\nNature isn't there as an afterthought. We NEED nature to exist and to help our health and wellbeing. No nature, no future. We should be considering our environment 2 or 3 generations in the future, Change takes time."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt’s proven that humans are happier when they’re close to nature & particularly trees. The happier people are, the healthier they are, the better they interact with one another; productivity increases, antisocial behaviour reduces. Society & communities function better. Everyone benefits even our wildlife.\n\n\nAlways consider the impact of how any developments impact wildlife. Get accurate baseline data and always implement a mandatory biodiversity scheme so existing wildlife can recover quickly and potentially improve over time.\n\n\nHumans cannot live happily without nature around them. The UK has depleted almost all of it’s wild areas. Any new developments must be part of a wildlife corridor to viable habitats. We’ve destroyed so much nature in the last 50+ years. We have to do everything possible to support & encourage it from now on. Our new generations deserve it."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nFor clean air and healthy living.\n\n\nMore flower meadow areas on roundabouts and small grass areas.\n\n\nTo keep wildlife alive and plentiful."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt’s vital to realise that humans are a part of the wider ecosystem and need to be in balance with nature\n\nWe cannot exist in an unnatural environment without inspiration from the natural world\n\nThere should always be planning in place to ensure we don’t lose any more of our already severely depleted numbers of wild species\n\nIt is vital to enhance natural habitats and is even more important in these times of decreasing mental well-being to allow spaces for nature\n\n\n\nPlan connected and varied natural spaces to help and encourage biodiversity\n\n\nIt is one and the same, we are all part of the same ecosystem\n\nYou need to integrate andconnect natural spaces, it’s not sufficient to just provide a field for people to walk their dogs, this doesn’t encourage nature as most wildlife disappear s, dogs are predators\n\nThere’s been a massive decline in numbers of birds especially and we are rapidly approaching a concrete desert\n\nWe should have a fantastic mosiac of wildlife habitats with the canal and Severn plus traditional orchards\n\nAll of this stuff s being neglected to make “developers “ massive profits\n\nIt’s well recognised the physical and mental benefits of being surrounded by nature and there needs to be far more involvement in planning by the likes of GWT and WWT both local organisations to encourage and enhance the whole environment county wide before it’s too late"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nTo protect the habitats of indigenous wildlife within the Gloucestershire area.\n\n\nPlanting of trees and creating habitats to encourage wildlife to thrive.\n\n\nSo many of our older trees are removed for development and replanting is not conducive to sustaining wildlife."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI say this because it is essential for mental and emotional health.\n\n\nLocal authorities need to Insist that some green elements (trees, open spaces, water features) are integral to every planning application, because a totally built environment quickly becomes sad, harsh and hollow."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural world around us is so important for sustainable life. We live in a circle, but there is a large kink in the circle and the balance is not right.\n\nHaving animals and nature around us is good for everyone's mental health and promotes children to be inspired.\n\n\nProtection of our green Spaces.\n\nGetting children and adults engaged in farming, protecting our wildlife and stop building on flood planes.\n\n\nThe balance has been tipped in the wrong direction. Building house has overwhelmed the natural world. This balance needs to be restored and areas protected."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNatural environment is important for mental health wellbeing and exercise. Heathly happy community. Living alongside thriving wildlife and nature.\n\n\nTruly sustainable development that increases bodiversity and reduces impact on climate changes. More woodland, wetlands. Solar panels and car charging in new builds. Joined up thinking between planned new developments. Wildlife corridors. With new planting, a plan to water new trees and help establish new biodiversity. Not just tick box and leave. Too many poorly thought through developments for profit only.\n\n\nWithout nature. All the associated resulting problems with a degraded environment and people's physical and mental health will cost local governments more time and money than if investment in nature is at the heart of all decisions from the beginning."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe philosophic dualism of man and nature is being challenged. We are part of nature and we need to care and enhance it to our mutual benefit.\n\n\nMaintain public footpaths, to improve public access to the countryside. Lower carbon dioxide emissions across all council activities, including council vehicles\n\n\nHealth, both physical and mental have been shown to benefit from living with or having close, easy access to, nature.\n\nNatural lives have value for their own sake too"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is something I have always treasured since a young age.  Without nature what is life\n\n\ncouncils should include essentials for wildlife when building.  It breaks my heart when a mature hedge has been standing for years providing shelter and it then ripped out of night.  Wildlife has a right for habitat.\n\n\nWithout nature what is the point.  I do not want to live in a concrete junge, GB is know for its landscape let us not destroy it.  Maybe control the amount of people coming in the Country so we don't have to lose our lungs"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThere is no planet B, time is running out\n\n\nStop building on flood plains.\n\nTeach children in schools about growing food and foraging, being resourceful and responsible.\n\nOur world is more important than test scores\n\n\nThe world is burning.\n\nThere will be no drinking water in 25 years.\n\nOur food and environment is toxic.\n\nHow is this progress?\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt's good for mental and physical health.\n\n\nBan the use of pesticides across all councils. Encourage wild planting for pollinators.\n\n\nBecause nature is in crisis."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nFor wildlife, fauna and flora to flourish. To make the world a more beautiful place and to save many species.\n\n\nMore wild flower patches on roundabouts or in parks where there is just empty space.\n\n\nTo build green coridoors when developing so wildlife is taken into account."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural world is everything! The air we breath, the water we use, the food we eat and the species we share the planet with.\n\n\n20% BNG on developments and not the totally inadequate 10%. Stop using pesticides.Stop using peat.Stop cutting communal grass areas so frequently. Plant trees and hedgerow plants. Plant wildflowers. Encourage voluntary groups.Coordinate your actions with other councils and NGOs and other land owners.\n\n\nWe need nature to thrive everywhere and not just in small pockets. We're in a climate and nature emergency and development needs to be a major part of the solution"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe want to aid local biodiversity & to help combat climate change\n\n\nSupport reduction in the use of pesticides & Help farmers with nature supporting set aside\n\n\nhealthy fauna & flora are key to the future & development should always positively reflect this"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is a vital and irreplaceable resource for health and wellbeing for everyone. It supports physical and mental health, fosters resilience in children, nurtures communities and social cohesions, gives people a sense of belonging. The natural environment brings a sense of wellbeing that comes from appreciating  and feeling part of the world around you.\n\n\n\nBe different and make the flourishing of our local wildlife and green spaces a prerequisite to developments. These should happen within a map of wildlife areas and corridors and access to green spaces that will support residents' physical and mental health.\n\n\n\nFor the survival of nature we need wildlife corridors. For wellbeing and quality of life we need access to nature for all incomes - that means where we live, without needing transport."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause we can't live without it and it is important for all our senses\n\n\nRestrict access to areas so that nature isn't disturbed by humans other than natural maintenance practices. Better revenue funding to maintain areas for nature. Create more path networks so that people can explore nature without trampling on it.\n\n\nSo that it reduces the lose of nature and doesn't push nature into a corner where it can't thrive. So that animals aren't displaced and habitat mosaics are connected\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe availability of wild spaces for our threatened wildlife needs long term planning and commitment by all who are tasked with managing our environment. Green spaces and clean waterways help to maintain good mental health and encourages social well being, sense of belonging and pride. The positive effect for our wildlife is the difference between existence and extinction.\n\n\nIncreased work with schools to create woodlands and forest schools to establish an early connection with young people and nature.\n\nThe formation of more voluntary or expert led groups for unemployed/ disabled/ socially prescribed adults to work on gardens, parks and rough spaces to litter pick, wildflower planting, reestablishing hedgerows etc.\n\n\nCrucial to integrate shade providing trees near dwellings as summers get hotter- providing green corridors in small and large scale to enable animals to move at will. Maintain clean water and clean air"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt's vital for our physical and mental health, our food production and the future of all human and non-human beings\n\n\nStop building so many houses on green land, and make use of the buildings that are already here, put limits on ownership of more than one house unless it's for permanent living rental.\n\n\nIf we don't we will end up with so little left that it won't be able to support the wildlife needed for our survival"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nEssential\n\n\nRiver debris clearance days\n"]
["I support Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nDevelopers need to create passageways underneath / through fences to allow wildlife to cut through gardens and stay off roads, for just one idea.\n\n\nThe natural environment supports the ecosystem that provides all humans, animals and plants with food and water. It is imperative that we protect it and not decimate nature with building spread out houses and housing estates.\n\n\nBuilding homes in the town and leaving the surrounding fields and collections of trees alone will mitigate the destruction of our green spaces and Green Belt - not that developers seem to pay any attention to this. Animals need a home too and many animals do not cope with urban spread.\n\nWe don’t have any forests except around the Forest of Dean. This is not enough. We should re-wild as many areas as possible.\n\n\nIf we don’t support nature it won’t be able to support us with oxygen, food and water. Please act responsibly now."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe moved to Winchcombe to be close to nature, green fields and woodland.\n\n\nCut back on construction and concrete and tarmac, which prevent proper drainage and mean more flooding.\n\n\nMy personal view: nature in its widest sense is much more important than building, building and more building."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nFor well- being and ultimately human survival since we depend on a functioning eco-system. Also, we have no right to destroy nature.\n\n\nDeclare nature emergency  Protect and re- wild land. Re-purpose land where possible. Support organic farming of crops and discourage consumption of animal products. Ensure all council owned land is managed organically for the benefit of nature and wildlife. Improve public transport.\n\n\nBecause without a functioning eco system the human population will not survive. Plus, we have no right to destroy nature."]
["\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan.\n\n\nIt is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nTo me this is all about balance - ensuring the human animal does not dominate and disregard all other animals and wildlife.\n\n\nKeep green what is green. Keep wooded what is wooded. Use brownfield land for new housing and developments.\n\n\nHumans depend on nature to survive. The exploitation of nature can only go on so long before we pay the ultimate price for our negligence."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is so essential for the health and wellbeing of everyone. It brings people together from all walks of life. The future of people and planet depends on protecting it\n\n\nThink sustainable and green when it comes to future developments. Integrate nature wherever possible. Put nature protection and support above profits.  A local campaign to all community as a way of connecting people to nature and environment.\n\n\nIt's the only way to have a resilient and progressive future."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature and Wildlife is important for our survival.\n\n\nKeep looking after trees, green spaces and wild areas.\n\n\nImportant for wellbeing."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nFor mental and physical well-being and a sense that the health of our environment and planet is being looked after for the next generation.\n\n\nAll new domestic and commercial development should be self sustaining and have due regard for impact on the natural world. Solar catchment should be compulsory. Development should be nature friendly. Access roads and pavements should be lattice based to allow rainwater to pass into the ground. All properties should be equipped with rainwater butts.\n\n\nBecause if it does not we will become a concrete jungle."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment is our natural environment! It is necessary for our health and mental well-being.\n\n\nWhere development is absolutely necessary, it should be done in such a way that existing wildlife and environments are protected. Destroying established natural environments then planting a few new trees elsewhere is not sufficient.\n\n\nQuite apart from the benefits to humans of an unspoiled natural environment, animals have the same desire to live, and the right to do so, as humans. They require a natural environment, and it is our responsibility to ensure that these are protected."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nTo conserve our urban spaces as refuges for wildlife, giving beauty and peace to the community, whilst giving refuges to all the wildlife which is threatened and declining across the County\n\n\nConserve existing green spaces and ensure that green spaces, suitable for wildlife, are included in all new developments, preferably on brown field sites. Ban pesticides in all council owned green space and encourage voluntary ban in private green spaces.\n\n\nOur wildlife has suffered disastrous decline - witness last year's major fall in numbers of bees, butterflies, garden birds and many others.  Humans need wildlife to bring pleasure and relaxation in nature"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nthe natural environment provides the life support systems for us all.\n\n\nnature and wildlife welfare must come first, there is so little left.\n\n\nwhat is the point to work in any other way?"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nHelps mental health brings people together\n\n\nSustainable projects that encourage nature not harm it will save money in long run\n\n\nEveryone needs nature for well being"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI have a lung condition and clean air and time spent in nature are essential for me. My entire life in concerned with studying and recording wildlife in the Cheltenham area. Our U3A nature group provides an essential opportunity for like minded people to learn about and share their interest in nature.\n\n\nPrioritise brown land for building and stop all changing of farm land into car parks or building land. Minimise drastic hedge trimming and protect wildlife corridors which are essential for healthy species populations.\n\n\nIt is essential for development to design and build in existing and future wildlife. Domestic gardens, when not concreted over for parking, provide wildlife with water, food and shelter. Where houses have to be built it can be done while still leaving existing ponds, hedges and specimen trees to benefit the residents but also the wildlife. Wildlife corridors must be protected and extended to ensure the health of wildlife populations. It can be done in harmony (see the \"Birds\" estate in Bourton on the Water)."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nTo preserve our natural heritage.\n\n\nProtect green spaces that already exist and encourage people not to disturb them.\n\n\nBecause both need to be present."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe environment is what sustains us and helps mindfulness\n\n\nSolar panels on all commercial and fac\n\ntory buildings\n\n\nThere is only one planet and we need to look after it."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is a space where people, including children, can breathe clean air and observe nature.\n\n\nPeople are more likely to care for places they know about and co-operation with public transport providers could help promote access to them without the need to drive there.\n\n\nIf we don't, we'll lose more fauna and flora for future generations and it's good for people's mental health."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt's where I live!!\n\n\nEnsure environmental impacts are always minimised\n\n\nBecause we only have one planet!\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nGreater connectivity to nature has been proven to improve wellbeing. Our community values nature from individuals to groups. Nature preservation and harmony with development is crucial as government addresses housing need\n\n\nEnhance planning regulations to ensure developers can’t overlook or make tokenistic steps towards nature. Commitment to wildlife corridors. They bridge the gap between habitats which otherwise would be small and isolated and join them together. Linking core wildlife habitats helps to restore and preserve biodiversity, allowing movement between important habitats to maintain genetic diversity in wildlife populations.\n\n\nDevelopment working in harmony with nature is not insurmountable it is critical because development disturbs ecosystems. Diversification for nature ensures it is healthy. Biodiversity with native plants keep ecosystems healthy."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause humans are part of nature and cant live without it\n\n\nInvolve young people in creating solutions to environmental problems\n\n\nBecause humans are part of nature and cant live without it"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt helps our mental health, provides places for our physical well being and provides a sustainable infrastructure.\n\n\nSupport tree planting, protect sssi’s,\n\n\nTo provide a sustainable future"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature barely has any space left. It is confined to limited hedgerows by main roads where many Animals and Birds emerge and die due to cars. Green spaces are being built on, trees are being cut down and can thus no longer absorb water so flooding is occurring. It's saddening and I'm glad I didn't have kids because the World is getting a lot worse. This is just the tip of the iceberg.\n\n\nProtect green spaces. Rewild derelict spaces. Create more nature reserves and Parks, some of which don't allow dogs so that they're safe for children to play in and aren't full of dog faeces. Protect Wildlife and stipulate bigger penalties for Wildlife crimes.\n\n\nIf we don't there will be more flooding, more pollution, loss of species and all we'll be left with is back to back buildings to house humans, pets (affection slaves for humans) and livestock; many of which are kept in appalling conditions."]
