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Winchcombe and SudeleyNeighbourhood Plan:

Environmental Report (November 2015)

This Environmental Report is a companion document to the Winchcombe and Sudeley Neighbourhood Plan. It describes the relevant strategies, plans, policies, data and other evidence that have been taken into account in preparing the pre-submission draft Neighbourhood Plan that the Town Council and Sudeley Parish Meeting Chair have approved for public consultation.

It is the “environmental report” required by the Environmental Assessment of Plans Regulations 2004 and was sent to the formal consultation bodies in early 2014. It was updated to accompany the December 2014 consultation draft neighbourhood plan. That consultation draft was delivered to every household in the two parishes of Winchcombe and Sudeley and thus to all persons who are affected or likely to be affected by, or have an interest in the decisions involved in the assessment and adoption of the Neighbourhood Plan. The covering note drew attention to the fact that there was an updated draft environmental report – available at the Town Clerk’s office and on the Neighbourhood Plan and Town Council websites.

The detailed material following “non-technical summary” describes: the screening process to determine whether the neighbourhood plan is

likely to have significant environmental effects, in consultation with the environmental assessment bodies;

the scoping stage, setting the context and objectives, establishing the baseline and deciding on the scope, again consulting the environmental assessment consultation bodies

developing and refining alternatives and assessing affects before publishing this Environmental Report and consulting the consultation bodies and the public

WINCHCOMBE AND SUDELEY NEIGHBOURHOOD PLAN ENVIRONMENTAL REPORT; September 2015

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Contents

1. Non-technical summary (page 3)

2. Introduction and methodology (page 8) 3. Screening: the overall policy context (page 11)

4. Screening: the environmental and socio-economic factors (page 31)

5. Summary of sustainable development issues and evidence (page 49)

6. Scoping: investigating alternative preferred development sites, especially for impact on protected landscapes (page 54)

7. Scoping: assessing the effects of draft Plan policies (page 62)

8. Final Environmental Statement taking account of responses to the December 2014 consultation version of the Neighbourhood Plan (page 70)

ANNEX European sites Screening Matrix (page 71)


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1. Non-technical summary Introduction This Environmental Report is a companion document to the Winchcombe and Sudeley Neighbourhood Plan. Winchcombe Town Council and the Sudeley Parish meeting decided to prepare such a Plan, under town and country planning legislation, to encourage sustainable development to meet the needs of the local communities – economically, socially and environmentally.

While paying proper regard to national planning guidance and the local development plan policies of Tewkesbury Borough Council (see paragraph 6 for details), the two local councils were keen to put in place a statutory plan to guide where new homes and businesses might be located locally, and to steer public services and new infrastructure. A particular concern was to protect the Area of Outstanding Natural Beauty (AONB) and other land which, if developed in a major way, would unduly damage the setting of that AONB.

This Report describes the relevant strategies, plans, policies, data and other evidence that have been taken into account in preparing the pre-submission draft Neighbourhood Plan that the Town Council and Sudeley Parish Meeting Chair approved for public consultation in December 2014. It has been updated where necessary to reflect later changes in the national and local legislation and policy. As the “environmental report” required by the Environmental Assessment of Plans Regulations 2004, an early draft was sent to the formal consultation bodies in early 2014. It was then updated to accompany the December 2014 consultation draft neighbourhood plan. That consultation draft plan was delivered to every household in the two parishes of Winchcombe and Sudeley and thus to all persons who are affected or likely to be affected by, or have an interest in the decisions involved in the assessment and adoption of the Neighbourhood Plan. The covering note drew attention to the fact that there was an updated draft environmental report – available at the Town Clerk’s office and on the Neighbourhood Plan and Town Council websites. The legal screening requirement: is a Strategic Environmental Assessment needed? A Strategic Environmental Assessment (SEA) is required under European legislation for all plans that are likely to have a significant effect on the environment. This particularly relates to plans that designate sites for development such as the Borough Council’s Local Plan and Neighbourhood Plans produced by parish councils.


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The purpose of SEA is to provide a high level of protection of the environment and to integrate considerations of the environment into the preparation and adoption of plans with a view to promoting sustainable development. The SEA process sets out criteria for assessing the significance of the impact of a plan on the environment. For example, if a plan proposes a housing development it may have an impact on the wildlife of the area or have an impact on landscape. If a significant effect is possible, the assessment requires the consideration of options and for the evaluation of the potential effects on the environment.

