Cleve Park Appeal – TRAPP’D Representation - DRAFTPINS Appeal reference: APP/P0119/W/17/3182296

SGC Planning reference: PT16/3565/O

Application site address: Cleve Park, land at junction of Morton Way and Grovesend Road, Thornbury, South Gloucestershire BS35 2HX

Submitted by: Colin Gardner, Old Orchard Cottage, Buckover, Wotton-Under-Edge, GL12 8DX.

E-mail: colind.gardner@btinternet.com

1. Introduction and Summary

I am instructed to respond to this appeal on behalf of TRAPP’D (Thornbury Residents Against Poorly Planned Development). We are an Action Group formed from residents of Thornbury who are alarmed at the impact of the speed and quantum of housing development in and around Thornbury with more than 300 registered supporters. We are not against development per se, but we are against poorly planned development.

We are against the appeal proposals for the reasons given by the LPA, and in addition because the development is contrary to the following policies set out in the South Gloucestershire Local Plan Core Strategy:

CS15 and CS33 – Distribution of houses CS32 and CS9 – Character, quality and distinctiveness of the environment CS7 – Traffic and Congestion

2. Background to the Development

The context is critical to our objection. TRAPP’D came into being one year ago because of deep concern by residents about the cumulative impact of housing development on the character and infrastructure of our historic market town. Thornbury lies at the edge of the greenbelt to the north of Bristol, and has become a prime target for speculative development, such as this one from Welbeck Strategic Land. The map below illustrates the problem:

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370 houses by Bovis (aka “land south of Gloucester road” PT17/2006/O): Revised Plans submitted 9 Oct. These plans go right through the middle of SGC’s proposed “Green Gap”

500 houses at Park Farm

(being built)

125 houses at Post Farm (being built)

300 houses at Thornbury Fields

(being built)

130 houses at Ainscough (aka “land west of Gloucester Road”

PT16/4774/O): Now approved

3000 houses at Buckover

150 houses – “land at Crossways” in call for

sites

This application

Taken in sequence of approval there has been a 25% growth in houses since 2011, either built, under construction, or approved prior to this appeal. If this appeal is accepted it would take the cumulative increase to 32%, with more to follow:

Housing growth in Thornbury

+25%

+32%

This scale of development contradicts the Core Strategy vision for Thornbury (see Appendix A) which beginson page 147 by listing the town’s strengths including “proximity to attractive countryside and areas of open space” which is therefore protected by policy CS32 (see Appendix B) which says that development will “ensure that the current character and setting of Thornbury’s open spaces, which contribute strongly to the attractiveness of Thornbury, is maintained and enhanced”, and by CS33 (see Appendix C) which states that “proposals will need to demonstrate that the development would not adversely impact upon the historic environment and its setting”.

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Within the context of that vision, CS33 considered that “the preferred location for a housing opportunity is to the north of Thornbury [note: this application is diametrically opposite to that location] where potential exists for up to 500 dwellings”. This was Park Farm shown in green on the map above.

CS33 also stated that a further site for 300 houses had been allocated to meet the Council’s five-year land supply (this is “Thornbury Fields” shown in pink on the map) – essentially code for the fact that the Council lost on appeal before the Core Strategy had been adopted. Hence the Core Strategy overall made provision for 800 houses, as shown in CS15(see Appendix D).

Other sites in pink on the map above – Post Farm, Alexander Workwear, former council offices – have all since been approved with building underway, and the Ainscough development gained outline approval subject to agreement of S106 contributions in August.

With each planning application the applicant argues that the incremental impact of the proposed development on services and congestion is not significant. However, it is the cumulative impact that really matters. As a community we welcome people into the town, but even though only around a quarter of the developments prior to Cleve Park are now occupied we believe that we can show that the harm caused by these developments on infrastructure services and traffic congestion is already very significant.

As of the start of this year relatively few of the recent approvals have been built out – South Gloucestershire’s Annual Monitoring Report 2016 show an estimated 316 completions to the end of 2016/17. The number of dwelling actually sold and occupied will be slightly less, so for the purpose of assessing the impact on infrastructure we are assuming that by this point less than 300 of the 1,225 shown above prior to Cleve Park will have been occupied.