["\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is important for people’s mental and physical wellbeing to have easy access to nature.\n\n\nOne proposal I would make is to expand Robinswood Hill Country Park in Gloucester to include all the hill i.e move the golf course.\n\n\nIf we carry on destroying our natural environment and replacing nature with concrete and bricks, we are removing an invaluable resource for future generations."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment is fundamental to survival of the planet\n\n\nEnsure that you connect natural areas in your planning - connectivity is key to species survival.\n\n\nThe natural world is in crisis"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nFor health, relaxation, an appreciation of our beautiful world\n\n\nConsider the impact on open spaces and nature's plants and creatures when considering planning\n\n\nTewkesbury is susceptible to flooding  and it's vital to work with nature to help its people and the world around us"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nEveryone feels better if they connect with nature. It brings communities together and improves well being. It is essential for survival of the planet.\n\n\nNature encouraged in town centres to bring people together. Only approving building projects that protect & encourage nature not destroy it.\n\n\nWe all need nature to be happy people don't want projects that destroy nature & in the long run we all need nature so the nature friendly projects are the only ones that will be truly successful\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt's essential for our community, to prevent further and worsening flooding.\n\n\nEnsuring new buildings are built sustainably, with solar panels or wind turbines. Have rain gardens or roof gardens providing areas for wildlife to travel through.\n\nEncourage more use of local transport, park and rides, better more reliable links.\n\n\nWithout nature, there is no real harmony. But  working  with it everything and everyone will benefit."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWithout nature there are no humans. Nature also provides that space for quiet reflection as well as vast enjoyment.\n\n\nLimit building to brownfield sites\n\n\nOtherwise there will soon be no nature left in the county!"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is vital to keep indigenous flora and fauna , urban gardens do not support wild life\n\n\nstop building on green field land\n\n\nglobally we lose huge numbers of species every year , eventually we will have monoculture and no diversity"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt reflects the health of our environment\n\n\ninvolve local communities at all levels\n\n\nWe are all part of the whole environment"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nFor our wellbeing, breathing fresh air, exercise, and the our future health and our planets sustainability.\n\n\nSpare spaces for insects, nature, verges rewilded, more trees etc new houses without gas, and have to have eco credentials, allotments, and planted up.\n\n\nTo not change the environment negatively but increase our airquality, encourage nature for wellbeing."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt’s important for mental & physical wellbeing & for protecting biodiversity & links to the climate emergency\n\n\nIncreasing biodiversity and natural environment when approving planning developments. Ensuring green space is not destroyed for development when there are brownfield sites or derelict structures that could be developed instead\n\n\nTo help reduce carbon emissions/offset carbon. To protect species and improve habitats\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is essential for good mental health and well-being. Everyone should have access to green spaces and our native wildlife should always be prioritised.\n\n\nStop the use of pesticides which kill our bees has to be the most important thing. Without bees WE ALL DIE.\n\n\nYou prioritise developers over nature, so many houses and it's all about squeezing in as many as possible at the expense of natural spaces. The council should insist that developers provide nature reserves and green spaces.\n\n\nYou are supposed to represent your constituents, but you just represent your own selfish interests, things need to change. It needs to change right now."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe are building, building,building on land that wildlife depend on, people don't like wildlife living in cities, foxes in particular yet where can they go? We have stolen their habitat.\n\nWe don't see wild flowers anymore, they used to be everywhere.  There are no insects/nectar for birds to feed on so we don't see all the birds, bees and butterflies anymore. Humans have a lot to answer for. Shame on us\n\n\nPROTECT WILDLIFE. STOP STEALING THEIR LAND, RESTORE BUILDINGS INSTEAD OF BUILDING NEW. WILDLIFE BELONG IN THE WILD THEY ARE NOT SAFE NEAR HUMANS\n\n\nI don't  think development and nature work. There are too many humans hellbent on abusing wildlife. So keep them apart and stop all the greed. Where are our greenbelt these days? Don't they exist anymore????"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature is relaxing\n\n\nTo have members who respect nature on committees"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment is part of our community, it isn’t a second priority. We need to look after it carefully.\n\n\nThe council’s need to map what is important habitat areas and species. Every development needs to consider and demonstrate how they will improve that habitat map, and it’s interconnecting links with other habitats, not simply offset it elsewhere. This is above and beyond what BNG requires.\n\n\nThis is imperative as space and time is running out. The ability to be business as usual is not an option. Developers need to understand that the community and potential buyers place value on nature. It’s important!\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt provides a balance and calm when stressed\n\n\nEncourage all schools to do regular litter picking events and ban all single use plastics whilst partnering with local supermarkets to raise awareness and provide more plastic free options to consumers\n\n\nAny development that doesn’t work a"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nFor 10 years I have volunteered at my local Junior School Garden Club. I have seen first hand the impact that being outside in a green space has on children, especially those with special needs.\n\n\nAs a carer reconnecting with nature has a restorative effect on me and the person I care for. I love walking but even being able to simply watch birds and squirrels in my garden gives such a boost to my mood.\n\n\nStop developers from grubbing out hedgerows. Insist developers install solar panels or heat pumps on all new builds.\n\n\nAll new developments whether residential, retail or industrial must include green spaces with natural or man-made environments for wildlife i.e. hedgerows, bird and bat boxes, hedgehog houses.\n\n\nIf we don't look after nature we are NOT looking after ourselves or our planet."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt's obvious.\n\n\nA sensible policy of green belt preservation."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nMy grandchildren deserve better\n\nIn my lifetime we have become the most nature depleted in Europe\n\nThis is a disgrace\n\n\nBuilders want to maximise profits\n\nHigh density tiny gardens and little land for wildlife\n\nThe infra structure doesn’t keep up hence water quality and the state of our rivers\n\n\nIf it doesn’t we will never restore the quality of wild life  no new sewers for new estates justvoump more into the outdated infrastructure"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature provides me with space to be away from screens and at one with nature. I really value being able to access green space and spend time in areas rich in wildlife with the sun (or rain) on my face and wind in my hair. Its so important that everyone can enjoy being outside and benefit from the massive health and wellbeing benefits that nature brings.\n\n\nMore sustainable alternative natural green spaces is required so that everyone has access to nature and space to be outside. This needs to be integral to all development. We can't just rely on sending people to nature reserves or exisitng green spaces, these are already struggling to provide enough space for people and this is damaging really valuable habitats for people and nature.\n\n\nThe SLP needs to ensure developments think about how people can get to and from work, shops, schools, doctors etc. If you need to have a car to live there then there's something wrong with the siting of the development.\n\n\nStop building in the floodplain, the existing flood defences are already under strain and you are simply letting developers push costs for maintaining these defences onto the public purse.\n\n\nSet clear targets for natures recovery in the county.\n\n\nWe are already one of the most nature depleted countries in the world. Whilst we need to build more homes, including for tenants, we shouldn't allow these developments to further deplete nature or cut off vital corridors for wildlife (or be placed in those areas identified as most important in the nature recovery network).\n\n\nThe SLP also needs to consider the impacts of housing and development on water courses and flooding more generally - no houses should be being built where surface water drains into sewage network. SuDS and blue-green infrastructure (and funding for their maintenance into the future) should be a requirement of any development to prevent further pressure being added to sewage networks with resultant impacts on rivers and water quality.\n\n\nDevelopments need to include urban trees and native planting to cool air and provide corridors for nature and make these areas people actually want to live and that can support wildlife."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nA healthy natural environment is known to improve both mental and physical as well creating a balance which is essential for the future of our country.\n\n\nAvoid known reserves i. e. Unlike the permission given for Coombe Hill. Leaving natural areas among housing conurbations.\n\n\nWe need our wildlife  - such as insects to pollinate crops."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe need to be more aware of the local environment.\n\n\nListen to local community groups with the lived experience."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nAccess to nature is essential for the health & happiness of all life\n\n\nEnsure robust protection of sensitive areas & aim to expand these areas if possible\n\n\nIt is vital that nature is protected for it's own sake & for the wildlife it supports - we cannot just keep exploiting & decimating the natural world as this poses a very real threat to life itself"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature feeds the soul and helps mental and physical well being.\n\n\nI would like to see more trees planted\n\n\nWe need to learn how to balance our human needs with those in nature so we can live happily side by side"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is the difference between LIFE and DEATH\n\n\nClimate Emergency demands radical and responsible actions. Less CO2, wind farms on the Cotswolds, local natural areas for all communities, and regenerative farming practices in our areas.\n\n\nLIFE is dying before our eyes, we are not the only living thing on this planet that matters."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nA healthy environment is essential to human and other life, it is not optional. Degraded air, water and other physical components endanger all of us.\n\n\nI support the GWT objectives. In particular, far more should be done to protect mature trees, so often mutilated or cut down without any environmental consideration.\n\n\nRestoration will not work otherwise. It's quite obvious."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI am a landscape painter so I spend a lot of time out in nature throughout the seasons. In urban areas wild places where natural habitats are supported provide not just a space for our native flora and fauna to thrive but also an invaluable resource for humans. Studies have proved the impact that connecting regularly with Nature has on mental and physical health .. we need more preventative measures  for health given the situation the NHS finds itself in\n\n\nWork with charities such as Stroud Valleys Project to improve the wild spaces. I know this is already happening with the Wilder Frome project in Stroud but we need more cross agency collaboration to ensure our wild spaces are protected\n\n\nSee my comments above about preventative health initiatives which can be aided by volunteering programmes for those suffering from mental health issues.. any new building development should work in harmony with Nature to ensure increased biodiversity and to protect what we already have."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nTo protect nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt’s vital for life, not only other creatures, but for ourselves too. No insects means no humans and yet pesticides are still freely available, I’m seeing a widespread sterilisation of nature in our community and it’s devastating\n\n\nPlant wildflowers that can be strimmed in the autumn, rather that constantly mowing. Leave areas of Thistles and nettles so that butterflies and moths have breeding grounds, plant more trees. Bring in legislation that ensures builders plant (and maintain) more trees than they destroy. Make sure new builds have hedgerows instead of fences. Make sure ecology is not only taught to children in schools, but the schools and council owned buildings are sustainable and environmentally aware. Put a value on rubbish. If people were paid for their recycling, littering would stop. Make sure plastic recycling is done in the UK, not sent abroad.\n\n\nGardens have more potential for wildlife than agricultural land does, but that relies on people being educated on the importance of nature. A huge issue in my area is people’s war on leather jackets, as all they see is the desire for  a perfect green lawn. They hire companies to come and put pesticides on the lawn to kill them. Our area is also a nesting ground for swifts and starlings that rely on these insects. Which, if encouraged, keep the lawns perfect. But instead their food source is being destroyed. It’s an insect apocalypse, which will eventually lead to our own."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is so good to have areas of natural diversity and beauty to enjoy both to visit and to preserve the outlook from places like Robinswood Hill and the Cotswold escarpment.\n\n\nTo preserve those ancient woodlands that remain.\n\nTo preserve green corridors between important wildlife habitats, for example Robinswood Hill and the Cotswold escarpment.\n\nTo preserve the green fields at Whaddon and Brookthorpe rather than allowing the land to be used for yet more high density housing development. Create a woodland and preserve the land for agriculture and nature.\n\n\nIt will not only benefit many species and help prevent their decline. It will also be good for the mental health, general health and well being of the people who do live in the area.\n\nSo many new housing developments these days look the same and this urban sprawl is obliterating the green belt, greatly increasing the human population which is in itself putting an ever increasing strain on the environment for nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause it’s important for local wellbeing while contributing to the bigger picture of saving the planet for future generations\n\n\nGreen spaces should be part of every development to recognise the value for mental health for everyone, but there also needs to be funding for the maintenance and development of those spaces\n\n\nHealth and wellbeing have not traditionally been part of building development discussions and yet it is widely recognised that natural  environments provide a therapeutic balance to our lives"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment is essential to all of us and to the resilience of these councils. The biodiversity and climate crises are going to have significant impacts on the councils and how they run. If they can only see it in financial terms, if they don’t act now to future-proof themselves they will be spending more money they don’t have on flood issues, drought, human well-being issues. To not act shows short-sightedness\n\n\nApply Building with Nature standards to all new developments. Look to redevelop derelict areas rather than take up new land\n\n\nWe cannot build back better if we don’t address biodiversity issues. More houses require more water and this cannot be taken from abstraction any more. More homes, means more sewage into our watercourses. More homes means more energy usage. We cannot continue to build without ensuring we are building with and not against nature"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe need open spaces, colour, fresh air, good places to walk in, to see and hear nature. In this time of mental health crisis, more young people than ever being diagnosed with special needs, obesity in all ages and general despair, free, natural, open spaces are needed for self help and for nature to thrive.\n\n\nFor the green spaces that are already there, pay more attention to the wildlife that is there, expand on it, work with wildlife and ornithological trusts. Put up bat boxes, owl boxes and develop pond areas. Dredge Saintbridge pond! A once thriving wildlife habitat is changing its format and not for the good. For inner city green spaces, make them greener! Develop the under used parks by having wildflower areas. Contact bee keepers, allow them to have hives within the parks (Germany do this) and on rooftops. Encourage rooftop gardens. Help and encourage the City Farm. Support local nature activists to turn unused brownfield/derelict sites into green public areas, even if only temporarily. Ensure that all schools, colleges and universities have a nature area on their premises. Recruit after school/work nature armies. Ensure that all new or expanding housing developments have green/wild/wet spaces as part of the planning application. When considering housing development applications, suggest brownfield site use first.\n\n\nIt is important because so much green belt and countryside is being ripped up, rather than using brownfield sites. Aged hedges and trees are being lost. Replanting cannot take the place of mature flora. Plant more by all means but leave what is already there. Consider badger runs, fox runs, owls, bats etc. Cater for them instead of creating habitat and feeding deserts so that they leave. Eco systems shouldn't suffer because of 'progress' whether it be building or roads. I dread to think how much wildlife has been disturbed by the felling of the Air Balloon trees as one instance. It is important because once nature is lost, it is far harder to bring it back, than to nurture and keep it."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBiodiversity net gain enforced on construction. Build Garden villages / towns 15 minutes to all community facilities blue & green spaces, allotments access, rewilding gardens & public spaces\n\n\n30% rewilding & restore habitats by 2030 enforced by regulators. Bees, bugs & butterflies restore hedgerows & natural flood defences.\n\n\nClear air, soil & water whilst accessing green & blue spaces."]
["\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment sustains human survival at a global level, both physically & psychologically, & we all have our own part to play at a local level.\n\n\nThe councils can still deliver their development targets, but they need to ensure that the developers make sufficient contribution too, which they can well afford.\n\n\nThe natural environment is a finite resource & the development industry (& government) must acknowledge this, especially in profit expectations. High quality biodiversity enhancement & green space add financial value to new development"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is vital for our health and well being\n\n\nPut sustainability at the heart of financial and planning decisions\n\n\nWe can not survive without nature"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nMan depends on nature. By harming nature man is harming himself.\n\n\nExpose the corrupt government allowing open border access to newcomers.\n\n\nAccept that this is a small country and limit immigration. The need for new housing is largely driven by the increasing population.\n\nI live in Drybrook. 100 new houses were built on a greenfield site. Why wasn't the huge brownfield site in Cinderford used? The FODDC is corrupt. They do not comply with the law that states all planning determinations MUST go before the full council. I have witnessed where councillors wished to speak but were not allowed \"Because it is outside your constituency\"."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause we all need to live in a balanced environment that benefits both plants, animals and humans\n\n\nKeep our living spaces clear of litter for starters\n\n\nSo we can embrace nature rather than alienate it"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nFor health minds and bodies. I do not want to live in a concrete tomb\n\n\nRedevelop unused office accommodation for housing\n\nProtect rivers from pollution, by constant monitoring of water purity. Hold CEOs of water companies personally accountable with hefty fines\n\nDon’t cut down trees, plant them instead\n\n\nClimate change and the future of the planet"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWithout the nature is essential to me. Everywhere i go i notice nature. The birds, flowers, trees we all enjoy talking and looking, hearing the nature around us.\n\n\n\n\nCouncil's really need to do more. They need to enforce laws on litter and dog poop. The lack of baskets and flowers around gloucester is sad. The green spaces we have are shrinking with flats all the time. The litter around Gloucester is shocking.\n\n\nThe developments have a duty to make some space for nature we need nature to survive support our physical and mental health as the developments are everywhere there is lack of safe places for nature. No efforts are made to help."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nProtection of nature is very important as the planet is suffering from damage caused by humans and soon will be too late. Consequently this could be extremely disastrous\n\n\nWith city many trees have been lost to storms and vandalism and largely not replaced. Plant more trees , big ones too. The city has many beautiful trees and the numbers are steadily in decline when it could be increased. Our parks and play fields are places crying out for more wild areas and lots room for trees planted in places they can be let to grow\n\n\n\nPeople who know better than me can plan developments to be not detrimental to environment in many ways"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nVery important for health of all sorts\n\n\nRing fence some areas and some finance"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature plays a huge part in my wellbeing. As a young person, I had a horse and spent much of my childhood in the countryside. I had involvement from CAHMS from a very young age and the outdoors was a positive factor in my youth.\n\nAs a teenager, my mental health suffered and I left home. I was a teenage mother and lived in poverty. I had no access to nature at this time.\n\nFast forward to today and I live comfortably. I have access to nature and participate in outdoor activities for my wellbeing.\n\nMy point (badly explained) is as follows:\n\nNature helps with mental health issues and general wellbeing. I don’t feel - from my own experience - that those who are underprivileged/live in poverty have the same access to nature that those who are financially stable do. I feel that issues of financial instability and mental illness can often go hand in hand. So, surely it is important that nature is available to everyone.\n\n\nWe have so many vacant lots/buildings already, that I feel these should be developed before building on new sites that are currently green areas.\n\nI also believe that projects (like the Gloucester Urban Greening Project) should be extended to more of Gloucester’s parks and green spaces.\n\n\nWhilst I appreciate that development is important; if development does not work in harmony with nature, we will lose nature to development."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause it will soon be too late to save the planet.\n\n\nStop fooling yourselves & take measures to protect wildlife & nature from further destruction.\n\n\nBecause its our last chance. "]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt's a good stress release to have trees and plants.\n\n\nTrees planted on housing estates must be protected. They should only be removed by a Council approved arborist.\n\n\nWe need green corridors through estates to bring nature into towns"]
["I am commenting to support Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency for better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures all development is sustainable and works in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe are part of the natural environment- if it thrives so do we.\n\n\nEnsure all development is sustainable.\n\n\nOur lives depend on it."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe love accessing the green spaces near our home, we walk, we spend time outside, we track the wildlife near our home.\n\nWe also see the impact of heavy rainfall locally on developed areas.\n\n\nMore investment into protecting existing green space and ensuring green is a must in any new developments- natural area not synthetic looking man made. Let's work with what we have.\n\n\nNot only is green space in amongst living space beneficial to wellbeing. But not considering wildlife and green spaces within developments can have a devastating impact  on the future of the area and the planet."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nmental health, relaxation, oxygen, diversity of life, we are all connected too and need each other in ways we are only just beginning to comprehend, pollination of food, survival\n\n\nPlease don't build on it. Like the abundance of nature living on the pesticide free site behind Oakhurst rise needs to come out of local plan, possibly others like this I am unaware off too.\n\n\nsurvival as a species, adaptation to climate crisis."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt means everything to all of us, without a strong vibrant Natural Environment the future will be bleak , unhealthy and impoverished.\n\n\nPlant Deciduous Trees and create linked up wildlife corridors. Isolated Fauna will perish.\n\n\nBecause Natural Climate rules and will dictate the future quality of life on Earth one way or the other."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nTime in nature calms, improves mental health, lowers blood pressure. It's an essential for humanity.\n\n\nEnsure green field sites are protected\n\n\nNature is a basic need for mindfulness and mental health"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBesides benefitting us mentally and physically,damage to nature ultimate damages us - no habitat-no animals- no insects - no food\n\n\nWe need a sustainable plan to protect nature,including the climate, long term- thought and care at all stages of planning and building to protect habitats and all nature\n\n8\n\nWithout harmony with nature the future of humans,as well as all forms of life are at risk.We already have an EMERGENCY on our hands"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nFor good mental health.  For nature to survive -- and for us to survive too.\n\n\nMake parks safer places eg tougher on out of control dogs.  More wild patches and trees.  Develop pond in Sandford Park near Bath Road.\n\n\nTo ensure the future of wildlife and us.  To improve the health, mental and physical, of residents."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nHumans have no right to destroy / consume or replace everything in their path. Humans need nature to exist. Children deserve to inherit the best world possible.\n\n\nLead by example.\n\n\nStop destroying nature - protect it.\n\n\nProtect ancient woodlands and existing trees/hedgerows as a priority (even vs headline grabbing, grant winning planting of new trees).\n\n\nStop building on nature - repair & renovate existing property first.\n\n\nMake public transport safer, and more accessible.\n\n\nStop demonising animals who have been forced into sharing our urban environments.\n\n\nSupport farmers (ensure they're properly paid and incentivised) to produce locally grown organic plant based produce and eliminate reliance on beef and dairy.\n\n\nProperly penalise those who destroy or harm nature - be that through fly tipping & littering, destructive bike tracks through woods, or dumping of sewage into rivers and other forms of pollution.\n\n\nEducate adults on the importance of nature and encourage parents to pass that on to their families - stop perpetuating the notion that children can solve the decline in biodiversity and climate change alone.\n\n\n\nNo nature - no us.\n\n\nOur decline in mental health and wellbeing directly tracks with the decline in nature.\n\n\nOnce the tipping points are reached there may be no way back."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI value the countryside and all the wildlife that relies on natural untouched areas\n\n\nWildlife signage to warn motorists wild areas left alone,no strimming without checking area thoroughly etc\n\n\nNature has been around longer than destructive humananity"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI care passionately about protecting biodiversity and slowing or reversing the effects of climate change - and the natural environment are intrinsic to both of these.\n\n\nI propose that you should rewild areas of the Cotswolds AONB that are currently used for farming. Restore damaged or degraded landscapes. Promote the area as a protected natural reserve for eco-tourism and use this to create jobs and wealth in the region.\n\n\nAny development in the area should be directly linked to the improvement of the natural environment in the area."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nImportant for relieving stress, for beautifying the urban environment, for breathing fresh air, for respecting animal life, and for alleviating climate change as much as possible.\n\n\nThere are so many grassy areas in town and on the outskirts that could have trees planted on relatively cheaply in collaboration with certain organisations/charities, which would filter the air and reduce the carbon footprint. Just rewilding many grass verges would save the council mowing budgets and reap huge environmental benefits.\n\n\nNew developments will be round for a very long time: planned right, incorporating plenty of trees and green spaces, they can be beautiful and reduce local opposition considerably. Sadly, it seems something developers end up scrimping on, not allowing the space needed, or simply letting new trees die due to lack of watering and not replacing them. It would also be lovely to see new developments built with thought for how they might not end up adding yet more vehicles to our roads."]
["\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nA healthy and diverse ecosystem is essential for our food security and for our physical and mental welfare.\n\n\nResources to inform and assist landowners including households to aid in building and preserving natural habitats. For example encouraging brash piles and composting instead of bonfire burning would create habitats, provide compost and reduce pollution.\n\n\nWe will lose vital pollinators, natural pest control and healthy ecosystems if we do not work with nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment is so important for our mental health. We learnt this during lockdown when we all had to stay local. We learnt to appreciate our local natural spaces. These need preserving.\n\n\nPlant more trees, mow grass verges less, leave areas natural for nature to take over, provide more bins and empty them more often  to reduce litter. Stop building on flood plains.\n\n\nDevelopments harm nature. New developments should work alongside nature. We should live in harmony with nature not work against it. Children should have the opportunity to see wildlife. They wont protect what they cant see."]