The environmental assessment bodies were consulted between December 2013 and February 2014. The results of this consultation are described in the Report and a formal screening opinion was issued to the Town Council on 6 th August 2014 indicating the outcomes of the screening stage including responses to this consultation.

The overall policy context for the Plan is largely set by the Government’s National Planning Policy Framework and National Planning Practice Guidance – and in particular 12 core land-use planning principles. From the start, the Plan has reflected all these, as appropriate. Paragraph 116 of the Framework was particularly important to the Town Council in developing the Plan in that it makes clear that major developments are not usually acceptable in Areas of Outstanding Natural Beauty, except in exceptional circumstances.

The Plan was drawn up during a period when there was no up to date Tewkesbury Borough Plan and only a draft Joint Core Strategy for the area. Nevertheless, The Plan has been prepared on an expectation that draft policies give a reasonable expectation of the policies that may ultimately emerge. A wide range of other relevant policies and assessments were considered, including the latest flood management strategies and the Cotswolds AONB Management Plan.

To complete the screening process, relevant data were reviewed covering biodiversity, the needs of the local population and human health, nature conservation (covering fauna and flora) and landscape, soil quality, air and water quality, the built heritage, climate change (in each case considering any interrelationship between them).

A Habitats Regulations Assessment (HRA) is a process that looks at the potential impact of proposals within a plan on internationally designated wildlife sites. For the purpose of the HRA, internationally designated wildlife sites are Special Protection Areas (SPA), Special Areas of Conservation (SAC) and Ramsar wetland sites. The initial stage of the HRA process involves consideration of the reasons for designation and the conservation objectives of each internationally designated wildlife site within a reasonable


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distance of the Neighbourhood Plan Area and the potential impact of the proposals within the plan on these. This report details the assessment of the Winchcombe and Sudeley Neighbourhood Plan against the need for an SEA or HRA to be produced to accompany the Plan. A Habitats Regulations Assessment was however not required and the appropriate formal screening matrix is at the annex to this Environmental Report.

An Environmental Report covering the requirements of the SEA Directive would be required to accompany the Neighbourhood Plan – largely due to the potential significant impact on the nationally designated AONB landscape. A summary of all the issues to be covered – under 21 headings - is provided in the table following paragraph 143. Those headings are:

climate change energy consumption in buildings loss of biodiversity loss of landscape quality flood risk water resources air quality land and soil quality reuse of previously developed land waste management character, identity and quality of the built environment traffic impacts health and social inclusion new housing needs serviced housing for older people employment and economic growth visitor economy and tourism regeneration of deprived areas town centre retail capacity

Scoping Section 4 of this Environmental Report provides an assessment of each of the 21 issues to show how each is to be addressed in the policies in the draft Neighbourhood Plan, and also shows for each any potential significant environmental effects. Only one of the issues was assessed to have any potentially significant adverse effects on the environment – that relating to the building of new homes anywhere outside the built up area of the town of Winchcombe. Other lesser effects under the headings of paragraph 6 of Schedule 2 of the Environmental Assessment of Plans and Programmes Regulations 2004 would be adequately addressed through draft policies.


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Given that the only issue formally triggering Strategic Envirnomental Assessment was the proposed location of potential new housing developments close to Winchcombe, the Town Council focused their assessment on the investigation of alternative sites for that development. That process is described in Section 5 of this Report. What does the SEA conclude?