Compare that to Employment - since adoption of the Core Strategy in December 2013 South Gloucestershire has recorded in its employment land survey for Thornbury a net loss of 348 jobs. This does not include the Council Offices where some 300 people used to be employed. Note that this deterioration in employment sites is due to the Local Authority ignoring Policy CS12 which safeguarded both Alexandra and the Council Offices as employment locations, and instead allowed yet more housing. With falling employment and rising numbers of houses, Thornbury is being transformed from an historic market town to a dormitory satellite development of Bristol, with all the implications on things like traffic congestion that go with it.

3. Impact on Services

The appellant commissioned a report in support of the original application on the impact of the proposed development on the town infrastructure “Local facilities assessment for Cleve Park (Carney Green) August 2016” (Appendix E). We have shown that this report was materially inaccurate in several important respects. We believe the most telling of these errors is regarding the GP capacity statistics. We believe the measure of patients per GP is a good bell-weather of strain on a town’s infrastructure because it is a service that everyone needs and can be measured objectively over time and against other locations. We believe the fact that Carney Green falsified this information is a telling admission of a wider problem that the appellant wishes to hide.

An extract from the South Gloucestershire Infrastructure Delivery Plan, published in March 2014, is attached in AppendixF. This report (para 5.5) notes that the standardcapacity within NHS South Gloucestershire is 1,700 patients per GP, and further notes that this is above the national average of 1,520. The table in Appendix 6 of that report then shows the number of patients per GP in each practice, and it is important to note that the number of GPs is correctly based on a measure of full time equivalent GPs (described as the number of WTE GPs in the table) which accords with the NHS England Full Time Equivalent (FTE) definition, being “a standardised measure of the workload of an employed person. This

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measure allows for the work of part-time staff to be converted into an equivalent number of full time staff. It is calculated by dividing the total number of hours worked by staff in a specific staff group by 37.5” . The results for Thornbury are extracted from the table, giving a total of 11.95 FTE GPs and an average of 1,796 patients per GP:

No. GPs (full time equiv) List size

Patients per GP

Thornbury Health Centre - Burney 6.25 9884 1581St Mary Street Surgery 3.03 6749 2227Thornbury Health Centre - Male 2.67 4825 1807Total Thornbury 11.95 21458 1796

At the time of this report it was envisaged that 500 new houses would be delivered in Thornbury, and the report notes that an additional 2 GPs would be required to support this, and also notes that there is a problem with the level of space in the surgeries (para 7.7).

Moving forward to 2017, TRAPP’D requested equivalent data from NHS England, who supplied statistics as at January 2017, showing the number of FTE GPs has actually decreased to 10.11, we understand because of the difficulty in recruiting and retaining GPs, with several now working part time, and the number of patients per GP has risen to 2,090:

No. GPs (full time

equiv) List sizePatients

per GPDr.Foubister & Partners 4.00 8,764 2,191 Dr.Male & Partners (now Streamside surgery) 3.07 5,071 1,652 St.Mary St. Surgery 3.04 7,292 2,399

10.11 21,127 2,090

It should be noted that the list size is virtually unchanged at the start of 2017 when this data was collected, supporting the point made earlier that few of the new houses were occupied by this time. It therefore comes as no surprise to the residents of Thornbury that the normal waiting time for a non-urgent GP appointment has worsened significantly recently, and is now typically around six weeks.

Compare and contrast this picture to the one painted by Carney Green. Para 4.5 concludes that “ Across the threesurgeries,thisequatesto1,510patientsperGP,whichisbelowthe1,700 capacity limit referredto in the 2011 evidence base (NHS South Gloucestershire) within the SouthGloucestershireInfrastructureDeliveryPlan”. This trick was achieved by taking the Health and Social Care Information Centre (HSCIC) list size of 21,136 patients and dividing it by the number of GPs mentioned on the websites at the time (14 in total) to derive this misleading statistic, i.e. by failing to take into account the fact that many of the doctors in Thornbury work part time. Based on this evidence the Case Officer reported to Members in para 5.174 that “t he cumulative increase in population…. should be able to be absorbed by the three existing practices.”