["\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nA healthy and diverse natural environment is essential to our wellbeing both menta and physical.\n\n\nMore innovative thinking around new developments. Better use of \"brownfield\" sites.\n\n\nCurrent planning laws take no account of working with nature. The current process is designed to work against nature and the environment and is in no way sustainable and take sno account of the importance of nature and the environment to our physical and mental wellbeing."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe rely upon the natural world for the climate we live in. We cannot live without it\n\n\nNatural flood prevention through habitat restoration.\n\n\nPeople need nature as much as nature needs space and therefore it should be accessible to everyone, including those living on new developments"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature is important in its own right, as well as being important for towns like Tewkesbury which experience flooding. Without natural wetlands and floodplains, people would suffer alongside wildlife. We need to declare a nature emergency before it's too late.\n\n\nRequirements for developers to include and plan in significant space for wildlife. Also any plans to develop should consider and implement effective plans for dealing with water run off. The area for development should also be surveyed to determine how much water it absorbs, which could determine whether the land can be used, or how much mitigation work needs to happen to prevent flooding in other areas.\n\n\nPeople need places to live, and so does wildlife, and the two can coexist."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe are nature and we have taken it for granted for too long. We need nature for our health and happiness.\n\n\nPrioritise nature when granting planning permission, promote hedges rather than fences, prioritise connected habitats across the county.\n\n\nNature makes us all healthier and happier, connection to nature is proven to improve life outcomes for children."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nNature and green spaces provide essential wellbeing for people and space for nature. Without our natural environment, we're doomed. Declaring a nature emergency as part of this local plan is an essential step because it acknowledges that nature has a role to play and that it should be considered across all council policy and decision-making. You've already declared a climate emergency so this is the logical next step.\n\n\nNature-based solutions should be the priority over manmade ones when addressing issues such as flooding, food security, vibrancy of town and city centres etc. Organisations like GWT have answers and solutions, it just needs local authorities to work better in harmony with them to put some of these ideas into practice. Sustainable urban drainage solutions for example are really simple and effective in combatting flash flooding, but all too often councils are shy of doing this work because of on-going maintenance. This perspective has to change if we're ever going to put nature into recovery and mitigate against the worst impacts of climate change.\n\n\nDesignate and protect nature corridors (blue and green) through urban areas out into more rural areas, to give species a chance to move and thrive.\n\n\nWe all know we need more housing, but it can't be to the detriment of nature as this is such as short-sighted approach. Without nature we'll all eventually have nowhere to live, so just building a load of houses will eventually be pointless. Why not be bold and build on Gloucestershire Airport for example, and make it the first truly sustainable new garden town? Much of the surrounding land could be used for BNG in addition, so the benefits are multiple.\n\n\nHolding developers to account is essential- green infrastructure on developments needs to be the right intervention for the location. Again BNG could play a role here. Finally developments need proper infrastructure for active travel, especially developments that are at risk of being isolated islands otherwise where a car is the only option. better cycle infrastructure and better public transport infrastructure.\n\n\nSmall wins- swift boxes, permeable driveways, space for allotments on the edges of developments- all of these small things provide huge benefits to biodiversity, flood management and people's wellbeing."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is important to ensure the survival of native species and where possible promote their increase in numbers. There are very few natural areas left and these need to be protected and connected to other areas so increasing the chances for nature.\n\n\nCleaning rivers and checking river for those who pollute.\n\nEnsure access to the countryside is kept open to ensure that the local population can access nature and be involved in it's protection. Look after footpaths and rights of way. Encourage farmers to wild part of their land or to cut down on chemical use.\n\n\nIncreased population and associated infra-structure can have a massive impact on habitat and if left unchecked can do irreparable damage and create new problems. Problems such as where to build, increased waste water, increased run off, losing sensitive habitat are all areas which need thoughtful and considered planning"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt helps people's mental health as well as wildlife thrive. A high functioning natural environment is of great importance to a place.\n\n\nCreate more wild areas and areas for wildlife to thrive. Increase communities connectiveness to natural areas. Increase the amount of litter picking and fines for littering. Campaign for reduced littering and fly tipping. Make it easier for people to access green spaces, e.g. wide paths, good signage etc.\n\n\nWithout nature, the world will not be able to survive. It is of paramount importance that nature is put at the forefront of decisions about developments."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause it's fast disappearing with over development\n\n\nResist overly dense new housing development\n\n\nFor the happiness and appreciation of local communities in the area"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThere is a climate crisis that will affect every one of us and, in particular, our children. Climate and nature go hand in hand - declaring a climate emergency without also declaring, and acting upon, a nature emergency will not force the changes that are so desperately needed. It is vital that locally we play our part in not just protecting but also actively restoring our natural environment.\n\n\nCouncils must start to prioritise the natural environment when considering planning applications - the needs of nature/wildlife must come above economic benefit. Developers must be forced to bring genuine, long-lasting benefits to nature and the local environment - promising to plant some token trees which are then not cared for and immediately die cannot be allowed to continue; developers must be held to account by the Council for impactful and ongoing natural benefit.\n\n\nIf development and nature do not work in harmony, the resulting biodiversity loss risks ecological collapse"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe great outdoors is good for everyone, a healthy environment, even better.\n\n\nNot sure, perhaps the timing of hedge trimming and such like.\n\n\nSo that we do not eliminate nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt’s so important to protect open spaces and diverse habitats- important for health and well being for ourselves and the animal and plant kingdom otherwise we’ll continue to get sicker and have more mental health problems and we’ll annihilate our habitats for birds, plants, insects and animals\n\n\nKeep footpaths and green spaces properly maintained, plant trees with the help of the locals (develop ideas for making this appealing), keep buses running and give people incentives to use buses. Get GWT into schools to talk to young children and to lead walks.\n\n\nLife won’t be worth living if endless developments of little boxes with no green spaces or trees continue to dominate the plans for housing. Look to other countries on how to produce houses that are in harmony with nature. Stop greedy developers."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency.\n\n\nNo environment, no life.  Simple\n\n\nReseed roadsides with wild flowers. Public spaces to have planters, organic gardens. EVs where possible. Heat pumps ditto.\n\n\nUnless councils lead, people will foul their own nests. Set a good example, encourage all to follow, name and shame those who do not\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nRelaxing and peaceful\n\n\nBuild on brown field sites.\n\n\nTo save the little we have left."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe country side is incredibly important and should be protected. We spend a lot of time outside walking, biking and riding in the surrounding country side.\n\n\nProtected areas. Not building on ever available green space.\n\n\nHabitats should be protected when developing site"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nAccess to green spaces s essential for good mental health. Also they help in our fight against global warming.\n\n\nRestrict building to brownfield sites and reuse empty properties in towns. Charge high council tax on second homes.\n\n\nWe need to protect biodiversity in order to safeguard the creatures that pollinate our food plants."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe cannot live without a vibrant and healthy environment.\n\n\nSupport local groups in a tangible way, with time and resources.\n\n\nFor the future of our wonderful country."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nit has an intrinsic value  and provides the natural services that support us and all life. Being in nature is important for our mental health and wellbeing and that of our children\n\n\nneed to consider the impact of all their activities and the cost to the natural environment alongside other costs and impacts. Declaring climate and nature emergencies puts this firmly on the agenda.\n\n\nWe know we need bigger, better, more and more joined up spaces for wildlife and development needs to occur in locations that doesn't prevent this from happening.\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThis is a beautiful part of the country and for me it's important to preserve the landscape and wildlife for future generations.\n\n\nKeep our natural resources in mind as one of the important considerations when looking at proposed developments. We need housing but people want to live in accessible places not in middle of nowhere.\n\n\nSome development is essential but not at the expense of destroying habitat and greater flood risk."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIf we don't preserve nature for coming generations, the quality of life will rapidly deteriorate - both physical and mental health.\n\n\nAll building plans should be made with the preservation of nature in mind.\n\n\nI must repeat, if we don't preserve nature for coming generations, the quality of life will rapidly deteriorate - both physical and mental health."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt's part of our world and makes for a healthier lifestyle\n\n\nBetter understanding of what is needed\n\n\nBecause without nature it would be a poor world that we live in and for our future generations"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI believe that the natural environment is vital to ensure the mental and physical wellbeing of the residents of Gloucestershire.\n\n\nGloucester City and Cheltenham Borough Council should consider the effects of everything they do on the natural world.\n\n\nIf development does not work in harmony with nature, the result will be more of the terrifying flooding that we have seen over the past few years."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nour future\n\n\nstop building on green sites\n\n\nto protect nature"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause We are losing our green spaces every yr ,Even in podsmead half of our local green is going to be built on next yr\n\n\nTrees  to cool under , suck up water in winter   hedge rows\n\n\nyes put in green areas and trees"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nAll the science shows that nature is beneficial - even the presence or absence of a tree in a locality can have predict health and economic outcomes.\n\nWe have vibrant ecosystems and rare (uncommon) habitat combinations that are in close proximity to high human density - that needs to be recognised as exceptional and worthy of protection. Insects and invertebrates are particularly important for pollination and food production but get ignored by the planning system.\n\n\nGreen spaces that have existing proven biodiversity MUST be protected in planning policy; we cannot only protect the rare and unusual, we need to protect the whole ecosystem. Small but precious areas like water meadows and local green space need greater protection as local habitat of vital importance - especially those that are accessed by children for learning.\n\nPlanning for nature cannot be done by condition when the councils have insufficient enforcement effort to follow through.\n\nCouncils should restrict or remove the use of bulk pesticides and herbicides across the county unless there is no other way forward.\n\nMandatory invertebrate surveys in any moth rich or beetle rich environment.\n\n\nIt is a vital part of the NPPF but often ignored or sidelined in favour of more quantifiable outcomes. It is the future of our planet that is at stake and it starts here!."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City and Cheltenham Borough Councils to join Tewkesbury Borough Council by declaring a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment is important to all of us, we are living in an ever decreasing nature depleted world.  It's making people physically and mentally ill and is no fun for the animals and insects who have no habitat left in which to thrive either.\n\n\nCouncils can do lots to help, by: Using Building for Nature standards.  Planting the right trees in the right places and monitoring newly planted trees and hedgerows plus having strategies for keeping them alive.  Using swift bricks and hedgehog highways.  Banning astro turf and pesticides and having stricter controls on paving gardens. Making sure all new homes have solar, grey water provision, water butts etc and secure cycle storage.  Using natural flood management.\n\n\nDevelopment must work in harmony with nature; Developers are humans too and it's also their world.  Development that works in harmony with nature can enrich everyone and everything, if it is fought again, we will be the losers.  We must secure a decent future for our future generations."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause we are in the process of moving over to the digital age so we need to reestablish the balance\n\n\nNature bridges over busy highways\n\n\nBecause we don’t get a second chance and this is the tipping point"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe exist as part of nature but are increasingly subduing it. Building houses and clearing the land to do this is destroying nature; we live increasingly artificial lives, and our priorities need to change.\n\n\nGive nature a chance and don't keep building!\n\n\nWe are from nature and should not consider ourselves separate."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt’s important for mental and physical wellbeing\n\n\nKeep flood plains and wild areas. Be aware of the habitats and preserve them.\n\n\nNatural spaces are dwindling and we need nature for the sake of mankind."]
["As a member I am commenting in support of Gloucestershire Wildlife Trust's call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nPlease take into account the following:\n\n\nThere are proven health benefits from being outside and in natural environments, in themselves enjoyable and  inspiring.\n\n\nI suggest as a minimum the following should be implemented:\n\nMaintain wildlife corridors.\n\nDo not build on greenfield/farm sites.\n\nEnsure that new builds encourage wildlife, eg including swift boxes/bricks in buildings, providing wildlife friendly areas.\n\nEncourage farmers to set aside areas for wildlife, eg field margins.\n\nEnsure that existing wildlife friendly areas are maintained.\n\nEnsure that all plant and fungi ecosystems are maintained.\n\nMinimise pollution from all sources thereof.\n\n\nAll nature is inextricably linked, including people who have been shown to be remarkably destructive and while admitting there is a nature crisis do nothing to mitigate the consequences of their actions.\n\nIf development does not work in harmony with nature entire ecosystems are destroyed to the detriment of all people, wildlife, plantlife and fungi."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt's the bottom line. Mankind depends on nature not the other way round.\n\n\nObey the law which directs that all planning determinations must be decided by the full council At present a small cabal makes decisions which encourages corruption as demonstrated by the council's refusal to open the accounts re the incinerator near Stonehouse.\n\n\nHumanity's existence  depends on nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI enjoy being out in the natural environment, it is good for my mental health and well-being. I love learning about nature and I want future generations to be able to have the benefits of living with the natural world.\n\n\nBetter public transport to get us out of our cars.\n\n\nWe need each other, having access to nature is good for us. Nature needs us to protect it."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe all need nature to be happy and healthy.\n\n\nNone\n\n\nThere is nothing more important than nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI live in the country by choice Hillesley in Stroud District council) just because of all the surrounding fields and woodlands; the birdsong and the occasional sightings of deer, badgers, rabbits etc., but sadly not hedgehogs\n\n\nBuild on brown field sites rather than green field sites - cleaning them up if necessary\n\n\nWe all live on this planet and we need to care far more for the creatures and nature that have to share it with increasing numbers of humans"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nQuite simply the future for our children and grandchildren\n\n\nA plan to protect our wild spaces"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThere is nothing more important! Nature knows balance, it only takes what it needs and never anymore\n\n\nStop building houses in vital green belts and wildlife corridors\n\n\nTo ensure we can protect what was there before us and respect the land that we feel we own\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt's our life blood\n\n\nThink nature\n\n\nWithout it we are extinct"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nAccess to the soil, farm to fork. Access to blue & green spaces in all gardens no dig or cut September to April to all bees, bugs, butterflies & hedgehogs & toads & frogs to hibernation to provide natural pest control. Access to allotments, seeds, herbs,fruit trees & locally sourced produce. Regenerative farming & no till use of natural pest control only.\n\n\nAll new homes with 15 minute access to amenities, no front car ports 15 minutes bus service to local city & surrounding towns, no driveways or garages for homes, segregated cycle lanes. Promote trees & hedges to provide wildlife, wildflowers for nature to thrive. 20 mph speed limits to reduce PM2.5,PM10, CO2 etc.\n\n\nBiodiversity net gain, nature 1st all developments to use SUDS."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nSimply put, without nature, we the human race cannot exist.  No clean air, no insects means no pollinators, no pollinators, no crops, no crops, no food.  We have a finely balanced totally co-dependent ecosystem on this our home.  We have a responsibility for future human generations that they can live full lives.\n\n\nPrioritise clean public transport over private, plant more trees, ensure new large parks are prioritised, bring green economy jobs to Gloucestershire, build on brown-field sites and ensure all, absolutely all, new house building is constructed to be completely self reliant, maximum insulation, minimal need for externally sourced energy, surrounded by trees, green areas.\n\n\nIn our lifetime we've destroyed so much of our natural world in this country - it is essential to redress that imbalance so future generations can live full and happy lives knowing that climate change is being addressed and our ever heating world can recover. Let our area be a beacon for new green measures."]