Overall, the plan has been put together in a way that delivers a high level of protection of the environment and integrates considerations of the environment into all relevant policies

During plan preparation, the main issue of concern was the potential impact of housing development affecting the nationally designated Area of Outstanding Natural Beauty and having a significant adverse environmental impact; the policy presumption was clear – that such development should not be permitted unless there was a clear need and no satisfactory alternative locations

Borough policy was nevertheless driving the need to find sites for housing development in or adjacent to Winchcombe

During the development of the Plan, two specific local needs were identified – provision of housing for older people looking to downsize, and starter homes for younger households – sites were identified where those needs might best be met (at Almsbury Farm and in an area behind Mercia Road (known as “West of Winchcombe”)

Following public consultation, the Town Council concluded that there was not enough evidence of the need for housing for younger families (on the West of Winchcombe AONB site) to meet the National Planning Policy Framework tests for major development

Instead, the draft Plan was amended to include a commitment to review by 2020 the need for starter homes for younger families with a view to identify the need, and a suitable site, in the period 2021-2031

On the other hand, the Assessment showed that those national policy tests could be met by a proposal to develop dedicated housing for older people and a care home on land at Almsbury Farm - a development would also bring offsetting benefits in the shape of new uses for a long disused barn and land no longer used for agriculture

The overall impact of the plan policies proposed was likely to be positive (by comparison with not having a Neighbourhood Plan). The Plan would enable Winchcombe to thrive as a living, working town set in an outstanding environment and conserving its historic character. New jobs, better protection of natural assets, better design and improved working and living conditions would all be encouraged by the Plan. The community would be stronger as a result of its engagement with the process to positively shape and direct development that is outside the strategic elements of the Tewkesbury Borough plan.


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If the Almsbury Farm site was to be excluded, there was no other suitable site available or potentially available with the same advantages of bringing listed buildings back into economic use.

If there was no plan at all, the goal of strengthening the community through engagement in its own development needs (the goal set out in the National Planning Policy Framework would) not be met and local people would remain disengaged from development control decisions.


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1. Introduction and methodology

Introduction

1. Winchcombe Town Council and the Sudeley Parish Meeting have prepared a Neighbourhood Plan in partnership with the community, covering the whole of both parishes. Mainly because of the location of much of the town and surrounding area in the Cotswolds Area of Outstanding Natural Beauty, the Council determined early on that the Plan needed a sustainability appraisal that would also meet the requirements of a Strategic Environmental Assessment (SEA). The Town Council also noted that there were no European protected sites in or near the two parishes of Winchcombe and Sudeley. Confirmation of this assessment may be found in the Annex to this Report.

2. So, this document not only represents a sustainability appraisal with evidence underpinning the Neighbourhood Plan, it is also the Environmental Report for the SEA. It is designed to inform the main statutory consultees with environmental responsibilities in England, other parties with a sustainability/environmental interest, and those with a local interest. It represents only a modest update of the Scoping Report published by Winchcombe Town Council on 6th August 2014, given that there has been no fundamental change in the evidence base or policy requirements for our Neighbourhood Plan.

Strategic Environmental Assessment

3. European Commission Directive 2001/42/EC is transposed into UK law through the Environmental Assessment of Plans and Programmes Regulations 2004 which applies to development plans with significant environmental effects. The assessment of significance of environmental effects is usually undertaken through a screening assessment using the criteria set out in Annex ii of the SEA Directive. A screening process was carried out with assistance from Tewkesbury Borough Council, and the outcome was published as an Annex to the Town Council’s Scoping Report published on 6th August 2014.

4. This environmental report addresses the information referred to in Schedule 2 of the Regs taking account of the factors set out in Reg 12(3) i.e. (3) The report shall include such of the information referred to in Schedule 2 to these Regulations as may reasonably be required, taking account of—(a) current knowledge and methods of assessment;(b) the contents and level of detail in the plan or programme;(c) the stage of the plan or programme in the decision-making process; and(d) the extent to which certain matters are more appropriately assessed at different levels in that process in order to avoid duplication of the assessment.


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SCHEDULE 2 Regulation 12(3)INFORMATION FOR ENVIRONMENTAL REPORTS1. An outline of the contents and main objectives of the plan or programme, and of its relationship with other relevant plans and programmes.2. The relevant aspects of the current state of the environment and the likely evolution thereof without implementation of the plan or programme.3. The environmental characteristics of areas likely to be significantly affected.4. Any existing environmental problems which are relevant to the plan or programme including, in particular, those relating to any areas of a particular environmental importance, such as areas designated pursuant to Council Directive 79/409/EEC on the conservation of wild birds(a) and the Habitats Directive.5. The environmental protection objectives, established at international, Community or Member State level, which are relevant to the plan or programme and the way those objectives and any environmental considerations have been taken into account during its preparation.6. The likely significant effects on the environment, including short, medium and long-term effects, permanent and temporary effects, positive and negative effects, and secondary, cumulative and synergistic effects, on issues such as—(a) biodiversity;(b) population;(c) human health;(d) fauna;(e) flora;(f) soil;(g) water;(h) air;(i) climatic factors;(j) material assets;(k) cultural heritage, including architectural and archaeological heritage;(l) landscape; and(m) the inter-relationship between the issues referred to in sub-paragraphs (a) to (l).7. The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment of implementing the plan or programme.8. An outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information.9. A description of the measures envisaged concerning monitoring in accordance with regulation 17.10. A non-technical summary of the information provided under paragraphs 1 to 9.