4. Impact on Schools

The Carney Green report on school places does not take into account new developments, stating that “ the full impact of the development[s] cannot be included. This is because the number of children occupying the homes is determined by the developer build out rate which typically spans a ten to 15-year period ”. The comment about a ten to 15-year build out rate is an interesting aside to the case made by the appellant on

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the five-year land supply issue. However, our point here is that the cumulative impact of recent development approvals is thekey issue when looking at the impact on infrastructure, so we have provided below an indication of the school place availability factoring in this element.

965

CapacityCurrent

pupil No.Free

places

Impact of new developments prior

to Cleve Park*Deficit of

placesA: Local Primary Schools

Christ the King Primary 161 138 23Crossways infant school 180Crossways junior school 240Crossways total 420 360 60Gillingstool Primary 210 164 46Manorbrook Primary 198 187 11St Mary's CofE Primary 215 198 17Total (at 7/3/2017) 1204 1047 157 347 (190)

B: Local Secondary School (within 3 mile distance)Castle School (incl 6th form) 1733 1654 79 174 (95)

* based on South Gloucestershire Council 's Developer's guide: Formula of 36 pupils per 100 houses for Primary and 18 pupils per 100 houses for Secondary schools

new houses, yet to be occupied

There are 5 junior and primary schools in Thornbury, and one senior school that also has a sixth form. There is another secondary school in Alveston, but this has been excluding as it is more than three miles from the development, which means that the Council would have to provide a free bus service for this school. The table below is based on school places as at March 2017 showing junior and primary school free places of 157, and senior school places of 79. We have then factored in an assumption of the impact of 965 homes still to be built or occupied prior to Cleve Park, using the formula from South Gloucestershire’s Developers guide (used in the Carney Green report – see page 22). This shows the surplus turning into a deficit prior to adding the impact of Cleve park which, as the Carney Green reports says, would be expecting to add a further 126 primary school pupils and 63 secondary school pupils. It is not clear how, or even whether, these places could be accommodated, but certainly at the very least the s106 contribution should take into account the fact that there will be no free spaces in any school by the time this development becomes occupied.

5. Impact on Congestion

Thornbury is very poorly served for non-car transportation. There is no railway station and bus services available take so long to get to and from the popular places of work that they are rarely used. We attach an e-mail (Appendix E) from Emma Blackham, South Gloucestershire Council’s interim Head of Transport and Strategic Projects. This e-mail was obtained through a freedom of information request and relates to a different development, but nevertheless her comment under bullet point 1 relates equally to Cleve Park where she says “Given the [Public Transport] journey times from Thornbury are already prohibitively long extending them further to serve 3,000 really isn’t good enough”. This e-mail was clearly never intended for use outside of the Council (see comments further down the e-mail about issues being “ fudged”) and is therefore unquestionably a genuine professional assessment of the situation.

Moreover, the shortcomings of the bus service as a practical alternative to commuting by car is underlined by a survey from TRAPP’D taken at the Leisure Centre bus stop (being the last passenger pick up point from

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Thornbury) on Wednesday 18th October 2017. Commencing at 07.00 hrs and terminating at 09.00 hrs. During this period there were six separate busses (the first at 07.09 hrs the last at 08.52 hrs) they carried a total of 101 passengers. All of the buses were single decker (34 or 35 seater models) and the passenger numbers were as follows:-

(i) 77. @ 07.09 hrs 5 passengers. (ii) 79. @ 07.11 hrs 12 passengers. (iii) 79. @ 07.42 hrs 31 passengers (included 2 school uniformed schoolchildren) (iv) 78. @ 08.07 hrs 30 passengers. (v) 77. @ 08.09 hrs 9 passengers (vi) 79. @ 08 .32 hrs 14 passengers.

It can therefore be shown that at peak commuting time in this survey the buses were only 41% full. At the same time, based on the current South Gloucestershire Council estimate [June 2016] of 2,185 cars leaving Thornbury daily between these times, this equates to only 4.5% of the residents commuting by bus.