["\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is vital for people’s  mental & physical health.\n\n\nRe-wilding, incentivise people creating wilder back gardens, protecting green belt from being built on.\n\n\nBecause without harmony we will destroy biodiversity and vital habitats. We will lose areas vital for wildlife and for the mental & physical wellbeing of the community."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause it will outlive me and my community\n\n\nencouraging people to support biodiversity in their own gardens - providing incentives to grow rather than to astro turf/pave over front gardens\n\n\nNature will help us to avoid climate catastrophe and we need to enable it to do that"]
["\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nI live in the natural environment. If it was destroyed the effect on the local area and nationally would be catastrophic.\n\n\nWork with the public and those with an interest and expertise in the natural environment.\n\n\nWe need nature and nature needs us to protect it."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nOur countryside is being swallowed up by housing development!!\n\nWe need to have natural environment to protect our wild life and our environment\n\n\nUse more brown sites for development many of these sites would easily & sustainably be suitable for transforming into housing. Leaving our natural environment free for us all to enjoy and benefit from. Hi\n\n\nTo enable the natural world to thrive and survive"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\npeople are part of nature - we need to integrate green spaces that are wild/connected/full of nature that give people the opp to connect  to the real world/fresh air/exercise/nautre/birds to appreciate the planet and our place within it\n\n\nneed to grow 'green corridors' through and around all towns, cities, villages so everyone can walk/cycle to a circular green route for exercise/nature/fresh air/down time\n\n\nwe need to learn we are part of nature , that we gain everything from it, that without a healthy planet we are gonig to become extinct. Connecting to nature and caring for it is vital if wewant to have healthy communities that are living in harmony with nature"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThis is critical for improving biodiversity, which we know is terribly impoverished throughout the UK, and for providing us all with opportunities to connect to nature, which we know is vital for our health.\n\n\nImproving public transport has got to be a priority - so much money gets spent on roads, whereas we need to be enabling people to use their cars less. This will be a lot easier if public transport is reliable, and affordable.  There needs to be imaginative, strategic, bold and joined up thinking for the long term - this will help us tackle the climate emergency, make us more resilient and give people hope."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt gives me a mental boost to see the natural beauty of trees and greenery  it is an escape to living in a town.\n\n\nUsing brown field sites for housing. Repairing housing stock.\n\n\nIt is self evident"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause we as humans are very much part of the whole picture and dependent on Nature.\n\n\nUsing brownfield sites/repurposing land for building/construction instead of continually encroaching on green land.\n\n\nBecause we are dependent on nature and needs our co-operation to survive and for us as humans to survive."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nVery important to protect existing wildlife\n\n\nDo more in depth surveys before sanctioning removal of hedges, trees and vegetation for Government funded schemes ie cycle ways."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nIt is vital to our wellbeing and existence as a species and should be protected at all costs.\n\n\nMuch more social prescribing by the NHS to get people to connect with nature, and for schools to offer regular nature trips for pupils. A local and national initiative to ask for more volunteers to help with restoration and conservation projects too.\n\n\nThe current systems are broken and put humans first, when in reality we must work with nature if we are to create a future for our existence as a species"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nA connection with wildlife is important for everyone and preserving green spaces to allow wildlife to live will benefit everyone in a community as well as the wildlife itself.\n\n\nPrevent veteran and well established trees from being taken down. Planting new trees, although helpful, does not replace a tree with many years of life connected to it. A mature tree is said to be worth over 1000 new trees.\n\n\nTo ensure that wildlife survives. Most developments result in far more land lost than is saved, and this has a seriously negative impact on wildlife, with diminishing places to live and feed. This is not to say that development should not happen, but it needs to go a lot further to protect wildlife from further decline."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment needs to be recognised as a key contribution to the good health of all communities. The link between healthy ecosystems and healthy communities has been proven time and time again. The natural environment forms an important part of every day life and provides the basics of a healthy life e.g. food production, clean water, pollination. The natural environment also provides higher levels of health relating to reducing stress and anxiety.\n\n\nMake more space for nature. Humans needs are prioritised too highly against the needs of nature, for example a football field is created as 'green space' instead of a wildflower rich meadow. Nature needs to be imbedded into development plans. Community should be built around the care and nurturing of the natural environment. Use the ecological surveys conducted to provide the appropriate homes for nature. Encourage people to have wilder gardens, use integrated nest boxes in houses. Stop installing fossil fuel reliant technology in homes to contribute to bringing the environment back to health for both humans and nature. Prioritise designing around nature not around the requirements of humans. A whole attitude change is needed.\n\n\nDevelopments cause great disruption to the natural environment. It takes decades for nature to recover after a development has been completed. This does not need to be the case. If properly designed developments could lower the impact on nature and profit from the benefits of the natural environment sooner"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nCOVID taught us all how important the natural environment is to people's well being, but also it is our responsibility to take are of it as we are largly responsible for the current biodiversity loss.\n\n\nWild areas on public land, encouraging individuals to do more in their gardens and engage more with wildlife generally. ALWAYS have biodiversity at the very core of planning decisions...\n\n\nBecause that's an opportunity for us to have a positive impact while making other changes and as we are changing the environment we are responsible to ensure biodiversity is protected and improved at the same time"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nMental and physical health. Places to experience connection with the natural world. The climate regulatory services nature provides make our world livable.\n\n\nHedgehog highways! Local construction supply chains with eco friendly materials. Protecting greenbelt land and regenerating disused land and buildings.\n\n\nBecause no one wants to live where nothing else can survive. We want to live in areas of abundance with thriving wildlife not concrete deserts. Nature is important for local food production and other essential resources. If we don't have that locally we have to import - causing more damage to the environment."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment is important that we have the opportunity to see nature even in a busy town/city.\n\nWe should be able to co exist with nature.\n\nIt is  lovely to see wildlife and gives a kind of therapy in our busy lives.\n\n\nMaintain gardens and parks, for they are oasises for nature to continue to thrive in our busy towns and cities, the same for the natural hedgerows.\n\n\nSo that we can co exist with nature and prevent the loss of any further species."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nAs a member of the Trust I have long had an interest in nature and the environment, but in terms of the SLP it should be noted that people without a deep interest in nature can't develop an interest in something that they have not been given the opportunity to experience.\n\n\nEven without that interest access to outdoor spaces, with clean air, water, plants and wildlife has immense health and well-being benefits. In the immediate areas around homes and work places it provides opportunities for social activities and exercise at little or no cost to the individual. It will help people to live a longer life in a healthier state.\n\n\nIt should not be necessary to travel far away from your home or school to experience a diversity or rich abundance of nature. It should not be banished to special reserves but accessible every where.\n\n\nThe legislation may call for a Bio-diversity net gain of 10% but it should be considered the minimum aim of any development, as this merely reverses some of the decline in the last 50 years in farmland and hedgerow birds for example. All Councils need to ensure consistent monitoring and enforcement to ensure that it actually takes place and is maintained.\n\nFor example trees planted in the wrong place (areas that could be restored as a rich-meadow-land) or that are not cared for after the initial planting by removal of plastic tree guards for example do not help.\n\nOther steps should include more sensitive mowing regimes (timing of mowing & removing cut vegetation - see Buglife's roadside verges campaign for example) in parks and road side verges to encourage wildflowers and insects.\n\n\nAs a resident of Tewkesbury I note the amount of buildings, roads and other hard landscaping in development adjacent to the natural flood plain with concern as this reduces the capacity of the area to absorb higher or heavier levels of rain fall that are predicted under many global warming models. Protection of and enhancement of the flood plains to absorb this water must be a higher priority for the plan.\n\n\nFinally it should be noted that clean water is essential to all life, and healthy soils and insect populations are essential for food security. Everything is interconnected and a lack of diversity and small and fragile populations of species in the environment is an indication of future risks"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan.\n\n\nThere  are many reasons we need nature: for mental health, for enjoyment, for exercise, for play, for interest, for relaxation, for improved air quality, for cooler summers, for natural carbon sinks and for food for example.\n\n\nI would like to see councils spending the money that is used to keep green areas 'tidy' on developing the same areas for biodiversity.\n\n\nWe are already a nature-depleted country and getting worse not better. Where development is necessary it should be considered within the overall needs of the community, and these overall needs include a need for nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nDon't want to live in a housing estate\n\n\nNot to build on farmland or Green Belt\n\n\nBetter standard of living for everyone\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBecause without it we live in a barren environment.\n\n\nEnsure that we incorporate planting directly into the ground with every highways project. Ensure a high proportion of green space in every new / maintenance project.\n\n\nWe need to mitigate for flooding and over heating and increase biodiversity and habitat - more planting is required and not just of trees."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWhen I first moved to Quedgele I used to walk across fields full of wild flowers beas and insects. My children loved exploring the wildlife and doing mini beast salaries. Now my walk is all houses no place for wildlife.\n\n\nWildlife corridors linking open spaces.\n\nGrass verges replaced with meadow turf full of wild flowers. ( would also save money on mowing)\n\n\nWildlife is in trouble. I understand homes are needed but so is wildlife."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nLike many people it makes me feel happy when I see nature thriving. Nature also gives us resilience to flooding holding trees and hedges hold together saturated souls and prevent erosion and create the comfort of shade in hot weather.\n\n\nTo convert unused town buildings E.g offices into housing. To not only penalise empty house owners, but really crack down on second home ownership with higher taxes.\n\nAlso to stop building on flood planes! Riparian habitats form important corridors for an incredible diversity of wildlife. They are also prone to flooding which is distressing and costly to property owners and the wider community so it makes no sense to keep building there!\n\n\nBecause humans are going to always need housing so it is important to have good strategies in place to protect areas of high diversity and connectivity from the beginning rather than develop on them and then replant imported non-natives afterwards. We loose so much- often  hundreds of years of growth and natural function in the process. Older more established natural areas always supports a richer, more diverse natural community.   Also nature protects and supports humankind in so many ways we cannot afford to loose any more of it."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nThe natural environment provides us with everything we need for survival, without it we have no future. I need to ensure that my children have a future to look forward to.\n\n\nConsider the impact on nature in all decisions. We must not allow further biodiversity loss. Development must be carefully located and designed to have minimum impact on the nature recovery network and biodiversity net gain must be implemented properly. Using GNCF as the local broker will ensure the most meaningful placement of offsite BNG within the county. Well designed destination SANGs are needed to relieve recreational pressure on nature reserves and protected sites.\n\n\nThere is only a finite land area to meet all needs. To stop biodiversity declines, maximum biodiversity opportunities need to be integrated into all land use types. Development should deliver to actual housing need, maximise biodiversity benefits and be located in the least damaging location to biodiversity. All new development should be zero carbon."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nVital for spending time outside with our young family in real nature. Not just a ‘park’\n\n\nProtect greenbelt\n\n\nBecause the country is growing and their needs to be a balance"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nMassive physical and mental health benefits; all the ecosystems services and natural capital benefits that one might conceive; the natural environment is fundamental to human existence\n\n\nHaving worked previously for a local authority that had already declared a climate emergency, I would say please do not miss this opportunity to declare a nature emergency.  There is increasing awareness of the way that nature (biodiversity) and climate are inextricably linked - so both need a seat at the top table.\n\n\n1) Currently I lead a project focused on adder conservation on the Cotswold Escarpment.  Adders are one of many native UK species that are negatively impacted by development breaking up their range into smaller and smaller fragments.\n\n2) As an example, I very recently saw one of GCC's main supplier tree nurseries promoting an ivy cultivar (originally from France) at landscape designers, falsely claiming that it has all the benefits for nature as native climbing ivy.  This is false since the ivy cultivar being promoted does not produce flowers or berries.  Every autumn, native ivy is one of the last sources of nectar for pollinating insects, and the berries that follow are an important winter food source for many bird species.\n\nIf this ivy cultivar were to be used widely across an urban area then - because of the lack of flowers and fruit -  it could be detrimental for urban biodiversity.  Except around airports where birds need to be discouraged, this would not be working in harmony with nature.\n\n\nhttps://linkprotect.cudasvc.com/url?a=https%3a%2f%2fwww.woodlandtrust.org.uk%2ftrees-woods-and-wildlife%2fplants%2fwild-flowers%2fivy%2f&c=E,1,tl_MnZIoOyi-3WZxByDy-s8mQ1SnWTVZ1AxJwHszFHhFQ9JSPARNNkdmomH3BFAiT4MNLBgRbrP5CAMwzXJjKLPKfHCBThW80lUt40PkRYTmO2bR-w,,&typo=1\n\n\nhttps://linkprotect.cudasvc.com/url?a=https%3a%2f%2fwyevalenurseries.co.uk%2fnews-projects%2fwe-launched-a-new-non-climbing-ivy-at-four-oaks%2f&c=E,1,kZMXD8dgzPw_Em7cd203iPiyoNTltQJxPOy89bCKsbc-oGM-_-suAsiZje3spMj7hPKzDdNmkt7487fgk-jGp986IVQgGJVU-LYAjBpW5wpIIFy4whESJy2uVVqC&typo=1"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nEnvironment issues are becoming more and more important we are running out of time\n\n\nMore eco friendly communities\n\n\nSo that we preserve the earth for our future generations"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nWe absolutely depend on it for survival. We are part of nature and nature is part of us. There will be is no economic gains from destroying the basis of all life in the long run.\n\n\nInvolve communities, educate and inspire. Invest in nature based solutions.\n\n\nWe need to approach things considering the wider system... We cant depend on temporary gains , mitigations or offsetting without address the root cause and considering how things interconnect."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nBeen interested in natural history all my life.\n\n\nPlant some trees and ensure they have water!\n\n\nNatural areas are being lost to development at an alarming rate."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nHumans are nothing – and cannot survive – without nature. Stop destroying our ecosystem. Prioritise nature!\n\n\nStick to development of brownfield sites. Prioritise the natural world"]
["Integrating protection of the natural world is crucial to any council's health or social policy, as such a great deal of evidence shows that healthy, green and blue space has innumerable benefits for individuals and communities;\n\n\nGet more volunteers in! Lots of people are willing to do things. Some less than others, but provide incentives and community building, and the efforts to help nature can move ahead more quickly.\n\n\nI am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nA healthy natural environment promotes wellbeing (body & mind), community cohesion and a healthy environment improves the locality.  It is also less costly in the long-term in terms of health.\n\n\nLocal authorities need to engage in more cross-council joint-working using holistic approaches. Where possible ‘rewilding’ should be undertaken - an example being that parks should be invested in with better management aimed at helping the environment- with ‘wild areas’ being created and maintained sympathetically.  Councils should urge land-owners (and help with funding grants) that hedges should be maintained manually, NOT cut by chain flailing which destroys much of their usefulness to wildlife.\n\n\nCouncils should take more interest in the state of local  rivers, streams and watercourses.  They should actively monitor these and engage with the wildlife trust to improve local fluvine ecologies.  Councils should also pursue and prosecute companies (including Severn-Trent) who pollute the waterways or ignore their environmental responsibilities.\n\n\nWe need to address issues for the natural environment because without nature we are nothing"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nSince living in my area there is less and less green space for nature. We often take walks as a family. We moved to this area to be around nature and it’s being sacrificed for building new houses.\n\n\nBuilding less houses. Working with nature rather than against it\n\n\nWe have the share the planet with nature, all that’s natural habitats we keep taking away can’t be put back easily. We are pushing nature out, causes more flooding by building houses on the fields needed.\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nAccess to natural spaces is essential for good aiding physical and mental wellbeing. Spending time in nature is a recognised anti-depressant, it is free and solves a problem in a healthy pressure-free way. Just as importantly, these natural environments provide habitiats for the local ecosystem of birds, insects and wild animals.\n\n\nLook to re-purposing derelict or underused existing built environments. Direct housebuilders to take on these areas of land and 'recycle' them into fresh new developments.\n\n\nQuality of life, good health and mental wellbeing for people. Protecting the balance of the wildlife of our domestic ecosystem. Birdsong, butterflies, bees are simple yet valuable and should be around for everyone to enjoy. Without insects there is nothing to pollinate a wide variety of plants."]
["I have lived my entire life in the countryside.\n\n\nTB cull is imperative.  Badgers are suffering, and spreading, TB to other animals.  A peer-reviewed scientific analysis of Defra’s badger control policy in England has revealed a 56% fall in bovine TB rates. Badgers are the only animal that can hull out and eat alive a hedgehog.  Thanks to the explosion in badger numbers, hedgehogs are now on the vulnerable, at risk of extinction list.\n\n\nBadgers are an apex predator.  We need to manage the spread of tb which costs the tax payer 100s of thousands of pounds pa."]
["Please declare a Nature Emergency, This is essential for us and the planet. Healthy areas have healthy people;\n\n\nBan gas boilers, heat pumps on all new builds, solar PV too;\n\n\nWe need zero polluting businesses, homes, cars, recycling centres etc etc."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI used to love next to a huge open field home to frogs, newts, foxes, badgers etc. It is now gone. I miss the wildlife and green spaces. Our children will soon only read about these animals in books.\n\nDesignated nature areas that cannot be built on.\n\nBecause nature is vital to our mental health. In a world with mental health crises, we need to preserve what we have. We have already lost so much, we cannot afford to lose more."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThere are lots of mental and physical health benefits to engaging with nature. Having more greenery and nature just makes it a nicer place to live. Helps prevent flooding and provide shade, reduce pollution and overheating.\n\nCouncils could support nature by avoiding building on the green belt, providing more funding for green spaces, maximising/enforcing the net biodiversity gain development scheme.\n\nThey could encourage council housing residents to plant more trees, take part in no mow may, etc.\n\nAllow more land to be used for community gardens.\n\nEncourage businesses to plant more nature friendly shrubs etc in car parks and surrounding landscaping.\n\nDo more perennial planting like in Sandford Park. Less throwaway bedding plants like in Imperial Gardens.\n\nDevelopment working with nature is important because it is better to incorporate nature friendly aspects when building, than try to add them later! Rainwater collection and community growing spaces are just two possibilities"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe live in a stunning area - we need to protect it for generations to come and stop huge urban housing estates swallow up the countryside.\n\nReplanting of trees to replace the devastation of ash die back\n\nNature has been harshly hit and it’s diminishing at a shocking rate and flood risks are out of control"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe are all reliant on nature for survival\n\nPublic consultation\n\nDevelopers can help nature enormously"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature and bio-diversity is vital for humans in the form of food security (pollination) and also for dealing with mental health issues. Nature also plays a vital role in tackling climate change, reducing air pollution and reducing severe flooding. Also, we should be protecting nature for nature's sake.\n\nEmpower local people to take local responsibility for managing local wildlife, allow us to plant wildflower verges, and clearing areas of litter. Give us information, lend us tools, give s the resources, give us advice on how to set up local groups, to take pressure off limited council budgets and we'll supply the manpower. Wildflower verges reduce the need to cut grass, for example. And they'll make areas look nicer. Ugly patches of abandoned grass on council estates can be transformed to create small wildlife oases, which can be linked with people's gardens. Reduce red tape and petty health and safety guidance. I think we all know how to use a shovel or pruning knife safely.\n\nFor all of the reasons above. Destroying nature is not good for the environment. Nature needs to be built into all developments whether that's small ponds, wildflower verges, planting trees, hedgehog tunnels, bat boxes, or creating bug hotels etc. Give local people the chance to do this work on behalf the council, via nature groups such as the Wildlife Trusts."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment is essential natural habitat for all species on the planet! We need to be connected to our landscape for health and wellbeing of our mind, body and soul.\n\nMake rewilding exercises and in-person visits to nature conservation sites mandatory for all council and government cabinet members in order to develop true relationship between environment and policy makers.\n\nSimilarly, make in-person visits to local wildlife rescue and rehabilitation centres mandatory for council members and keeping abreast of local ecological issues and plans in order to develop real understanding and empathy for the needs of the natural environment and inhabitants.\n\nThis is a no-brainer! Without a healthy balanced environment we all suffer, all species animal/vegetable/mineral. We have got to remember that humans are but one species within a diverse and carefully balanced natural design, not separate from nature. In order to thrive, life needs balance and biodiversity."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n\nHousing developments are now being built with no front gardens and very small back gardens. There are no green spaces planned into new developments as they piggy back off spaces put in by other developers. What was once wild areas nature thrived in are being turned into concrete and brick with an occasional tree to tick the ''green'' box.  I no longer even see birds around my house because they have nowhere to roost. We are snuffing out wildlife that could, so easily, be accommodated at the planning stage. My area was, so say, designed using the principles of a village.... I can see none of the beauty of a village in Kingsway.\n\nDon't allow houses built right against the pavement and road ~ even a small area of green between them would make a difference.\n\nInsist that *every* new development has a significant percentage of its own green space ~ do not allow them to use larger green spaces near by.\n\nInsist that new developments do actually plant the trees they put on their site plans *and that they maintain them so that they survive into maturity ~ about half of the bushes and trees planted on my development (that I had to push persimmon to actually plant) have now died and they now Say it is the council's job to deal with as the roads have been adopted.\n\nBecause without nature, humans die.\n\nThe mental health crisis that we are in are a direct result of the nature poor lives we live nowadays.  With more trees and wildlife outside your front door, people might be able to get joy just walking down their street."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt has been proved that access to nature improves people's health & wellbeing.\n\nProtect and create green spaces and plant wild flower meadows wherever possible.\n\nIt is easier to ring fence green nature friendly spaces before land is developed."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI would like to see more diversity of wildlife in my village, Olveston. Spaces for nature should be protected because it is their home too, it's not just for humans who are selfish and greedy. It should not be built over just to provide new houses for humans when they have not taken good enough care of existing houses and don't share with each other. We shouldn't be so isolated, shutting ourselves in our homes. It is important for my community to access nature and the great outdoors because it is good for our mental health and our physical health.\n\nI think you need to go to peoples front doors (pre warn them first) and explain and educate. You need to build relationships."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nliving on a floodplain the natural environment is a constant reminder of human fragility. Nature doesn't need us. We gain health and pleasure from the Beauty and diversity of our surroundings-though this is shrinking quickly as we all can see.\n\nStop agreeing to massive building projects with NO gardens/endless tarmac , no solar panels/eco materials and poor quality building materials and  practically no trees. Balance is a necessity work with nature .\n\nHabitats for birds and mammals are being destroyed by greedy developments. There could be laws to make sure  these issues are addressed when developing land. Councils could support wildlife by making sure some rules are addressed at the planning stage?"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is essential to keep a balance in nature so we must preserve all the species we can as they are all interdependent including us.  It can spiral out of control quickly if we don't take urgent measures to protect, replace and help the nature around us which we have already destroyed so much of.  I worry for our 7 grandchildren that we are leaving the environment in a frightening state.\n\nPlant all kinds of trees and keep them watered in the dry weather.  Volunteers to help?\n\nLeave hedges and trees when building. Plant parks etc with insect friendly perennial flowers, blossom trees and berried plants etc. leave rough ground and use much less weed killer especially round up.!  leave or put in ponds and nature corridors.  Try hard to stop run off from fields into waterways and sewage pollution. Monitor streams etc to show people the damage and highlight it so people are aware of damage.\n\nWe have to understand that we are destroying the balance and causing floods by building and reducing farmland so having to import more food.Farmers need to be encouraged to farm sustainably and reduce fertilisers, recycle waste, use waste to generate energy on site and also use solar and green energy sources.\n\nBuilders should only get planning permission if they build zero carbon houses with heat pumps, solar panels ,insulation, electric car charge points and innovative building materials like wood framed houses etc avoiding cement where possible. Young people need to be encouraged into new green jobs and trained into a different world as things need to change at a much quicker rate.  All generations need to realise we need to work with nature and we can't keep things as they are."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe are a semi rural area and so many of us get to meet up and chat while enjoying our green space areas.\n\nMonitor our changing environment and plan accordingly with any new builds making sure green spaces are protected/enhanced.\n\nIt is so easy to look at the development of projects but lose sight of our natural areas we need to protect"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is essential for physical & mental health & wellbeing\n\nNature must be a priority in all Council decisions. Work in partnership with local community organisations & those eg Wildlife trusts protecting & furthering the needs of the natural environment.\n\nTo minimise the loss of biodiversity & harm to wildlife & to build for a sustainable future"]