Plan scope and main objectives

5. The neighbourhood planning process is designed to empower residents, employees and businesses to come together - under the leadership of town and parish councils - and say where new houses, businesses and shops should be located and what they should look like.

6. The Winchcombe and Sudeley Neighbourhood Plan will (when adopted) contribute to the overall central policy of the National Planning Policy Framework by encouraging sustainable development to meet the needs of the local communities economically, socially and environmentally. It will focus on development and use of land and buildings – anything that requires planning permission. It needs to be generally in line with the ‘Basic Conditions’ ie: It must be appropriate having regard to national government policy; It must contribute to the achievement of sustainable development; It must be in general conformity with the strategic policies in the development plan for the local area (currently the “saved” policies from the


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Tewkesbury Borough Local Plan to 2011 (March 2006)) – which may in due course be superseded by a Joint Core Strategy for Cheltenham, Gloucester and Tewkesbury (currently in draft form) and a Tewkesbury Borough Plan (on which early work has started); and It must be compatible with human rights requirements and EU obligations.

7. With input from local residents and businesses, Winchcombe and Sudeley councillors have explored the opportunities and issues likely to arise over the next fifteen years or so – in our rapidly changing world. They have shaped a draft Neighbourhood Plan with policies to help the town and its surroundings to flourish. The draft Plan comprises a written statement with: draft policies, each supported by explanatory justification; and a detailed proposals map on an Ordnance Survey base showing policy designations and allocations.

8. The draft Plan seeks to promote growth and investment, mainly in and around Winchcombe itself (as a “Rural Service Centre” designated by the draft Joint Core Strategy), through the allocation of land for development (following an appraisal of site options). It sets out proposals for infrastructure investment and public service enhancements to support the level and distribution of development proposed.

9. This Environmental Report explains how the Neighbourhood Plan was screened and scoped for a wide set of environmental considerations, before being formally approved for submission to Tewkesbury Borough Council in November 2015

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2. Screening: the overall policy context

Introduction

10. This section provides a summary of key relevant national, regional and local studies, plans and policies which could influence the Neighbourhood Plan. Key aims, objectives and indicators have been identified from the national, regional and local documentation and have been incorporated into the SEA/SA framework and used to inform baseline data and the identification of key issues.

11. International and national policies other than the new National Planning Policy Framework (NPPF, 2012) and National Policy Guidance (NPPG, 2014) have are not specifically reviewed as it is assumed that relevant sustainability objectives within these documents have been incorporated within the NPPF (which the Neighbourhood Plan must take account of, and the regional and local policies with which a Neighbourhood Plan must generally conform..

12. This chapter contains the original policy review of the various documents and their relevance to a neighbourhood plan for Winchcombe and Sudeley. Although there have been subsequent changes in the national policy guidance and practice notes, and some progress with the Joint Core Strategy and first draft Tewkesbury Borough Plan, these have not significantly affected the overall context for the draft Plan.

National Policy Context

13. The National Planning Policy Framework (NPPF) was issued in March 2012 (and guidance on its application was issued in National Planning Practice Guidance, in March 2014). It sets out the Government’s overall planning policies for England in a succinct document that replaces all of the previous Planning Policy Statements and Planning Policy Guidance Notes. The NPPF sets out that there must be a “presumption” in favour of sustainable development, so that it is clear that development that is compatible with the guidance can be approved without delay. Local Plans should include policies that will guide how the presumption will be applied locally.