There is currently no additional employment being created in Thornbury. Since adoption of the Core Strategy in December 2013 South Gloucestershire has recorded in its employment land survey a net loss of 348 jobs. This does not include the Council Offices where some 300 people have now been transferred to Yate. Therefore, we believe we can conclude that anyone moving into the proposed development would be commuting to and from work outside of the town, and would be doing so by car. In other words, Thornbury is becoming a dormitory town, with commuting almost exclusively by private car.

The A38 near Thornbury runs parallel to the M5 between junction 14 and the interchange with the M4, and is the designated strategic relief road for the M5. The A38 is very busy at rush hour on normal days; added to this the occasions when the M5 is busy (almost every Friday and Saturday in Summer) or restricted, then traffic comes to a standstill on this road, typically for between 1 to 3 miles, leading up to the traffic lights at the very junction at the end of Grovesend Road that the proposed development will seek access to:

Alexander Workwear housing development

Cleve Park

Traffic Lights

M5A38

Cars parked along here causes stretches of

hazardous single file traffic on Midland Way

Cars queuing to join A38

Standstill traffic during periods when M5 traffic

heavy or restricted

Morton Way

GrovesendRoad

Access into and out of Thornbury onto the A38 is therefore also very busy at peak times. A further traffic problem has arisen on Midland Way (which is the designated access and egress route for HGV’s to Thornbury’s Trading Estate) following new build on this road (Alexander Workwear).

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This road also has sections of Double Yellow lines to restrict parking, interspaced with permitted parking on one side of the road. When HGV’s access the road, there is insufficient space for an HGV and car to pass each other where cars are parked. It was therefore no surprise that in October two HGVs were involved in an accident where the garden wall was demolished and the corner of the house was damaged.

The main access to the potential Cleve Park Site will be by two entrances off Morton Way.Traffic calming measures will form part of the remedial work associated with pedestrian crossing points. We believe that residents and visitors to the site will need to park along Morton Way and that subsequently Double Yellow parking restrictions will be needed interspaced with permitted parking on one side of the road, as it is on Midland Way, thus recreating the conditions for another serious accident. It should bereadily apparent from this description and the map above that the location of the proposed development is at a “crossroads of congestion”, and will significantly worsen the already poor traffic conditions with resultant delays, adverse health impacts and risk of accidents.

Appendix F shows pictures of the result of the recent accident, of traffic queuing along GrovesendRoad, and of severe congestion affecting the A38 up to the point of the intersection with GrovesendRoad.

The impact of traffic congestion on people’s health and well-being is now well documented amid a realisation that this is a much more serious problem than had previously been appreciated. Core Strategy CS7 (Appendix G) has the aim of “reducing congestion and air pollution by improving accessibility by means other the private car”, and is therefore compromised by this proposed development.

6. Application of the NPPF

The Supreme Court ruling on Richborough destroyed the argument of the overall supremacy of the NPPF. Since then the same court, the ultimate arbiter in the law of the United Kingdom, confirmed and strengthened in a judgment handed down in 30th June 2017 (East Staffordshire Borough Council and the Secretary of State for Communities and Local Government v Barwood Land II LLP) the primacy of a proven 5-year supply of housing sites. In short, if a five-year supply can be demonstrated then development outside of the adopted plan must be refused.

A view has sprung up that there are only two options regarding the level of addition to the objectively ascertained housing demand, namely 5% for day to day vagaries and 20% for persistent under delivery; this is not so. It was considered by the Court of Appeal (Bloor v Secretary of State for Communities Local Government and Hinkley and Bosworth B C). The Court ruled in a judgment handed down 19th March 2014, that the size of the buffer depended on individual circumstances; it is not prescribed by legislation but is instead a matter for those arriving at planning judgments to set such a level as to provide a realistic prospect of achieving the planned supply. It also follows that as circumstances change and variations occur, as they surely will, then the decision makers must also revise the level to attain the requisite number. It is evident that the officers and councilors in considering this development proposal have acted in ignorance of their duties and the appellant’s case rests solely on the performance being so wayward as to justify the addition of 20% uplift in the target. This is not the case; the inspector hearing the Little Stoke appeal accepted that the supply was compliant.