[" am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nA healthy natural environment means clean air and water and nourishment for pollinators that pollinate our crops.\n\nCouncils should create wildlife areas in parks and other open spaces and plant nectar-bearing plants for pollinators.\n\nDevelopment should work in harmony with nature as nature is essential for our physical and mental wellbeing.\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is of tremendous value to human mental and physical health.\n\nEncourage volunteer groups and activities.\n\nBecause humans need green space."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nbecause we appreciate it and enjoy it and benefit from it\n\nGive room for green spaces, parks, woods and grass, we and all living things need these.\n\nwe all like to see living things thrive and flourish and this aids our wellbeing"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nTo keep balance between buildings and nature\n\nBuild more on brown sites\n\nPeople need nature to keep healthy"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWithout it we all die either of depression or lack of crops due to no bee populations etc\n\nMake nature highways, not pockets so nature can move freely rather than be stuck in one garden or hedgerow and not thrive. Manage land with knowledge and with nature in mind not just any tree or wildflower. Engage every neighborhood to have their own highways of nature with hedgehog routes etc\n\nSame as deforestation it cuts off the journey for nature which then cannot thrive, in a small prison of green. Connect it up or lose an eco system entirely."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nMental health\n\nNature reserves\n\nTo develop sustainably"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe need to protect nature so that future generations can see and enjoy what we have.\n\nIf development is checked nature will just be destroyed."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt’s vital to our ecosystem and the biodiversity of our community\n\nMore wildlife reserves in local areas - each village should have at least one wildlife conservation area, local schools and clubs can help towards the upkeep and teach the importance of protecting our wildlife\n\nTo protect local wildlife and endangered species"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nGreen spaces and the natural environment are key to people's mental health and well-being, as well as being important in  carbon capture.\n\nPush for swift, bird and bat boxes to be part of the design for new buildings.\n\nPeople's well being and mental health is at stake when buildings and projects do not work in harmony with nature"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nHealth, physical and mental, saving the planet\n\nUse brownfield sites for new developments and not encroach on greenfield sites or AONBs\n\nWe need to co exist to fulfill the circle of life and maintain rich diversity"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nHealth, cost of living, happiness\n\nBe more interconnected with charities\n\nIt doesn't only impact people health anx wellbeing, but also the national budget!!"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nTo ensure we look after our wildlife and in turn our planet\n\nEnsure more stepping stones and wildlife corridors.\n\nWe are destroying our wildlife and natural environment - it will help us if we help it"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nLiving near to Burrows Field in Leckhampton shows how valued this green space is for walkers, sports and general enjoyment. It also shields adjacent hedges & meadows for wildlife. Green spaces serve many positive functions and need protection.\n\nPrioritizing those areas where wildlife still remains diverse and, where possible, providing corridors to link them together. Cycle lanes help encourage less car journeys. Fewer plastics & improved recycling of them.\n\nHousing should be more sustainable, and promotes well-being if connected with nature. Flood mitigation possible."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment is vital to me as it helps my physical and mental well-being, provides essential resources, and supports biodiversity. It offers recreational spaces that foster a sense of connection and responsibility towards our planet.\n\nWe have recently had wild flowers planted close to our house, it would be nice to see these implemented in other green areas.\n\nBiodiversity is key to ecosystem health, providing critical services such as pollination, water purification, and disease control."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature helps keep me sane when life is difficult.\n\nPlease ensure you  work with local nature groups in drawing up the Local Plan\n\nNature is not just a nice option, it is vital for all of us."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nHealth and survival\n\nEducation and communication - so the general public can learn how vital it is, what they can do and how...\n\nIt is becoming a matter of survival, and done well outcomes will be so much better for everyone"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe are destroying wildlife.  We need a balanced approach to support both wildlife & humans.\n\nSet wildlife corridors between existing green spaces.  Reclaim and Re-wild areas where possible\n\nAccess to green spaces and the nature it supports will improve the quality of life for humans."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe all need green spaces and wildlife for the sake of our mental and physical health.\n\nTurn brownfield sites into green ones. Plant trees and gardens wherever there's unused space.\n\nWithout nature the built environment is a soulless and unhealthy wasteland."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt won't last for the future generations if we don't protect now."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe need nature for our survival never mind simply a better quality of life.\n\nJust make sure nature is considered in every decision. I don't live in your council area but what other councils are doing could influence what my council does.\n\nWhen nature dies we all die."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nAccess to nature is crucial for human health and happiness\n\nReduce motor traffic (e.g. wide 20 mph), more trees\n\nEssential for human health"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe are one of the most nature depleted countries in Europe and anything we can do to fight the decline is surely worth doing, particularly when it costs nothing?\n\nBuild on brown belt sites instead of green - look at disused industrial sites, factories and warehouses, before flattening trees and concreting fields.\n\nWe need more houses and we need more nature. They have to work together to achieve this."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBecause we share this planet\n\nCreate Biodiversity Net Gain areas in all devcelopments (which is the law anyway) and rewild wherever possible\n\nBecause destroying habitates and not replenishing them means they're gone forever"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI believe being in the natural environment helps humans see what is important in life, both by getting perspective on their own lives and also seeing and learning about other creatures which share the planet with us.\n\nDeclaring an emergency is a start but everything the council does should have built-in checks to help nature. I would like to see more high quality green spaces, a ban on plastic grass and flowers, appropriate planting of trees and shrubs which are useful to wildlife, nest boxes, insect hotels etc within the urban environment, and protected areas where wildlife can be undisturbed.\n\nIt is important that any development is sensitive to the wildlife it will affect so that we do not see a further decline in many species which we should be helping to conserve."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is essential for nature to thrive to secure all of our futures.\n\nUse Pesticide Action Network (https://linkprotect.cudasvc.com/url?a=https%3a%2f%2fpan-uk.org&c=E,1,wFChgT1y58uligGY7BW4-nPn-81-hYA5si_RdlzIGbo8hBeGlcxOcOd43i-gmhArV3t-kZs2yAS0UIj0KuNr0JK-_oGlKRWY7FPf70zDp2VldkCPnBBj&typo=1) to help reduce the amount of pesticides the county uses.\n\nIt is otherwise in danger of destroying what is most useful to the residents."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment matters for our emotional and physical wellbeing.\n\nMore vertical green planting on walls & around lamp posts.\n\nWe *are* intrinsically nature. Our built developments should have texture, scent, breathability and colour, as living breathing bio-organic environments."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nseeing nature and being in nature is good for us and everything that lives in it\n\nwe need to protect not bulldoze. you can't take a 300 year old tree and replace it with 3 twigs and then leave it . There needs to be a few years of looking after. Or better still look for better ways to keep the tree.\n\nMost people want the look of nature , but many want to save the wild that live in it.  If you look the most expensive houses are the ones on the tree lined streets"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is so important for our physical and mental health.\n\nWe need more ponds and trees.\n\nIf we do not have nature, we do not have healthy communities."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nMy local countryside park is a crucial part of my life. It is good for my physical and mental health.\n\nAlways take into account the effect on wildlife when giving planning permission for any developments. Green spaces need to be seen as a necessity for any community.\n\nBecause natural spaces are good for our health. Trees and green spaces are good for everyone and enhance any development. No-one likes living in a concrete jungle."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nPreserving nature and improving health.\n\nPromote it and spend more on it.\n\nProtect it before it's too late"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature should be important to all of us. It can provide us with calm spaces to relax in. Obviously it is vitally important to the wildlife which in turn benefits us.\n\nSave green spaces, plant more trees, stop using harmful pesticides and respect wildlife habitats. Also creating wildflower meadows.\n\nThis benefits humans and wildlife."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nA balanced ecosystem is vital to reverse declines in plant and animal species which support human physical and mental well-being, for example pollinators and the wildflowers they feed on, swifts and the insects they feed on, trees which provide shade etc.\n\nIncorporate existing trees and hedgerows into new developments where at all possible. Include “swift bricks” in each new house built. Replace some areas of close- mown grass with wildflower meadows (parks, roundabouts, verges). Stop using pesticides/herbicides (Paris has done this very successfully).\n\nOften, important natural habitats are lost unnecessarily when land is developed. Changes in the way developments are designed can have huge benefits for nature, and for the people who live and work in them, at relatively little cost."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt lifts my mood, supports a healthy life and is something that is intrinsicly precious and should be protected.\n\nEncourage people to live more sustainable and less damaging lives, protect nature via planning rules and decisions, ensure business develops and operates sustainably.\n\nWe need a strong economy to support our lifestyles and we need nature for a healthy life. The balance needs to be struck such that business and the environment/nature can thrive."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt should go without saying, but we are one of thousands of species on this planet. The time to start respecting all those non human species is now\n\nStop cutting down anything that looks 'messy'. Stop building on any tiny spot that is available. Plant trees. Stop paving over every little space. Etc etc\n\nBecause we are not the only creatures on this earth!"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe can't eat money, your plan should be helping to save us from ourselves not more of the same old profit led development with little regard to sustaining life on our planet.\n\n40% of Greenfield development sites should be left undeveloped and managed forever for nature.\n\nWe can't and won't survive as a single species on this plant, without more nature our country is still living in an unsustainable way."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is so important to keep in touch with nature and support our natural environment where ever we live. I love in a city and crave more green and natural space. Nature supports our wellbeing in all ways and it is vital that we try to live in a way that supports it for us as individuals and the survival of our planet.\n\nEnsuring that any new builds, whether buildings or roads, have green spaces built in around them to support nature. Housing has lost more and more garden space over the years in favour of cramming in more houses in to the space. This is detrimental for us and for wildlife.\n\nWe are nature. Not separate from it. Our wellbeing and the wellbeing of our planet depend on the natural world around us to sustain our atmosphere and our health, both physical and mental. We must recognise this and not concrete over our beautiful planet with no regard for nature and it\"s needs."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBecause everyone and everything benefits from a world that is rich in wildlife\n\nGetting local individuals and community groups to grow native tree seedlings to be planted in Gloucestershire.\n\nBecause we must learn that we share the world with wild creatures. It is not ours, but theirs."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment is integral to being a human. It is essential for maintaining physical and mental health. Importantly, we cannot replace what we lose. Forests and woodlands takes years to form and develop.\n\nMaking every effort to preserve and keep green space. Being clever about where we put new developments. Not in areas that are unconnected to services and communities which mean the inhabitants are reliant on cars.\n\nIt's important for people's quality of life. Areas that are overdeveloped have an impact on people's physical and mental health. Green space is important for quality of life. It is particularly important for deprived communities, older people and children. Not forgetting the importance for wildlife. Once it's gone it takes years to get it back."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature underpins everything we do, from providing food to improving our mental health.  We will all be poorer - if not dead- without it.\n\nIntegrate and normalise environmental considerations in all departments. Consult with experts on what needs to be done and how. Don't mow till August!\n\nWe are facing a biodiversity crisis. If we don't take it seriously now, it will be too late to act. Environmental considerations should be front and centre of all planning."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is a lifeline, both literally and metaphorically. Being in Nature is good for our physical and mental well-being and a healthy, and biodiverse, natural world keeps us all alive.\n\nA quick win would be to stop mowing all verges during the flowering season and to do a late cut. This would save both money and wildlife.\n\nSimilarly encourage farmers not to flail hedgerows. The devastation and destruction seen every year is so unnecessary.\n\nUse properly trained, and experienced, independent ecologists to conduct full and proper surveys as part of any planning process.\n\nAs part of the process Councils could insist that all new builds, whether domestic or commercial, include environmentally friendly aspects such as solar panels, proper insulation and, preferably, swift bricks!\n\nWe are in a nature emergency, which is also an existential one, no-one can be outside of the efforts to reverse the situation. Business, government (local and national) and individuals must work together with the nature related organisations to do the right thing for nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIn the 5 Valleys we are surrounded by the majesy of God's creation, it is there for humankind to benefit from in whichever way, it is the Councils moral resposibility to preserve it.\n\nTo provide more, and better footpaths that are accessible for all with much more and better signage.\n\nAll Councils must slow down this urge to build on new pastures, and only permit such building when all brownfield sites are exhausted."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment is our life support system. We must do all we can to protect it and improve the biodiversity that we have.\n\nThere needs to be more initiatives in place to show people at all levels the wonderful world that needs cherishing.\n\nInform and educate. If people don't know about the threats to nature and how their behaviour impacts that, they won't know  what positive changes they can make.\n\nWe have lost too much nature. Protecting and improving our natural environment will be beneficial for everyone. There is scientific evidence that living in an area where there is nature all around has benefits everyone's health and wellbeing."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment is crucial to our survival as everything is interlinked. So we need to create and protect a healthy natural environment for our own wellbeing and survival.\n\nLocal green spaces managed more for nature. Better communication and education about importance of nature in urban areas. More consideration of natural solutions for flooding and health etc.. basically we need to re-design our towns and cities in harmony with nature.\n\nNew development can have a detrimental impact on our environment, and make problems such as flooding worse. More natural developments are much better for peoples mental and physical health."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt gives us space to relax and keep fit and learn about nature.\n\nWildlife corridors and protected environments"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWhy are we even discussing build on Greenbelt lane? For many years it has been protected land, what has happened? Green belt is so important for nature to be protected, it was put in place for good reason to protect it, it is important for the air we breath an and our mental health as well as our nature that live in it. It’s there world not just ours to take and take. It has to stop somewhere.\n\nMore sympathetic building practice that considers nature as a priority. Stop building mass estates incorporate smaller amounts of house which would have less impact on nature. Stop bulldozing hedgerows the drop of a hat, these are important for birds and wild animals, native hedgerow where animal feed and nest should be protected or replaced to encourage wildlife To survive going forward\n\nIt is our duty to develop responsibly, once these areas are disturbed and bulldozed they are then gone forever, our countryside is wonderful and people need to respect a cherish it and keep areas safe from development. Re-establish and keep the Greenbelt land where it can be kept safe."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt helps to not only support local agriculture but also helps nature to flourish and survive the global climate crisis.\n\nIncrease tree planting along the river and canal banks. Small cost for big long term reward and flood water mitigation.\n\nWe are all part of this one world."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe cannot continue to expand the urban sprawl without providing open spaces, maintaining mature trees and green areas.\n\nUse existing brownfield sites for new builds, rather than wrecking green areas and natural environments.\n\nIt is not natural for humans to live without access to open spaces and nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI live in an Area of Outstanding Natural Beauty. This means a lot to me. It's fragile and under pressure for housing.  I know housing is needed but can't our councils protect the environment AND build on brown field sites?\n\nReview all sites scheduled for housing and consider whether they could remain undeveloped. All too often the easy choices are made. A beautiful environment is good for all residents.\n\nBecause we are all one. Without access to fresh air and trees we become unhealthy and depressed. It is everyone's right to access green space. If we lose that space we we can't bring it back."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\nTo enhance a feeling of well being by our connecton with nature.\n\nWork with naute by building in wildlife corridors and retaining green spaces. Protecting hedgerows and managing verges for the benefit of nature.\n\nIt is more sustainable and can protect us from extremes of weather such as flooding."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nAs a mother I want my children to have the same (or better) opportunities to observe and experience Nature that I had in my childhood. We know that there is a shifting baseline of what is regarded as diverse. The sad fact is nature is becoming more impoverish every generation.\n\nTo work together as a collective. To stop building on floodplains. To create honeypot sites that takes pressure off more sensitive nature sites. To invest developers money in permanent recreational officers on the ground that can help manage recreational pressure. To create new nature refuge sites in the floodplain that act as wetland stepping stones to nature. To embrace biodiversity net gain as way of rewarding landowners to restore species rich grassland and to de-intensify their need to get maximum productivity.\n\nOne of biggest pressure on the Severn Vale is unsympathetic development - it is not just houses but all the infrastructure (ie drains, roads, way-leaves) required to resource these development. Also insufficient recreational sites accompany these new development sites and so extra pressure is put on quiet nature sites as people seek solitude and space."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment is so important to me because I always feel so much more at peace in nature. I am studying in the conservation sector, and we just aren't doing enough for what should be considered a nature emergancy!\n\nWe need to plant more trees - on every available surface (a mix of native trees). Another really important point is to work with farmers to move towards sustainable farming. We won't be able to overcome the challenges without the help of everyone, especially the local community. Working with the public to promote growing veg at home, and the benefits it provides (not just delicious food, but mental health).\n\nWe cannot survive without nature so it is so important that we conserve it. There are so many wonderful benefits such as supporting us in food, water, materials etc. and if we take that away to build houses, we will not all survive."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is what sustains us all. I love the natural beauty of my local environment\n\nBuild on brown sites, convert and repurposed disused offices.\n\nIf we don't it will harm everyone's future"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nOur natural environment is so important for our health and wellbeing,  both physical and mental. We should be protecting biodiversity and our wildlife for future generations.\n\nEnsure existing housing is used effectively and nog left vacant mist of the year. Charge full council tax for vacant/partially vacant homes to help deter AirBNB and 2nd/3rd/4th home ownership. Free up existing housing rather than building. Ensure any new builds are visually fitting for the area ... There are some appalling designs out there! Plant trees on new estates and Ensure new homes have natural gardens. Ban artificial grass. Protect green belt land and hedgerows. Make it easier to dump rubbish so we have less fly tipping.\n\nTo protect our wildlife and ensure a good quality if life for local residents. To reduce health issues associated with poor housing. To prevent the loss of biodiversity. To protect our countryside for future generations."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature is important locally as somewhere to go for fresh air, exercise and stress management.  I walk in the Forest every day.  It’s important also to preserve the areas we have as they are so few.\n\nOrganised litter collections in wildlife areas, more signs for people not to leave rubbish, trail signposting for walks, community herb gardens. Protection of ancient woodlands and trees.\n\nThe destruction of local habitat by developers means the loss of wildlife, green areas and insects.  If the animals (like hedgehogs) have nowhere to go they will just disappear.  Would it be better develop existing and derelict housing?"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe all need easy access to nature for good mental health. Feeling connected to nature is very important for wellbeing and once it’s lost it difficult or impossible to replace. Nature provides a buffer against stress and negativity allowing people to balance difficulty. It reduces antisocial behaviour and allows people to have gratitude for their environment.