It is a matter of fact that without any addition (buffer), South Gloucestershire has a five-year supply of housing and the only decision to be made is what the level of adjustment is necessary to ensure that the overall requirement will be met in the period of the Local Plan. Clearly 20% is too high at this stage in the plan; the projections commissioned by South Gloucestershire from Mr. T. Cann, MBA Dip (Est Man) FRICS, Senior Director, Residential Development Consulting, BNP Paribas Real Estate, indicate an oversupply will result. We therefore argue that the lower figure in the NPPF is appropriate which confirms the existence of a 5-year supply, which remains the case even with uplift to10%. All of our calculations have been made using South Gloucestershire’s last published performance, but we understand that the situation has

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markedly improved because in an internal document dated 20th July 2017 Mr. P. Conroy, Strategic Planning Policy and Specialist Advice Team Manager advised, “The council has made progress in reducing the extent of the housing supply deficit. Where previously the decision taker may have judged the larger shortfall to be an overriding factor in favour of approval, this position now needs to be re-evaluated as part of the overall planning balance, especially given the fact the council is currently actively engaging through the plan led system on options for the future growth of Thornbury."

The Appellant makes frequent references to the Joint Spatial Strategy which will be examined in public next year and to the overall housing requirement of the Bristol Housing Management Area. For the sake of argument, notwithstanding that the Plan has yet to be proved sound, the enhanced housing provision it contains for both Thornbury and the South Gloucestershire from 2016 to 2036 if added to the calculations show that a five-year supply exists even at the higher 20% addition.

As part of that overall assessment it is material to consider that permission has been given for more than 1,200 new homes in Thornbury since 2013, a 25% increase in dwellings which has not been accompanied by additional education or health provisions. This is a considerable level of new growth for the Town, as it currently stands and is a relevant consideration to the harm versus the benefit of the proposal. Considerable weight should therefore be attributed to this as part of the overall planning balance as it is clear that housing needs of Thornbury and the local area are already being met. Moreover, it is not the role of the planning system to further displace growth that is identified to come forward to address the housing and wider spatial strategy needs of the other parts of the District by building a level of homes over and above which are considered appropriate and commensurate with the objective to achieve balanced and proportionate growth at Thornbury. The adopted Core Strategy identified the appropriate and commensurate level of growth, which has already been exceeded.

NPPF Paragraph 47 directs that where a shortfall exists, sites be “moved forward from later in the plan period”. South Gloucestershire has identified all the sites necessary to comply with its obligations and this proposal is not included and therefore cannot be moved forward. Introducing additional sites will inevitably produce more dwellings than the objectively assessed need demands, as is evidenced by South Gloucestershire’s own documents showing the projected totals increasing way beyond 28,355. This reinforces the conclusion that the Authority is applying an inappropriate level of buffer.

The proponents of boosting the supply of sites within South Gloucestershire all acknowledge that any perceived shortfall is a temporary condition; the Core Strategy will deliver what is required. Again, we quote from Mr Cann’s analysis of the performance: he identifies that it takes typically 33 months before the first dwelling is completed. The applicant is not a house building company, Welbeck’s approach, they tell us on their web site, “Maximises values for freeholders.” They also say in relation to landowners selling directly to builders, “The Welbeck approach is diametrically different, and remains in line with the owner’s best interests throughout. It means the landowner receives highest value .” This approach creates three avenues for delay; first it does not bring additional building resources into play. Second, the bidding and evaluation process can be protracted as the highest profit is pursued. Third, the consequences that may arise from selling to the highest bidder rather than the bidder best equipped to proceed; the buyer could even seek to sell on rather than develop (one of the main causes of the building shortfall elsewhere in South Gloucestershire) or having paid too high a price need to delay delivery and/or renegotiate the detail. The latter has been succinctly summarised by The Guardian: “Landowners sell to developers offering the highest price, who maximise profit by slowly releasing houses onto the market to fuel further price growth, skimping on build quality and affordable housing.”

It is alleged that Cleve Park will make a significant contribution to the housing supply adding considerable weight to the granting of approval, it does not; the 5-year calculation barely changes. References have been made to the Appellants record in timely delivery. Four schemes feature prominently in their publicity of which three have been granted planning approval:

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Manor Close, Henfield, W Sussex, 102 houses received planning March 2014, sold on July 2014, yet to be completed.

Ridgewood Farm, Uckfield, E Sussex, 1,000 houses received planning June 2015. Wealden DC predicts first 50 in 2018/19.

Clevelands, Bishops Cleve, Gloucestershire, 550 houses received planning 2012 sold on in 2014 to Persimmon who have built about 130 dwellings.

It should therefore come as no surprise if the sale of the land takes 2 years and first construction extends well beyond the 33 months referred to by Paribas.

7. The proposed development will cause significant harm to a designated Green Infrastructure and visually important hillside and is inappropriate and inconsistent with the Vision for Thornbury and Policy Objective CS9

The proposed location is outside of the boundary set in the Core Strategy and undermines intent to prevent the town from becoming more lopsided by growing away from town centre. The illustration below is taken from P148 of the Core Strategy:

Location of proposed site

“Visually important hillsides”

Core Strategy 9 (Appendix H) states that any “new development shouldconserve and enhance the character, quality, distinctiveness and amenity of the landscape”. The brown chevrons on the illustration above denote “visually important hillsides”which are designated in the core strategy as significant Green Infrastructure. The proposed developmentdirectly contravenes this policy, and will cause material harm to the visual amenity for the town and from this visually significant hillside, as referred to later.

8. The site is unsustainable in terms of its location to services and thus promotes the use of cars

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The location proposed is also outside of the recommended distances to key services, as can be seen from South Gloucestershire’s chart below (used in Sustainable Access Profiles, and adopted in November 2017 in the Polices Sites and Places Plan – see appendix ?) which shows that even on an ‘as the crow flies’ basis. The proposed location is outside of the radius for all key services, as used in South Gloucestershire’s Sustainable Access Profiles (Appendix I):

Location of proposed site

Distance from town centre:800m

1,200m

2,000m

However, this simple ‘as the crow flies’ indicator is imprecise and understates the real distances. TRAPP’D has therefore undertaken a survey using safe walking routes, measured both from the nearest point of the site and the site centre:

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Facility mode of Travel Distance Travel Distance SAP distance Percentage of SLAmeasurement nearest site entrance central square (site centre)

metres metres metres %Primary Schools.Crossways Junior Chev Drv Surveyor's measuring wheel 841 1,061 2 miles (3128m) * 38%St. Mary’s COE. Chev Drv Surveyor's measuring wheel 1,403 1,623 2 miles (3128m) * 55%Manorbrook Jnr Chev Drv Surveyor's measuring wheel 2,205 2,425 2 miles (3128m) * 80%

Secondary Schools.Castle School Chev Drv Surveyor's measuring wheel 2,365 2,585 3 miles (4827m)* 57%Marlwood Chilt Pk Surveyor's measuring wheel 5,202 5,522 3 miles (4827m)* 120%

Health facilities.Health Centre. Chev Drv Surveyor's measuring wheel 1,803 2,023 800 253%GP. Surgery Chilt Pk Surveyor's measuring wheel 1,684 2,004 800 251%NHS Dentist Chilt Pk Surveyor's measuring wheel 2,037 2,357 800 295%Opticians Chilt Pk Surveyor's measuring wheel 2,056 2,376 800 297%Pharmacies Chev Drv Surveyor's measuring wheel 1,644 1,864 800 233%---“----“---- Chilt Pk Surveyor's measuring wheel 2,067 2,387 800 298%A & E (Hospital). Chilt Pk Car odometer 24,080 24,400 5,000 488%Small Injuries Unit Chilt Pk Car odometer 14,580 14,900 5,000 298%