\n\nTo ensure that all development is balanced with nature allowing communities easy access to nature and green places. It’s also critical that we have larger wild areas not just marginal green islands which squeezes wildlife into smaller and smaller green pockets becomes trapped within their green islands.\n\nMore and more diversity is being lost all the time. We need to ensure that existing species are protected and their environments protected for future generations. This is especially true for trees that help reduce the impact of global warming and soften the development of urban spaces"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nGreen spaces helps mental health\n\nMaintained open spaces including suds\n\nImportant for everyone's mental health"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI feel better when I am surrounded by nature. Good for health to have open spaces.\n\nHave a special budget allocated to nature reserves.\n\nFor the wellbeing of all people, we need to be a part of nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIncorporating the natural environment into developments will improve the health and wellbeing of the residents\n\nStipulate optimum sustainability in the design of new developments..both the buildings themselves and the associated curtilage\n\nIndividual health and wellbeing. Retaining and using the natural capital will provide greater efficiency and cost effectiveness over the medium to long term"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt's vital on so many levels - wildlife habitat, survival of flaura and fauna, green spaces to just chill in and take in the beauty of nature, vital for mental health.\n\nCreate more wetlands, stop cutting down hedgerows and trees, use brown sites for development,  there are plenty of those.\n\nBecause without nature, there will be no life!"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe should protect the  natural environment for the wildlife but also the benefits that come from such an environment eg supports mental health, supports general health overall, clean air, supports endangered species including insect population, declining bee population …  the natural environment is the reason why many individuals have stayed or moved to the Cotswolds. If the natural environment slowly disappears then the appeal will also disappear\n\nStop building on green spaces and force developers to build on brown land. Stop creating precedent for developing on once protected land on the green belt\n\nNew developments should be minimal and in keeping with the location and natural surroundings. The lack of infrastructure cannot support large developments and negatively impacts the existing community and the wildlife. We have seen so much wildlife disappear or get injured due to more cars on the road due to increased population and disappearing hedges and ancient trees"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nA healthy and vibrant natural environment is important for the well-being of everyone and everything in the naturally world.\n\nMore areas set aside for wild plants, insects and animals.\n\nDomestic and commercial development can devastate the wild environment.  It needs to be planned and executed very carefully in order to minimise this damage"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nMaintaining and protecting our natural environment is so important for our community. It ensures we all have access to natural spaces, improve mental and physical well-being. It means cleaner air. Can protect against flooding (still a major issue in Gloucestershire as seen in the winter of 2023/24). Nature underpins our very existence - if we don’t protect it locally, we will lose it. More green spaces could also encourage more cycling and walking, helping people see a safe, healthy alternative to car travel. The sheer number of cars parked at my child's school gates and nearby roads makes my heart sink each morning. I'd love people to feel they had a safe, car-free green route in their community in order to get to school or work but sadly this clearly isn't the case at present\n\nI'd love to see more initiatives that encourage people to get involved in 'greening' their streets and local communities. Many of us have lost touch with nature, so help teaching people about planting and growing in a sustainable way to best promote nature - even in tiny places - would be fantastic\n\nIf nature is promoted and at the heart of a new development, it makes that area a more pleasant place to live in and can give people more pride in where they live, and look after their community"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nHumans are just one  part of natural biodiversity. As those who exploit natural environments the most, we need to keep that damage to a minimum, so that nature can flourish alongside us.\n\nThe natural environment soothes and calms me in an increasingly busy,  urban world.\n\nWe need new houses,  but  more use should be made of brown field sites before building on fields.  Every new estate should include green spaces and wildlife corridors so that existing wildlife is not threatened by development.\n\nWiping out wildlife when a new estate is built is a loss to the whole area.  Populations become fragmented and may disappear altogether.  We are only beginning to understand how ecosystems work on the micro scale,  so don't really know what impact might be until it is too late.  This includes plant as well as animal life."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nClimate change is a global problem that a single person feels is out of their control. If we all focus on improving our own patch it will make a huge difference!\n\nI suggest group litter picks, ensuring farmers leave wild patches and hedgerows around their field, encouraging more of a plant based diet, encouraging school kids to engage with plants and insects to spark their passion for it.\n\nClean energy systems such as solar panels, heat pumps and electric cars must be encouraged to protect our local environment! Clean air, reduced noise pollution etc means healthier wildlife and healthier lives for us in the community."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt's important to wildlife and to people\n\nTo stop building on it and stop illegal fox hunting.\n\nIf we don't it will all disappear."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature is vital for human health and happiness. The more we have, the better off we are.\n\nInclude mini wetlands in new builds; bird boxes on houses; leave grass areas to grow and plant wildflowers; install nature corridors to connect wild animals.\n\nWe still need development including new housing so it's important that we make sure any new development is as nature friendly as possible rather than just not having any. People and nature should be able to coexist."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment has saved me in the darkest of times and I want to help protect it for me and the people and animals that I love.\n\nSome ideas would be Litter picking for fun, cleaning up rivers so they can be enjoyed by people and nature, encouraging more ponds, Renewables and hedgehog highways\n\nI would like to not cause further harm, and preferably leave the world in a better place than when I was brought up into the world"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI guide local people on nature walks and hikes to improve their physical, emotional and mental wellbeing. Plus raise awareness of the importance of protection natural landscapes. I want to ensure that children and grandchildren get the same opportunity.\n\nRaise more awareness of the benefits of creating a deeper more personal relationship with the natural world.\n\nHumans are nature so what we do to nature we ultimately do to ourselves. By learning to live in harmony with nature we can learn to live in harmony with each other."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural beauty of the Cotswolds and other parts of Gloucestershire attracts visitors and improves our quality of life. It absorbs carbon dioxide and produces the oxygen we breathe. It also sustains food production we rely on.\n\nCouncils could take action. Cut verges and grass areas less often - save money and stop killing insects. Embrace rewilding and ecotourism. Create more wetlands to trap carbon and become peaceful leisure areas. Use trees and beavers to reduce flood risks.\n\nThe UK is seriously nature depleted despite the general population loving the natural world. This contradiction lies in the few wanting to profit at the expense of the many by using natures resources and not paying the true cost. Developers are in that category and they need to change and start valuing nature not stealing from it.\n\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is all our futures\n\nListen, hear the wind in the trees. Do not be intimidated by the requirement for development without full consultation.\n\nOur grandchildren’s well being."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI love my area of the Forest of Dean and having the natural world right on my doorstep, but we are noticing huge swathes of forest being cleared. There are few really old trees left in the woods, the ash dieback is meaning vast areas need to be cleared, on top of the clearing done for commercial gain. The dogs can’t go in the water any more due to the risk of spreading disease to our native crayfish which are dying out. I’m noticing people being reluctant to allow native plants and wildflowers to grow in their garden in favour of weed killer sprayed barren lawns. In my own garden we have lots of hedges and a pond and native plants-in this small area, we can visibly see the difference small changes make-hedgehogs are frequently seen in our garden, as are bats. Small changes can make a massive difference. I’m concerned about the use of neonicotinoids in our agriculture. Our local school is setting up an organic allotment and trying to teach children that they can grow food themselves without pesticides.\n\nWe need to be caring for our soil and banning pesticides and chemical fertilisers. We should be installing wildlife bridges to allow wildlife to cross without danger from the roads. We should be building spaces for bats and swallows in our new homes and taking more care to follow through on protections for nature. There should be nature corridors planned in for developments and holes in fences to allow creatures to move around. Humane solutions for pest control should be used wherever possible to prevent the poisoning of owls, foxes and other apex predators.\n\nWhen there is a tree protection order on a tree, there should be significant fines for cutting it down as my experience is that developers chop first and apologise after.\n\nWe need public information campaigns about why people need to care for wildlife and the dangers of using poisonous chemicals as most people prioritise “neatness” over the health of our wildlife.\n\nWe cannot afford to lose more biodiversity. People complain about the deforestation of the rainforests, but the reality is that we deforested our country long ago and we need to be replenishing it.\n\nLet’s make nature a priority in our planning and policies. With the right support we can turn the tide in the UK and create a future where we live in harmony alongside nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe need to make more space for the natural world in all our lives for everybody\n\nPut the environmental considerations first in all decision making\n\nWe need to think and plan for future generations."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is one of the most important contributing factors to good mental health in people.\n\nIf you don’t then the long term effects could be catastrophic to nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNatural environments are important for everyone’s mental health. Developing areas into a concrete jungle reduces mental well-being and also reduces wildlife corridors especially the destruction of hedgerows which we have witnessed in our local area.\n\nStop developers randomly destroying trees and hedgerows and instead making them develop around nature.\n\nAsking developers to include swift nestboxes when building houses.\n\nDestruction of habitat reduces or even destroys species that are all part of the natural food chain."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature allows us to enjoy the beauty of the countryside and its inhabitants. However, the flora and fauna are being endangered as a result of urban developments. We need to protect our heritage for generations to come.\n\nConsult key groups responsible for maintaining and nurturing nature in the early stages of  planned developments.\n\nIf we don’t look after our nature then once gone, it’s gone forever."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nnature needs protecting and its good for our health too\n\nKeep spaces for wildlife\n\nGood mental health"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt provides a space for recreation to help with mental health, as well as igniting awe and inspiration in those who stop and look.\n\nEstablish local nature reserves. Provide mandatory educational programs for primary school children to understand the importance in preserving biodiversity and the environment.\n\nBecause as the population increases, we have no choice but to encroach into wild spaces so this must be done with great consideration in order to preserve wildlife and habitats for future generations."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt provides a place where one can relax and also exercise.\n\nThe natural environment needs to thrive. Without it, we, along with nearly all species will die out. Gloucester, Cheltenham and Tewkesbury councils need to jointly declare a nature emergency.\n\nWhere there are green spaces, make them nature friendly. Plant trees and hedgerows. Reduce mowing and allow meadows to develop instead of keeping mono-cuture grassland. Stop building on green spaces. Instead encourage building companies to use brownfield sites.\n\nDevelopment can trash nature. The UK is one of the most biodiversity depleted countries in the world. Housing is a huge issue and we need a lot more of it so we need to combine nature and housing in a harmonious way."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is essential for well being.\n\nMore trees. Less verge cutting. Developers should pay for biodiversity uplift.\n\nBecause if it dies, we die."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe need to preserve and find more ways to add the natural environment to our surroundings.\n\nMake sure Developers plant trees, hedges, open spaces for children.\n\nBecause it enables people to be proud of their environment and want to preserve and add to it."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe are dependent on nature - it is important both in itself and because people need it, for food and for wellbeing.\n\nStop destroying it for housing on floodplain that will only cause more problems.  Use brownfield sites for housing.  Tackle empty properties.  Make planting plans for underused land in towns and cities.  Stop mowing verges so much.  Make sure that next time the contract for green space maintenance is renewed it goes to someone who understands nature and has the right equipment to care for low mow areas.\n\nDevelopment that isn't in harmony causes problems for both people and nature. Flooding especially but also loss of nature impacts food production and wellbeing.\n\nWe can't keep acting as if this doesn't matter.  We are facing two crises with respect to our relationship to nature, we need to take this seriously alongside the climate crisis."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is so important that we protect our natural environment for our wildlife’s future and our health and wellbeing\n\nMore wildlife connectivity, retaining the existing trees and hedgerows and designing around them.  Standards to include all fencing to be hedgehog friendly, primary roads to have wildlife routes underground.  Plant larger specimen of trees.  More street trees to create avenues and wildlife corridors.  Keep houses away from existing woodlands\n\nNature should come above development and we work around it and incorporate it in the design. We all like to be surrounded by nature so the design should be built around nature.  All developments should be part of the Building with Nature scheme"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe have a duty to protect and look after our natural environment. Looking after nature in turn looks after us\n\nUse brown field sites rather than develop green field sites. Redevelop high street shops for flats and apartments so that there would be life in them rather than looking sad\n\nWe need areas for leisure as well as housing. I also believe we should live in harmony with nature not destroy it."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nPromotes good Mental wellbeing, for future generations to have as a valuable natural resource, promotes thriving healthy wildlife and increased biodiversity. To increase a crucial co-dependence between nature and people.  A lot of people are becoming detached from nature, which is wrong.\n\nEarmark council land or private landowners to plant trees, stop building housing estates in rural environments. Build more flats and provide allotments instead of carving up farmland etc. Encourage Parish councils to find pockets of land to plant for the future and provide them with trees to plant. Offer community woodland schemes.\n\nBuild wetlands and more nature spaces in every community.\n\nOffer nature-based workshops to education the local population about the importance of nature.\n\nDevelopments dictate the mental well-being of the people who live there. They create the environments for people to live therefore nature should be actively promoted and enhanced for both parties to coexistence. They need to plan for the future security of the natural spaces around developments and protect that land for the future and not allow it to ever be built on again. Future security is crucial."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBecause we are nature. We are not separate from nature. Without a full thriving ecosystem our days are numbered.\n\nReduce building on green field sites leading to loss of hedgerows and trees. Increase use of run down and brown field sites for building and green development.\n\nAs above. Our physical and mental wellbeing is dependent on being part of the natural world. We don't have the right to destroy other animals', birds', and insects' habitats for our benefit."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature is essential for our health & wellbeing, and we have a duty of care to the wildlife that call Gloucestershire home\n\nHedgerow planting, hedgehog highways, native woodland protection, stricter protection on mature trees, rich grassy verges, wildflower meadows\n\nA healthy natural world is the only thing protecting humans from catastrophic events in the future - we have seen the negative impacts already, and the huge loss of biodiversity directly impacts climate change"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is vital for wellbeing and enjoyment of flora and fauna is so important for the future.\n\nEach and every development must be legally bound to plant trees and hedgerows which will form corridors for wildlife. These corridors must then link to each development to form a permanent corridor for wildlife to thrive.\n\nFor the enjoyment of flora and fauna and wellbeing of everyone who will live in these developments."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature Restoration is essential for the entirety of our UK/GB, please?\n\nAll brownfield previously used lands must be utilised for all housing and commercial development, with as little as possible, preferably none at all of our sadly reducing nature and green spaces.\n\nDeclare a Nature Emergency to work in harmony with your Climate Emergency Declarations, to protect your beautiful areas, please?"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment is so important to preserve for the residents of Cheltenham as it promotes good mental health and wellbeing and provides spaces for wildlife to survive and thrive which is good for all of us\n\nThe good health and wellbeing effects the economy of the town by ensuring low sickness levels which impacts the use of our local health system for the better and contributes to a thriving economy which benefits everyone\n\nThis is why it is so important that Cheltenham Borough Council signs up to the agreement\n\nMaintaining good relationships with Gloucestershire Wildlife Trust and other similar organisations and to agree on mutually beneficial arrangements when planning infrastructure projects such as the improvements to Junction 10 M5 and the expansion of housing in the locality\n\nThis project will especially have a great impact on wild spaces in Cheltenham\n\nIt’s very important that spaces are preserved for wildlife in this area\n\nNature is so important for the environment and it’s positive influence on preventing global warming and providing positive benefits for everyone’s health and wellbeing being\n\nChoices made now will effect this in the next 15 years and beyond"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI care about ALL the inhabitants (not just human) of the planet, the country and the county we live in. Please properly respect all the AONB and SSSI classifications. Nature will fight back if we don't ultimately prioritise it - it already is, eg with floods, epidemics, and wildfires."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNot only does it help offset our carbon footprints, it also provides the serenity we need to look after our own wellbeing. The increased flooding seen in the local area also would benefit from more trees and wild areas, as housing development has only meant more pressure on water systems and increased flooding as a result.\n\nLocal community orchards and accessible serene areas of woodland walks within local towns, to reduce the need to drive to get to areas of wildlife.  We all need to reduce our carbon footprint, so having these areas on our doorstep is vital.  Also ensuring adequate drainage systems from road water, to ensure road runoff goes into formal drainage, not into wild water ways.\n\nNew housing and building should be done on already built sites where possible, and factoring in local infrastructure capacity.  Eg. Fairford water system is already in dire straits with sewage pollution and narrow roads and new housing developments casing more flood damage.  New housing should be in areas where infrastructure capacity is able to cope or where there is space to put more infrastructure without destroying areas of natural importance.  More woodland areas and open spaces are important, along with increased hedgerows and wildflower areas to heighten mental spirits. Get local community involved so people feel responsible for their home areas. Offer wildflower seeds to residents or offer areas residents can plant trees or vegetation, giving them the responsibility of maintenence.. like an extended garden. It will save council funds of maintaining it and will bring the community residents together.\n\nNature is of great benefit to our society, with plants and trees absorbing our carbon emissions and peat bogs and plants helping to reduce flooding.   Root infrastructures help keep soil in place to ensure soil isn't washed away.  Hedgerows should be planted alongside roads and should be left to grow thicker and fuller to ensure the natural defence system."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWalking in my local area, significantly helps with my mental health, I suffer from PTSD and being in and around nature keeps me calm and healthy. I also like photography and capturing local wildlife, I have seen myself the decline in the last few years, mostly due to pollution.\n\nI once went for my usual walk along the Longborough road towards Moreton in Marsh and was shocked at the amount of rubbish along the hedges and ditches, I contacted Cotswolds council and they did send a lorry out to collect some of it, I then gathered neighbours to help me litter pick. But it is still a major problem. I would like the council to have green space litter lorries GPLLs to help collect rubbish from roadsides and not just on main roads but also country roads. Unfortunately putting cctv on country roads will never be possible and we will never get on top of litteres, which I think mainly comes from delivery drivers. The rubbish gathering in areas where I've seen they park up for breaks. It's severely affecting out wildlife. Have seen it with my own eyes and the smell of pollution from roadside ditches. I can easily gather a regular group to litter pick however this is not enough to keep on top of it.\n\nDevelopment actually makes me sad, building companies and builders and traders don't actually care about the local wildlife, they only care about their income. The green spaces that are left around developments are not cared for, to encourage wildlife back again. Vast grass spaces with no flora or fauna. When developments are being built, why can't the building companies also work harder on the green spaces? Plant more seeds, create ponds? Plant trees? If we continue to develop housing in the usual way, wildlife will decline even more."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature is an asset that has to be protected at all costs for, obviously, habitats for wildlife but also for people's wellbeing. It is imperative we look after our natural environments for future generations to enjoy. They are such an important legacy.\n\nTo clean our rivers to protect and encourage wildlife, and keep them clean by bringing in stronger legislation that actually works to encourage farmers and industry to use other means to clean their sites without any pollutants entering any waterways in proximity to them. And do far more litter picking in the countryside but also put forward incentives for local communities to look after and cherish their areas by teaching their kids to take rubbish home with them. Peer pressure is so important.\n\nIf developers don't work with local communities and their natural surroundings then I believe any new housing developments are doomed. Councils must look at their brown sites and any infrastructure needed for new housing. As far as new roads etc. are concerned, why do we need more and wider roads when car use is being discouraged? Freight should be discouraged from using roads to using the railways. There was an incentive for this once but I don't know what happened to it. Developers should be rewarded for working in harmony with nature and given due recognition."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBy working with nature, and wildlife it promotes a much healthy, calmer space, where people can come together.\n\nBuild on brown sites, incorporate green areas, green roofs, eg. bus stops rain gardens, solar power on roofs.\n\nWe need nature, to help reduce our carbon footprint, building need to be responsible for the long term benefit if people and nature and the planet."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nConnection to nature is key to mental health and physical health. We are currently in a climate emergency and need to protect as much nature as possible.\n\nStop building houses on green belt, stop cutting down trees and focus on preserving and planting green spaces\n\nBecause without it we are just living in a concrete jungle. The council needs to stop building on land which is destroying the local environment"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is vital that nature is supported .To maintain biodiversity.This also maintains a good enviroment for the human population to have access to nature .It is good for well being.\n\nMaintain green areas that are meaninful for nature.Plantings that will develop into a sustainable habitat.\n\nIt is vital that meaningful designs of development include habitats for nature and that they are maintained in a conservational manner"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe started a campaign in our village to improve wildlife habitats and protect our environment\n\nEncourage communities to start their own “Go Wild “ projects\n\nTo preserve habitats, create wildlife corridors, encourage more birds, butterflies and insects. Plant native trees and wildflowers . Run workshops eg making bug hotels, bird boxes, create a nature reserve, do walks and talks in your area to make people aware of environmental concerns."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nTo refresh the soul!\n\nStop building on flood plains. Stop ripping up hedgerows.\n\nToo many species are endangered, we need to find options instead of building on greenbelt."