Town CentresHigh Street Shops Chilt Pk Surveyor's measuring wheel 1,846 2,166 1,200 181%

Other FacilitiesPost Office Chilt Pk Surveyor's measuring wheel 2,042 2,362 800 295%

Meeting Venues. Library Chilt Pk Surveyor's measuring wheel 1,801 2,121 800 265%Community Hall Chilt Pk Surveyor's measuring wheel 1,878 2,198 800 275%Public House Chilt Pk Surveyor's measuring wheel 1,043 1,363 800 170%Convenience shop Chev Drv Surveyor's measuring wheel 1,323 1,543 1,200 129%Convenience shop Chev Drv Surveyor's measuring wheel 1,246 1,466 1,200 122%

* Note: Barton, Grant & Guise# recommend lower l imit of 800m for Primary schools and 1.5km for Secondary schools# In "Shaping Neighborhoods" see appendix J

Site entry (opposite)

With the exception of schools, all facilities are well outside of South Gloucestershire Council’s recommended maximum distances and will result in the private car being the almost exclusive mode of transport for using local services, thus putting further pressure on town congestion and car parking space, which is current at a severe shortage. In the case of schools, Barton, Grant and Guise recommend a lower maximum of 800m and 1,500m for junior and senior schools respectively (we think South Gloucestershire Council has taken their 2 and 3 mile distance from the 1996 Education Act where those distances are quoted to determine where a LA needs to provide a free bus service), and under this measure the proposed site would be beyond the recommended maximum for every type of serviceand is therefore unsustainable as it will promote the use of cars and thus will directly contravene CS7.

8. The proposed building heights are unacceptable and will cause significant harm to the landscape setting of Thornbury and its rural fringe

The Cleve Park proposals include building height parameters for the main body of the site at levels that are considerably higher than any of the other recent developments approved along the rural fringe of Thornbury.

The houses along Morton Way opposite the western boundary of the site are less than 8m tall and are built on land that is considerably lower than the Cleve Park site. The cottages along Hacket Lane to the north-eastern perimeter of the site, including the Listed Building of Hacket House, are also less than 8m tall and again are set down well below the site.

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The applicants Building Heights Parameter (BHP) Plan sets the maximum build heights at 9m for the main body of the 2 storey housing and 12m for the central 3 storey section. The 3 storey section will therefore be up to 4m (50%) taller than the houses along Morton Way opposite this site.

The Cleve Park site is in an elevated position and so much higher than the houses along Morton Way and Hacket Lane and indeed any of the other more recent developments. So, at these height parameters the site will still stand out way above the rest of Thornbury. If you take the centre of the 3 storey zone it lies between the 65m and 69m contours so the ridge line of this section will be 77-81m above datum. The ridges of the housing along Morton Way show on the topographical survey at 68m above datum. The skyline for this development could therefore be some 9 -13m above this.

The sketch below compares the building height and the combined effect, after accounting for site level, on the ridge line with the adjacent houses and other recently consented sites nearby. From this it is very clear that the proposed development, by reason of its height is completely out of character with the town of Thornbury.

Buildings that will be 50% taller than the surrounding housing particularly when accounting for the difference in land levels will be totally out of keeping with the fringe of Thornbury and have an overbearing and detrimental impact on the surrounding area. All other nearby recently consented housing development was consented at substantially lower height, yet this site is on land considerably higher than the entire fringe.

The landscape character for this site is described in the Supplementary Planning Document “South Gloucestershire Landscape and Character Assessment” (SGLCA). This document describes Thornbury’s setting on page 257 as:

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“The topographical bowl within which Thornbury sits, limits the prominence of the town in the wider landscape, by the physical containment formed by the Severn Ridge; the open sided bowl merges with the adjoining Levels landscape to the west. Visually, despite the size of the town, the well treed structure throughout the older areas of the settlement greatly contribute to its integration within the landscape framework of the wider Levels and of the slopes of the ridge, which provide a backdrop to the town”and on page 260 the document states:“The expansion of Thornbury to the north, south and east, has pushed the settlement fringe closer to the Levels and further into the bowl landform defined by the Severn Ridge. The visual expanse of the town is evident within elevated views. However, Thornbury generally sits well in the landscape”

Thornbury’s integration within the landscape framework described in the SGLCA has only been successful because Thornbury’s development thus far has been predominantly 2 storeys with ridges that are set down below the tip of the treed structure referred to.