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBiodiversity is vital to our survival as a species, food production, mental wellbeing and oh the right of other animals to live on this planet too\n\nStop building on green belt, make better mixed use on brown field and disused. Tax second homes much more. Reduce stamp duty( 75% of it comes from a few square miles in London) encourage downsizing by single occupancies so that we have to build fewer houses.\n\nFirstly we do not have the right to remove nature but secondly, has anyone seen the flooding and devastation that comes from this approach? There are flood planes for a reason. We must respect and work together with nature for us to be able to have a future."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nFor my mental health and for the future of the planet and humanity...\n\nEssential swift bricks in new builds. Stop destruction of important hedgerows and mature trees.\n\nSimple, planet and human survival..."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nMarsh land south of bourton on The water\n\nFunding to allow for late cut hay/silage and  help towards electric fencing/cctv camera/sat tags\n\nLast known remaining curlew population in the Cotswold hills. consisting of 2/3 pairs. Curlews have been a part of the Cotswold hills for hundreds of years. We are a small team of farmers and volunteers trying to keep them going. The last 5 years we have installed electric fences. Under guidance from the BTO ."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is important for my mental health and I believe for others also.\n\nCouncillors should be made aware of all the existing areas, both natural and created, that support our nature. It would help them understand the importance of them.\n\nIt takes a relatively short time to create new developments but years and years to recreate habitats lost."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe are not somehow separate from the 'natural environment'. We are part of it. We depend upon it for our food, and we depend on biodiversity in ways that are not yet fully understood but are becoming more and more apparent. Our actions have already started a process of significant climate change which is negatively impacting everyone's lives. We can and must slow down such changes - further change is not inevitable and we can mitigate damage if we act quickly.\n\nCouncils need to protect green spaces and work with wildlife trusts and other organisations to ensure green corridors are retained or created to prevent further loss of biodiversity.\n\nWe must keep development in harmony with nature. Otherwise we exacerbate biodiversity loss. In addition for our own sense of well being we need some sense of our connection with the natural world, of which we are a part."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nFor peace , for escape , for learning to live together\n\nProper areas that are protected\n\nMental , physical wellbeing"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt's essential for my survival and to maintain the bio diversity\n\nPlant more tress, create more green and waterscapes.\n\nDevelopments in the wrong place could destroy the earth"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe live in a flood area and yet the Council still approve houses being built on the flood plain. This year has proved how foolish that is - nature has been unable to cope!\n\nRescind the approvals for more housing off the A38. Allow the floodplain to recover.\n\nLoss of habitat and natural flood runoff seriously affects all areas of nature. Currently development  takes no consideration of nature. There are no parks or wild areas put aside in the current developments in our area"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe are one of the most depleted countries when it comes to habitat loss and losing or at risk of losing the wonderful animals and fauna that we should cherish. We need to do so much more to stop the pollution of our waterways, restore lost habitats and enrich our soils to ensure that we can provide sufficient and sustainable food whilst allowing  nature to flourish. Our mental and physical health benefits significantly from a healthy environment and as a community we must come together to play our part in protecting it for future generations\n\nTake action to clear up waterways and littering especially on highways. Be more\n\nmindful of when verges, hedgerows are cut, ensure schools do more, ensure planning applications have their environmental impact at the forefront of decision making and where approved that plans include beneficial green spaces and planting, wildlife corridors, that\n\nall new housing developments have built in swift/swallow/housemartin homes, that councils work closely with Wildlife trusts and environmental charities to ensure their plans for the future align."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nEveryone needs green space to enjoy nature and protect wildlife.  Our green space in Gloucester is shrinking.\n\nBuild on only brown sites, increase number of trees to help with flooding.\n\nOnce green fields/wildlife areas are gone, they’ve gone."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe need animals and birds we need open spaces for people's well being.\n\nBuild sustainably Build with thought and the climate\n\nOur planet is interconnected. Break the links at our peril"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nSpaces to walk, engage with nature and positive mental health\n\nPromote the importance of nature\n\nWithout nature, we can't function as a species"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature provides so very much including positive mental health, physical exercise and connections to plants and animals. Going outdoors provides a positive and enriching experience which is free and Vitamin D too!\n\nStop building on flood plains now!\n\nOnce a landscape is built upon it is gone forever including the fauna and flora.  Destroyed"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is important for everyone, we need to preserve and protect the natural world in order to give a better future to not just nature but also future generations\n\nMake sure that all new developments have to preserve sections of land in order to protect the existing ecosystems.  Utilising areas to improve access to nature.\n\nWe need to co exist with nature otherwise we will all suffer the consequences.  This means considering the nature order instead of just focusing on making as much money as possible regardless of the consequences"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBecause we all rely on it our for our own health, wellbeing and community. Everything else is secondary.\n\nBetter housing plans, protection of wetlands and open spaces, citizen science.\n\nBecause it can't not! There's too much short-termism and corruption in development for nature to be given a fair chance."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment we have is so precious. The wild and open spaces in our local environment currently allow for the survival of wildlife. We are lucky enough to have hedgehogs, badgers and foxes visiting our suburban environment. However, the results of my RSPB garden birdwatch, suggested that we have fewer birds visiting our garden than most.\n\nKeep wildlife corridors and wild spaces. For example, the stretch of the Honeybourne Line that is currently left wild provides a great wildlife environment as do the wilder edges to Wymans Brook. People could be encouraged to include hedgehog friendly fencing, which includes small gaps for hedgehogs to pass through. We could discourage people from paving over their gardens and covering them with AstroTurf. Wildflower spaces in parks and on roundabouts are great. Let's encourage more environmentally friendly forms of transport. Let's make sure wildlife is considered with every new housing development, making sure that wildlife spaces are included. Residents can be encouraged to record and protect wildlife. Wildlife lovers will be keen to do this.\n\nIf we don't consider the natural environment when development takes place, then our ecosystems will become unbalanced. We will lose yet more of our native wildlife and diversity. The benefits of the natural environment are increasingly being acknowledged for both our physical and mental well-being. Green spaces also help combat climate change."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment has been fundamental for my mental health, it makes us all better able to cope with modern life, it is uplifting and a source of great inspiration for our family. It also protects human life on Earth!\n\nI often think that I would be happy to garden patches of land near me. Or create a garden for wildlife somewhere. But people don’t know where to start and where they are ‘allowed’ to do things like that. I would harness (most) people’s inclination to look after what is near them.\n\nWell if we don’t balance our needs with the natural environment then we will be destroying the land for future generations. Plus I could never live anywhere without a sense of the natural world. People are happier and life is better for people when they are surrounded by the beauty of the natural world."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nPrioritising natural environment space is vital as we live in symbiosis with the land and the natural life that nurtures it. Soil health decline affects the roots, the stability of the land, the quality of harvests, the density of green and the quality of human health.\n\nDelegate available areas to integrate permaculture plots.\n\nSustainability starts right under our feet. We can become more self sufficient by integrating permaculture plots anywhere we can in society. This is the natural order we must return to in order to prosper in green independence, nature has rights to be protected."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nFor a reasonable quality of life\n\nBetter maintenance of roadside hedges & drainage etc\n\nThe natural world forms the basis for all life.No insects ,no birds & so on."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt creates wildlife corridors and green space for people to enjoy for wellbeing and recreation\n\nensuring that new developments have spaces around them for wildlife such as hedgehog holes and swift boxes. joining patches of trees to make corridors. All aspects must increase biodiversity and be overseen by experts\n\nTo increase biodiversity and replace what has been lost so we are always making a positive impact on wildlife"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nPlants and wildlife are all part of the planet; humans - and the planet - cannot survive without a healthy balance of them. Being able to have nature around you is also beneficial to your soul and general well-being.\n\nDon’t be swayed by the idea of short-term gain (especially financial gain). Consider large green ‘corridors’ in housing developments, decent-sized gardens and plenty of trees. Don’t overbuild so that rain has nowhere to be absorbed into.\n\nBecause if we don’t maintain a good balance there will be problems, possibly leading to the downfall of the human race."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI love the outdoors and am an avid nature lover. I’m also an ecology and environmental science student :)\n\nTo keep designated green spaces\n\nIncorporate trees and plants into housing developments\n\nWe need nature to survive!! - health, food"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is vital for health and wellbeing\n\nSwift boxes and bat boxes on new buildings.  Hedgerows not fences. New wildlife Ponds.  Uncut verges.\n\nIt is very destructive usually with no obligation for nature conservation."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nGeneral health and wellbeing for all\n\nProtect spaces where nature can flourish bringing in flor, insects and animals\n\nDepleting nature for development is counterproductive for the communities that they are building."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI want my children to grow up in a lush and diverse countryside, and not to succumb to a concrete jungle. For mental and physical health and longevity and sustainability.\n\nKeep strictly away from greenbelt when developing large new housing estates. Keep urban areas away from rural as much as possible, whilst planting more trees in urban areas and raising awareness of the current nature crisis.\n\nFor our mental and physical wellbeing, now and in the future."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nAdequate housing, infrastructure and a healthy local economy are all important but this should not be achieved at the expense of nature. Integrating sufficient space for nature enhances the environment and enriches people's lives.\n\nEspecially at a time when more people appear, especially youngsters, to struggle with mental health issues, it is important to create a positive and healthy environment.\n\nThe Council needs to  incentivise developers and businesses to take positive steps to protect nature. At the planning stage, more consideration should be given to the potential impact on nature. Also, more could be done to educate people what they can do to help nature in their area. Some people move from inner-city areas to the outskirts and people do not necessarily realise that they are sharing their space with nature.\n\nHousing and industrial developments in the area seem to have had a negative impact on nature. Nature needs to be taken into account adequately when planning permissions are granted. New developments need to be more nature friendly and it is important to create larger, connected corridors for nature. With recent developments in the area the space for nature has been getting smaller and more fragmented. In order to protect nature for the future this needs to change. At the Gloucester Business Park there are several large plots which provide a habitat for wildlife, but, unfortunately, planning permission has been granted and these nature-friendly areas are likely to disappear in the near future. This is a great shame. Especially at the edge of developments, there should be a softer line between nature and development, to enable nature to thrive. Equally, I often pass through residential parts of Gloucester and wonder whether people there ever get the opportunity to experience wildlife."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\ngood for all the animals and plants that live in nature - want to keep them safe\n\ndon’t build houses on green spaces\n\nimportant to sustain nature, so we aren’t contributing to the decrease of species of plants / animals"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nHaving natural environments is good for peoples mental health and quality of air. It also gives wildlife a place to live, which is massively important. The natural places of this county is what makes it a great place to live - it’s what keeps people, particularly the younger generation, living here."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nProtecting natural spaces is vital to protecting my physical and mental health. It is also vital to preserve insects which are vital to pollinate crops and therefore food supply.\n\nEnsure we protect nature reserves and acquire more woodland and wild spaces. Encourage and allow young people access to nature.\n\nWe rely on nature for so much: as well as pollination, air quality, soil health and biodiversity relies on healthy nature and all this are vital for humans and animals alike."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt’s important for the ecosystem. We need clear cleaned rivers. It would also help to tackle climate change\n\nTo make sure that people respect nature for example providing bins to throw rubbish. To give information about wildlife and respect wild animals and their habitat\n\nBecause otherwise we destroy the nature and the ecosystem"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nOur lives are getting busier daily. Having green spaces where nature like bees, bettles, birds and hedgehogs can live keeps us in balance and provides places for people to relax and reconnect.\n\nAll new developments should be built with nature and the environment in mind. I.e ensuring mature trees are kept and not cut down (as shown many new tries just die) this helps to ensure shade to keep human s and animals cool. Ensure that green spaces have areas for nature that are unmowed, fenced off where necessary and planted with plants that can be left to go wild. We need spaces where foxes and hedgehogs etc can live and the councils must fully protect them at all costs.  Hedgehog fences in all developments, ensuring there are nature highways to allow animals to cross busy roads etc but ensuring these are properly joined together. I would love to see the council crowdfunding for things like solar panels for schools etc this helps to decarbonise with funding help from parents and family members etc. We are teaching our children that there is a climate emergency but doing nothing to address this or show them that we care. We must do this and let children lead too  - electric car charging points should be installed in school car parks to help teachers etc too.\n\nWithout nature we know that humans suffer. Less trees makes the world warmer , we keep just paving over grass and using awful plastic grass that gets too hot to walk on and makes flooding worse. We must look after nature not just so we can live in the increasingly hot climate but also for our own wellbeing. With less bees, increased flooding etc everything will cost more £. The more we invest now the less this cost will be in the longer term. The council should declare a climate emergency and really get Gloucestershire to stop using fossil fuels by really going big on pushing heat pumps, electric cars etc, designing town and city centres to be better for wildlife and promoting ways to help wildlife"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBecause nature and the environment are vital to a thriving society. Greenery helps keep the very air we breathe clean. No flowers/plants; no bees. No need; no crop pollination. It’s madness to carry on destroying habitats.\n\nForce developers to act far more responsibly than they are. They’re being allowed to get away with murder.  Raise standards and refuse permission unless far more creative and enriching environments are going to be created. Stop allowing them to replace trees and plants with unsuitable but cheap and easy species. Relocate wildlife. Provide shelters and protection for them\n\nThey’re currently in conflict and that needs to stop. With pursuation and insistence, standards can be driven higher which will benefit us all."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBecause without nature and the natural world we would not be here. We need it despite destroying it and because of human actions, it REALLY needs us.\n\nTurn any abandoned spaces, especially in towns and urban areas into pocket wildspaces, with wildlife hedges, wildflower meadows, recycled planters with herbs and wildflowers, insect hotels, bat boxes and bird boxes. That is what I am doing at my workplace in Tetbury, where I am turning the small piece of land owned by the library into a wildspace. We have already planted 120 trees from the Woodland Trust and have another 90 saplings coming in less than two weeks to finish our double wildlife hedges. The biodiversity around the library has shot up in the few years I've been doing this.\n\nBecause apart from the fact that trees and hedges improve air quality, prevent flooding and generally improve all areas including urban places, having green spaces also has been proven to to massively improve mental health. We need nature and green spaces, room for trees, wildflowers, hedges, areas of grass, even mini ponds, all so necessary for a healthy life."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environmet is vital for our well being and survival.\n\nMandatory large green useable spaces in new housing estates. More trees in towns. Brown field sites, all to have mandatory shared large garden for residents if it is to be converted to flats.\n\nIt is vital for humanity and well being on so many fundamental levels."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI feel it goes beyond just me and the community and is a global issue. Saving our ecosystems and creating a better world should be everyone's focus and priority\n\nall new builds should have inbuilt solar panels, water collection systems to use rain water to flush toilets.\n\ni have a real concern that when new developments occur, whilst trees and some habitats are maintained, after thought isn't given to other areas. for example, where i live houses have been built near multiple ponds - the ponds have been kept but no thought has been given to the migratory species of amphibians who make their way there every year only to be squashed on all the roads surrounding the pond"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nSpecies decline. Lived here for 35 years. Used to have healthy garden populations of bats, hedgehogs, toads and frogs. All now gone or in serious reduction despite gardening to encourage wildlife\n\nSTOP GARDEN INFILL! Planning has been granted by Stroud District council for 2 detached houses in Our neighbours Edwardian orchard despite multiple objections on environmental grounds. The result will be a further drastic decline in local diversity\n\nDevelopment does little to address the biodiversity losses incurred. We educate to encourage wildlife in our gardens which seems pointless in my experience with our “green” planning authority."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt promotes a healthier and less stressful lifestyle.\n\nTo try and ensure that 'corridors' between existing natural areas are kept in place. It is important that, wherever possible, the open areas do not become isolated islands within large new industrial/urban developments.\n\nThis is particularly relevant in the context of Flood Plains. Too many in Gloucestershire have been built on already, causing urban flooding to become a common annual event in some areas such that small businesses and properties become uninsurable ,"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe natural environment was here first! Having access to it is essential for physical and mental wellbeing for all members of the community.\n\nRestrict eradication of the natural environment as much as possible by not allowing so much new housing to be built, cutting down trees, etc\n\nTo preserve the natural environment for current & future generations"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nResidents need to see trees and hear birds in the town\n\nprovide more car free zones to give space for people to walk in\n\nPreserve the Georgian character and style with parks"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nfor well being and health\n\nhave green spaces and nature reserves.  also encourage wild borders on roads and assist allotment schemes.\n\nFor the preservation of the environment and ultimately us as well"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBees and insects helps pollinate our wild plants, my fruit and vegetables and fruit trees. We need bees to survive, they are our guardian angels.\n\nI hope to see more bees and insects, as well as more wildlife friendly green areas. It makes me and my family happy to see more trees, flowers, ponds, lakes. We enjoy daily walks amongst nature which is good for our health and wellbeing and looks beautiful.\n\nPlus I have an allotment plot, as I only have a small garden, so I can grow my own food. The more pollinating insects, the better.\n\nBy NOT cutting all the grass and  planting more wild flowers. It will bring many more bees and pollinating insects in the green areas and in gardens plus less grass and verge cutting.\n\nHaving more parks with wild flowers, trees & lakes. Where nature can thrive.\n\nErect more signs in these areas saying how this will help more wildlife and bees and how good it is for the environment and mental health. Educating people with the reasons why \"natural\" is best.\n\nAlso informing schools to teach children about nature, wild flowers and wildlife and why it's very important for everyone's future.\n\nRe-wilding is getting more popular in lots of towns, cities and villages to encourage more wildlife and pollinators.\n\nIt would help contribute towards 'sucking up' carbon and pollution, help reduce flooding and water run-off, meaning it is good for the environment and climate change, along with planting more trees and replacing ones that have been cut down.\n\nEvery housing estate should have a wildlife area next to it, along with trees, wild flowers, dog walking area. Plus an allotment as gardens are getting smaller.\n\nRewilding is the way forward for all councils, for our and all children's future. Including the future of wildlife, which keeps the planet alive.\n"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe only have one planet\n\nEnsure sustainable development\n\nBecause we are not somehow separate from nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nEverybody needs a green space they can escape to.\n\nLess destroying of our habitat to build houses.\n\nBecause then, everyone benefits."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is vital to protect the biodiversity of our local area. We are already very depleted and need to preserve and enhance what is left. Spending time in the natural environment is good for all of us.\n\nPromote and maintain wildlife corridors so that the wildlife can make the best use of the land available.\n\nIf it doesn't we will lose even more of the wildlife which we share the planet with."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nAll life is a part the natural environment and it helps everyone in the community to be as near as possible to the natural environment both mentally and physically\n\nOpen a dialogue involving the local and national environment groups and ask them their opinion\n\nAll living things are interconnected and need to be in harmony with each other"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nAs humans, we are part of our environment, to mess it up messes us up!\n\nDeveloping in sustainable ways which allow nature to thrive.\n\nAs mentioned above, when nature gets sick, we get sick."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt makes life worth living!\n\nImprove public transport to reduce the need for private cars, invest in green energy, sustainable local food production, planting to increase biodiversity\n\nOur future depends on it"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBy caring for and engendering local environments we are contributing to the bigger picture of helping the planet.\n\nBudgets are tight, but integrating environmental considerations right at the beginning of planning will always be more cost effective than trying to make changes later.\n\nIt is so much easier to plan short term, and kick the ball down the road, but changes to our climate and its consequences don't give us that time."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nOnly by protecting nature can we preserve our food supply, mental health and address climate change\n\nSupport farmers more to use environmentally friendly farming practices\n\nGovernment house building targets are ambitious due to housing need, developers must play their part in designing in real protections and biodiversity enhancements"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt's importance to mental health should not be understated. We need to protect the valuable ecosystem for the future, and combat the climate crisis\n\nStop building new developments! There are many abandoned neighbourhoods elsewhere that need investment and could be redeveloped instead\n\nMental health and keeping the planer alive. It's beyond belief that we are aware of what is happening to this plant and we keep going."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe need to protect wildlife habitats more than ever before, not just cover huge areas in buildings. Wildlife obviously needs the natural environment.  People also do. Being in nature is very important for mental health. Poor mental health is an increasing problem.\n\nThe Councils must protect the AONB and, where houses are being built, they must allocate large areas for wildlife."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWithout nature humanity will suffer and people will die. We all rely on animals in our day to day lives but many do not know this because they are too far removed - especially in urban places.\n\nSpend the money and force developers to revitalise city spaces and public transport.  DO NOT build on green land. Once developed it will NEVER be green again. When it's gone its gone. The UK is an island, not going to magically get more green land from somewhere. Don't build on flood plains! The water has to have a place to do and down stream isn't the option as it just makes others flood more. Leave open land as wet land and to flood.