However, the Cleve Park site, will sit well above this existing treed structure and no amount of additional tree planting is capable of reaching the very tall heights proposed. The key element of Thornbury’s successful integration within its treed structure cannot be carried forward into this proposed development.

The aerial photograph below was taken from the tree line adjacent to Cleve Wood above the site looking down across Cleve Park towards Thornbury and the River Severn. Note St Mary’s Church in Thornbury, St Arilda’s Church at Oldbury-on-Severn and the Severn Bridges, these are all clearly visible from public view points along the upper sections of Hacket Lane and other parts of the Severn Ridge above the Cleve Park site. This photo also shows how Thornbury sits so well in its treed structure and landscape setting. It is clear from this photo how housing at heights that will sit so much higher than the houses opposite this site along Morton Way will not sit at all well in the landscape described in the SGLCA.

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The SGLCA also goes on to set out the Landscape Strategy for the Severn Ridges on page 263 and in this makes a number of landscape objectives which are applicable to this site:

“Ensure long term protection of the character of the ridgeline as a rural backcloth, and the panoramic views across adjacent character areas”

“Conserve the rural character of the visually prominent ridges and hills.” “Any new vertical development should avoid dominating, or visually competing with landmark heritage

assets or undisturbed rural landscapes or skylines in the character area.” “Ensure that new development respects and integrates with the historic pattern of the host landscape

or the settlement pattern of small dispersed hamlets, villages, towns and scattered building groups and reinforces local distinctiveness.”

“Preserve the tranquillity of the landscape, particularly to the north and west of the character area.”

The introduction of development at Cleve Park at the proposed BHP of 9m and 12m goes completely against the strategy outlined because such unprecedented and very tall heights:

• will cause serious harm to the panoramic views from the ridge across the adjacent character areas are completely out of keeping with the rural character of the setting and as such will not conserve the

rural character of the ridge but detract from its visual prominence. will dominate and visually compete with the visually prominent heritage assets including St Mary’s

Church, St Arilda’s Church and the Severn Bridges (see photo above).• will dominate and visually compete with the undisturbed rural landscape and skyline viewed from the

ridge.• do not respect nor integrate with the adjoining rural settlement of the Hackets, nor the housing along

the fringe of Thornbury. They will overshadow and dominate both the Hacket and the housing along Morton Way.

• will intrude into the landscape to the north and west of the Severn Ridge character area. They will be very visible and therefore will dominate not preserve the tranquillity of the landscape.

For this reason, we consider that the Council’s Planning Committee was right and correct to refuse consent. The unprecedented height on land that is elevated above the rest of the town contravenes many of the policies set out in the Core Strategy including CS1 & CS32. This will cause significant and demonstrable harm to the character of Thornbury, its rural fringe including the adjacent designated GI visually significant hillside or scarp which forms part of the Severn Ridges and the edge of the topographical bowl in which Thornbury sits.

9. Conclusion and Summary

We believe we have shown that the Core Strategy remains the applicable policy base against which to assess this proposed development, and on this basis we believe that we have clearly shown the proposal would result in materialand very significant harm to Thornbury in terms of:

the cumulative impact on services and congestion, the site location the site design, particularly in terms of building height

In full knowledge of the 5-year land supply argument, the Development Committee rejected this application by an emphatic [6 votes to 1 against, with 6 abstentions], despite sloppy or deliberately misleading “research” presented to it on the infrastructure implications. Those Members having real local knowledge about the town and the principles laid down for Thornbury in the Core Strategy spoke wisely

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about the harm this development would cause, and silenced all but one of the critics focussed predominantly on the housing arithmetic for the Authority.

On behalf of the residents of Thornbury we call on the Planning Inspector to uphold the wise decision of the Development Committee and reject this appeal.

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