\n\nDevelopment MUST make room for anything displaced AND be built to last. So many developers waste resources, rush builds and make it so work has to be re-done. Developments should require holes in walls for hedgehogs. Bat boxes, bird houses, green corridors MUST be priority. People should have permeable parking spaces for water and no-one should be allowed to just pave their garden. Soil is vital and under valued life force of the planet. It needs to be left to do it's job too."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWhen I travel through the country I am shocked by the scale of new housing going up on prime agricultural land. Where does the wildlife go?  What about the mature trees and hedgerows?\n\nConsider buying farmland that is under threat of being built on and return it to eco- friendly standards. This has been done by Sheffield City Council which recently declared a Nature Emergency, with the local Wildlife Trust buying the land with donations from members. The land will be allowed to revert to rough, wet upland pasture to draw in such birds as plovers, curlews etc.  If this action had not happened the land would eventually have been bought for housing, though not suitable for the purpose.\n\nUnless there is an ecologist working for the building company, it’s unlikely there will be any harmony with nature. It MUST be strongly worded in all planning regulations and with regular in person, on site checks which are built into planning applications and paid for by the contractor."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nAs a person with unseen and physical disabilities, being able to be in contact with Nature is vital to maintaining my health and wellbeing. But as well as personal and sociological benefits, I believe we have a moral duty to protect Nature and the countryside from further devastation, ha habitat loss and human encroachment as we are not the only species on the planet and we have a responsibility to wild animals and organisms,  failing to do so will not only cause ecological collapse but our own demise too.\n\nPrevent housing developments from stealing more land from Nature, and enforcing much stricter penalties for organisations in the area (water boards, farmers, developers etc) who pollute rivers and soils and have a negative impact on the nature in their area.\n\nBecause sustainability is the only way forward,  that means we need greater diversity and a much more collaborative approach to everything."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nbecause its life\n\nput more area aside from development\n\nbecause we are both created by god"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nFor its own sake\n\n20% plus gain of nature for all New developments\n\nIf nature dies we all die"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe world needs more nature therefore we need to do everything to support it\n\nwherever possible water should be diverted into large ponds with reeds for use by farmers when weather is dry and might help with flooding\n\nhumans are covering more space then ever and continuing to spread leaving less for wildlife we have to do everything we can"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nTo ensure our wildlife is protected and in turn protect us.\n\nCreate more common ponds to harbour invertebrates and ensure rainwater runoff does not flood roads, buildings etc.\n\nTo enable the human communities interact favourably with nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature can’t speak for itself or fight against human activity\n\nLeave the natural world alone and let it breathe\n\nThis should speak for itself. We can’t keep taking without giving back."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe depend on it!\n\nLet nature do its thing, and let more people enjoy it.\n\nIt's a win win for nature and people!"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is vital for health\n\nDo not use dangerous chemicals that destroy plants and animals\n\nTo save this planet"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe are nature. There is so much joy to be had from being in nature - it is so important for our mental health. The connection with nature and humans is already so broken, it is vital that we do everything we can to nurture the natural world around us.\n\nAll further development must be in harmony with nature. DO NOT BUILD ON ANY MORE FLOOD PLAINS!!!!!\n\nMore green open spaces in residential areas; more hedgerows and trees;  bat and bird boxes; muchless light pollution; the list is endless, let's face it!\n\nNature is already so fragile, any further developments must work in harmony with it or there will be no going back."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBecause it is essential everyone's wellbeing and happiness\n\nSet aside land for nature; stop using pesticides, especially on grass verges; allow wild areas to develop; plant a lot more trees; reduce building on farmland; build on brownfield sites; encourage developers to convert existing buildings rather than tearing them down and starting again - hugely wasteful of finite materials - the world needs to use what it already has far more\n\nBecause life will be so much poorer without nature and it is already suffering so badly"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBecause without it being in good health we, the community suffers from ill health. Air and water pollution give us heart, lung disease and cancers\n\npush back against  supporting planning in favour of development (houses and businesses)\n\nTo avoid water and air pollution"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNo nature, no joy. We all saw how nature and the outdoors helped us through the pandemic. Too many green spaces are being built on, and woodlands too. Nature cannot take this onslaught anymore.\n\nPlease view Gloucestershire Wildlife Trust's comments, as I agree with those."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt's declining so fast every bit of habitat is now so important. Without having this connection we are nothing.\n\nCreate more habitats. Let verges grow. Stop cutting so many trees down.  Plant trees. Encourage hedgerows to be better kept. Stop building on green spaces. Put wildlife friendly boxes and holes in fences in all new builds.\n\nBecause too much habitat is being destroyed and this has to be addressed. You are taking from the countryside and not giving anything back but concrete."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nDeeply important for us all to have access to natural spaces,  for human wellbeing and mental health. This is well documented and researched. And we are fundamentally an intrinsic part of nature, and without it we will not be able to survive.\n\nAgroforestry Research Trust-Martin Crawford.\nWales off grid policy, One Planet Development.\nNot building on flood plains.\nPlanting more trees and replacing hedgerows in flood plains will help reduce the flow of water through the landscape, slow it down, and reduce the loss of top soil that gets washed into the rivers.\n\nIt is fundamentally vital, as we are nature and are deeply interdependent with the rest of nature for our survival."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIts incredibly important to look after the natural environment for future generations.\n\nmore joined up planning with conservationists like myself to ensure that waterways , soils, trees and ecosystems in general are protected and enhanced when developing and building goes on.  Also solar farms should be on the roofs of industrial estates and not in fields.\n\nit improves everyone's quality of life , and often improving the environment can save money in the long run anyways for example wetlands reducing flooding . Trees reducing soil erosion , shade, etc. I am curently studying Social and therapeutic horticulture and I am a qualified garden designer. i would very much like to get involved with planning of public spaces for the improvement of biodiversity and accessibility for everyone. If anyone reading this thinks that might be a possibility then please do get in touch with me."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nHow to put my feelings into words? Nature is everything to me. My solace when the world is too much, my medicine, my religion. I'm a neurodivergent woman and I feel at my best when I'm in nature. Seeing it being destroyed for the greed of others distresses me.\n\nStop building new estates on farm lands. Use old lands with derelict buildings and create oasis for the wildlife, re-wild some areas.\n\nBecause we are part of nature and we need it. And animals need it more than us. By developing mindlessly we are destroying the natural habitat of many species and we live on an island. When is this going to stop? When we don't have any single field left?"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nAside from the benefits nature has on human wellbeing, it's a vital thing in and of itself, and something that should be cherished and nurtured by people.\n\nPut nature high on the list of considerations when the council is carrying out or proposing works - housing, roads, play areas etc. More wildflower meadows on patches of un-used strips of land (i.e large roundabouts, verges etc) would be good too. Intertwine nature and the environment with our community!\n\nNature and the environment is already under threat from ever-growing populations, and many peoples' indifference or carelessness towards nature. Boosting nature in development and planning can at least *try* to fix this by not thinking of nature as something that's in the way, or something that's to be exploited, removed or pushed aside for human development."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe are causing so much damage to our environment at the moment and seeing issues such as flooding and storms. I want my children to have a happy life and that involves protecting the world they live in. We can do this on a local basis.\n\nIt would be great to see better safe cycle routes and protect nature from building projects. It’s sad to see green spaces diminishing.\n\nNature is good for all of us and vital for longer term survival. We must do all that we can to protect nature."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNatural environment is essential to all communities, it helps preserve the wildlife and flora and fauna to give balance between built up area and natural areas.\n\nIt helps mental health to have beautiful scenery\n\nHaving wardens/volunteers to maintain and promote theses areas\n\nWe cannot continue to just build new developments without a thought to its natural habitat and wildlife"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nFor my children’s future\n\nMake sure we keep our very important green spaces\n\nIt’s vital for all our futures"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe need wild spaces for  walking, exercise, appreciation of surroundings and well being.\n\nIncorporate habitats on new housing estates, parks, new builds for bats birds and reptiles\n\nSo many wild areas have been built on and been lost, they need restoring."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nHow can it not be?\n\nPrioritise brown field sites\n\nAvoid infill\n\nPreserve the Green Belt\n\nWe're living with a Human made, potential extinction with the natural environment sacrificed  to the supposed needs of commerce"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\njust walking on the school run and hearing bird song,  lifts my spirits. it improves my mental health.\n\nbetter, safer bike routes linking key spots (shops, drs, schools, parks etc). more trees, hedges, benches & less concrete. more bike stands to secure your bike outside every parade of shops. better (ie more frequent/ cheaper) bus services incl P&R,  to encourage people to use cars less.\n\ntrees give us Oxygen! not cars. more trees planted, better air quality, as well as less noise pollution."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\n- Wildlife and nature are critical for physical and mental health.\n- We should urgently re-plant felled, diseased ash trees with resistant species, establish green corridors along cycle paths, mandate swift / swallow nesting bricks / gables for all new buildings, introduce managed pond / wetland refuges in flood overflow areas.\n- Otherwise Mother Nature will eventually take us down. We are the custodians of the planet; development for us alone will cost us all. There is no doubt we have a climate emergency that will destroy society if we do not act."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe job that i do is extremely stressful. Having the beautiful green spaces around my locality brings a chance to decompress. A moment to be at one with the natural world, improving my mental health and giving a space to think, breathe and sit in the great outdoors. With the world climate changing these spaces are more important than ever to ensure we help the situation. Removing them only adds to the already massive issue regarding global warming.\n\nEnsure significant green natural world spaces are factored into any future development. Listen to the people!\n\nAs more and more development takes place, that brings more people, more carbon footprints, which in turn adds to the catatrophic issues as a world we face in relation to climate change. Working in harmony with nature ensures we dont add to this issue. It protects different species that may be facing difficulty. Natures equilibrium needs to be balanced, we must listen to the world!"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt's vital we reverse nature's decline, recognising we can play a vital part locally in what is a global emergency.\n\nRestore and protect peatlands (I believe we have some in the county), continue work to reduce car use, protect green spaces (especially those identified as being vital links in the wild network across the County so that species rich areas don't get isolated).\n\nWe rely entirely upon nature for everything, including at the local level (pollinators for our crops, water supply, clean air, mental health)"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nI have helped an international animal charity for good part of my working life and know that the natural environment is extremely important for wildlife, bio diversity and also the well being of people to access easily.\n\nWildlife needs more than islands of green spaces they need to be able to roam freely and thrive it is important to maintain large areas of green spaces so the eco systems are maintained. That species can co exist. Humans are moving too much into wildlife spaces and disrupting the eco systems - we need to maintain large spaces connected to one another to thrive.\n\nBecause the more you take away from the natural environment the increase in decline of wildlife and it will be gone forever. It is not good enough to build a housing estate and tick a box to say we have a green space with a playground on and some trees planted  so thats ok insects will thrive - its not addressing the total eco system."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe depletion in nature and wildlife in the UK is unprecedented. We cannot survive without nature. For every hedge that is destroyed; every tree that is felled the impact on wildlife is tremendous. It is not ok for developers to take a little bit here - a little bit there as this turns into huge losses.\n\nDevelopers must be made to develop brownfield sites. They are wealthy enough to take these sites on - in my area there are wide areas of ex mining sites but these are not built on - no one wants to take them on preferring green field sites.\n\nEcologists inspecting potential sites should be independent to the developers and planning departments and should be answerable to an independent organisation/charity and report to the public.\n\nI want my grandchildren to grow up appreciating wildlife - the benefits asssociated with enjoying nature on our mental / physical health cannot be underestimated.\n\nWe are all part of the wider cycle of life. If we destroy nature we destroy the fundamental building blocks of life. We won’t last long as a human race if we continue to destroy our habitat."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe live in a beautiful part of the country which I specifically cherish for its unique outdoor spaces such as the commons and hills and valleys. I have children who I want to instill a love of nature and living here is important for them to explore the natural environment. I also studied conservation at university so it is something I personally feel passionate about.\n\nI think its important to get local schools, nurseries and businesses involved in helping to preserve, protect and most importantly to enjoy our landscape. Tree planting, surveying, litter picking. Other team building activities or exercise classes in our local wild places would promote the importance and maybe get people involved more in conservation.\n\nFamily days are also a great way in the holidays to get people outdoors.\n\nIn terms of design for new buildings, I'd like to see more paths nd cycleways through small green areas and connectivity to wider green spaces for wildlife. We live in Eastcombe and Bussage border where there are some great paths connecting the schools with grassy areas. This attracted us to live here and this type of design and consideration should be included in plans but with more emphasis on wildlife habitats.\n\nNature offers us a break from the stress of busy days. It's hugely important for mental health. Outdoor spaces within developments are a great place for families as well as people in the wider communities to connect and are a great opportunity to create habitats to help biodiversity rather than to hinder it."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is important to have natural areas to allow people to escape from the stresses of everyday life. It's also important for the natural wildlife to have a place to thrive and survive.\n\nI think it would be good to introduce some wildflower patches in the more built up areas of the county to support bees and other insects\n\nOur wildlife is already in crisis. We need to make sure we are incorporating it in development to make sure we are allowing nature and wildlife to rebuild and benefit our community"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nHealth and wellbeing. Sustainability. Green belt areas should be protected for future generations.\n\nCommunity gardens and allotments. Garden education in schools and colleges. Gardening for hospital patients or NHS mental health outreach programmes.\n\nSustainability and, basically, to halt the damage already done by human race since the industrial revolution - but more so in the past fifty years. Scary."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nLiving in a city but coming from the countryside, having green spaces around us will help improve air pollution and the overall beauty of the city. Green spaces are great for walking as well as clearing your head on a mental health day. With more and more building developments arising, more green spaces are needed now more than ever\n\nConservation in the green spaces. Allow the grass to grow longer to encourage insects and bees. Gives species places to hide and play and survive as well as hunt for food.\n\nBecause development areas can be the make or break for some species. Less places to live = decline of species."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNature has an integral role in all our lives - it is not only important for our native wildlife, but it's also important for our communities and individuals. Places of nature give individuals and communities opportunity to get outside; learn about nature and care for it, it's also beneficial for health - shown by doctors now prescribing nature; it's also a fantastic place to meet and be social - be it a dog walk with a friends, a 'walking meeting' where you go for a walk in nature and tune into an office meeting while walking. foraging is also a great way to engage with nature. All of these activities can bring communities together to make them a more happy and caring place to live\n\nPut more support and funding into groups who are interested in nature. Local communities need to have training and opportunities to learn how to support the local wildlife. This can be done through parks, nature reserves, public footpaths - even verges and hedges on peoples doors steps.\nAccessibility is important for this opportunity - engaging in streets, businesses, schools -  Also engaging in different groups - going to them. 'Accessibility' in all stems of the word is paramount.  A lot of people care for our wild and green spaces it's just getting the word and understanding out there.\n\nMaybe more use of social media platforms to 'advertise' nature opportunities locally. All of this needs funding. If you get the local communities engaged and caring this could save a lot more than you spend!\n\n'Brown sites' and 'unused areas' are wild life havens. We need to stop humans seeing these sites as 'only used' if humans are making use of the space. More wildlife - thinking badgers, foxes and otters are being seen and moving into towns (cheltenham!) which shows their space is being over taken by more and more humans.\n\nSurveys needs to be carried out *shared and publicised* to the public . We need to not be afraid to give the public complex information. We also need it more accessible and promoted."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nEngaging and experiencing nature is imperative for human beings.\n\nConsider not building on flood plains, keep Green areas for public exploration amongst new builds, provide parks and cycling paths, plant trees and create ponds / lakes\n\nHumans can destress\n\nWild life can survive, trees can help our planet."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt brings a little bit of joy and an escape and it should be something we protect and look after just like it's doing for us.\n\nAsk people for ideas and be more involved. Take nature into a bigger consideration when making decisions. All nature, big and small.\n\nBoth development and nature are important and necessary, and they should be balanced without harm to nature and still developing what is needed."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nin times of changing climate e need all biodirversity we can get. getting nature is also important for people struggling with health issues\n\nmore protections for estabilshed woodlands rather than just planting more hedges and trees\n\nits important for all of our health and for our kids education"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBecause the survival of nature equates the the survival of all beings on this planet.\n\nMore construction on vacant spaces within towns and cities and less expansion into field sites."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBecause Gloucester has green lungs and is loved due to its being a small city with beautiful countryside\n\nLeave flood plains alone. Leave what was known as green belt alone. They want to build houses to attract new people for work but they won't want to come here because we are changing Gloucestershire not for the better. It will be like so many other areas\n\nTo stop it disappearing forever"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt feeds the soul by seeing greenery from trees, hearing the sound of running water and delighting in   wildlife in all its forms.  It can help us distress by taking our mind off our problems.\n\nOur town and city centres have declined with out of town developments.  This needs to reverse.  I see this, probably controversially, by building upwards.  People need somewhere to live, so apartments are the solution.  More people can live on a smaller footprint.  This saves what little unbuilt land is left for nature.  Flooding is a problem that is getting worse as fields are built on like around Twigworth.  We need decent flood planes especially along the Horsebere brook.\n\nIf we live in concentrated areas then public transport is more feasible without buses having to wend their way through distant villages.  I think we should consider an underground rail linking Cheltenham, Gloucester and possibly Tewkesbury.\n\nNature cleans the air and filters the water.  It also needs space to grow.  By having more trees we can lessen the impact of global warming, from cooling the summer heat and holding back water before it reaches our towns which are usually built downstream."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nBeing surrounded by a thriving natural environment is vital for the well-being of all members of my local community. It is not only mentally beneficial to be surrounded by such a positive natural environment but also physically and from a climate perspective also.\n\nIt is vital for our local councils to recognise the importantly of these natural environments and their major benefits through declaring a nature emergency, in order to protect them for future generations to come.\n\nAll too often we sadly see developers and local councils falling to grasp the important intrinsic value of these natural spaces within local communities. By failing to carefully weigh up financial gain against the value of working to preserve and restore areas of natural benefit to all, we risk loosing one of our greatest assets in being able to deliver a better future for our children and beyond."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nWe breath it, need it for mental health, a world with no nature will kill us. Our surrounding area has threat of lots of new development, and a river running through it.\n\nLive monitoring of river and air quality locally. By the hour. To make sure factories are not polluting and people make informed decisions about impact of driving everywhere.\n\nBuild up not along, ie flats not houses, take less space. People will have to get used to a flat if no kids or small family.\n\nUse dead space for building before fields and nature.\n\nTo build without harm to the environment and make balanced decisions"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nNo community is a community without integrating it into nature for our well being as well as being responsible guardians of our natural world.\n\nUse brown field sites, old shops, industrial units first, ensure that any re-use/construction incorporates green areas to maintain and support biodiversity.  Stop allowing big development companies to control the design including such small gardens for so called family (luxury) homes\n\nQuite simply because we are nothing without our connection to nature"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIt is important for wildlife to have a range of habitats and for people to have space to enjoy nature, open spaces and easy access from built up areas to  countryside.\n\nI live in Tewkesbury which has a number of spaces within the town for additional housing.  Farmers fields all around the town are being built on so that we are losing open green space, adding to flood risk and slowly losing farm land which should be feeding the nation.\n\nPeople and wildlife all need to live together to keep a balance in an already crowded world."]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nThe Forest of Dean is an amazing area for wildlife, alongside a working forest.  It would be a travesty to put further stress on the local environment with new housing developments in or nearby, especially when there is limited infrastructure.\n\nBuild on brownfield sites; create more wildlife verges; reduce the speed limit through the Forest to protect wildlife; implement a campaign against litter; increase education in schools about the importance of the environment to the future health of the planet.\n\nFrom Science Direct: 'By 2009, the UN General Assembly of 192 member countries was “convinced that humanity can and should live in harmony with nature.”'"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nIts protection is vital now because of the over development taking place to provide mainly holiday and second homes.\n\nChange in taxation encouraging residential long term lets and penalising self catering b&b\n\nWhen its gone its gone just like happened to the area around London"]
["I am commenting in support of Gloucestershire Wildlife Trust’s call for Gloucester City, Cheltenham Borough and Tewkesbury Borough Councils to declare a nature emergency, to provide new momentum for and better integration of nature into the Strategic and Local Plan. It is crucial that the SLP ensures development will work in harmony with nature, that developers are held to account over effective mitigation for impact on nature and that the three local authorities lead the way in combatting the nature crisis.\n\nfor wildlife\n\ndo not build on green belt\n\nfor our future"]