14. The NPPF sets out 12 core land-use planning principles that should underpin both plan-making and decision-taking. In summary, these are that planning should: be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area. Plans should be kept up to date and be based on joint working and co-operation to address larger than local issues. They should provide a practical framework within which decisions on planning applications can be made with a high degree of predictability and efficiency;


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not simply be about scrutiny but instead be a creative exercise in finding ways to enhance and improve the places in which people live their lives; proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. Every effort should be made objectively to identify and then meet the housing, business and other development needs of an area, and respond positively to wider opportunities for growth. Plans should take account of market signals, such as land prices and housing affordability, and set out a clear strategy for allocating sufficient land which is suitable for development in their area, taking account of the needs of the residential and business communities; always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings; take account of the roles and characters of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognizing the intrinsic character and beauty of the countryside and supporting thriving rural communities within it; support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change, and encourage the reuse of existing resources, including the conversion of existing buildings, and encourage the use of renewable resources (for example, by the development of renewable energy; contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value, where consistent with other policies in this Framework; encourage the effective use of land by reusing land that has been previously developed (brownfield land), provided that it is not of high environmental value; promote mixed-use developments, and encourage multiple benefits from the use of land in urban and rural areas, recognizing that some open land can perform many functions (such as for wildlife, recreation, flood risk mitigation, carbon storage, or food production); conserve heritage assets in a manner appropriate to their significance, so that they can be enjoyed for their contribution to the quality of life of this and future generations ; actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling and focus development in locations which are or can be made sustainable; and take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.

Chapter 12 of the NPPF is particularly important in looking to reflect Government priorities for the historic built environment (see paragraphs 99-103) and designated protected landscapes. In relation to development proposed in Areas of Outstanding Natural Beauty, paragraph 116 of the NPPF states that


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“Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.” The majority of the Neighbourhood Plan area is located within the Cotswolds AONB. So, the goal of identifying land to meet identified development needs in the public interest would inevitably need to involve an assessment of the need for development within the AONB, the scope for developing outside the designated area, and the extent to which any detrimental effect could be mitigated.

15. The National Planning Practice Guidance (NPPG) was issued in March 2014. Among other issues, it provides guidance on Neighbourhood Plan preparation.

16. More recently, the Department for Communities and Local Government has reminded local authorities to ensure that they take account of the full wording of paragraph 14 of the NPPF. This states:

“local planning authorities should positively seek opportunities to meet the development needs of their area. Local Plans should meet objectively assessed needs, with sufficient flexibility to adapt to rapid change, unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against: the policies in this Framework taken as a whole; or specific policies in this Framework indicate development should be restricted. For example, those policies relating to an Area of Outstanding Natural Beauty”

This is the basis on which the draft Plan has been prepared.

Implications for the Winchcombe and Sudeley Neighbourhood Plan

17. While it sets no specific targets or indicators, the principles of the NPPF must be taken into account and some areas of the guidance will be of particular local interest. For example: there is a detailed methodology as to how the objectively assessed housing need should be calculated, including how student housing, housing for older people and the re-use of empty homes can be included when assessing housing need. And, when assessing the deliverability of a housing site the NPPG states that plan makers will need to consider the time it will take to commence development on site, and building rates, to ensure a robust five-year housing supply; a policy encouraging a major development in an AONB would need to demonstrate exceptional circumstances and why it would meet a public interest test. Consideration should therefore include an assessment of:

the need for the development, including any national considerations, and the impact of permitting it, or refusing it, upon the local economy;


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the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and

any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be mitigated;

new development on flood risk sites should not be allowed unless tests set out in the NPPF have been followed and any resulting requirements met; a holistic approach to the historic environment of the whole area should be considered, including non-designated heritage assets alongside the designated Conservation Area, listed buildings and scheduled ancient monuments; there is guidance on the new measure that allows the designation of “local green spaces”, which carry similar protection against development as green belts do; plans should, for at least the first five years, make clear what infrastructure is required, who is going to fund and provide it, and how it relates to the anticipated rate and phasing of development a landscape and visual impact assessment (LVIA) is to be undertaken as part of the SEA. Such an assessment should be based on good practice guidelines, such as those produced jointly by the Landscape Institute/Institute of Environmental Assessment 2013. Winchcombe Town Council commissioned a suitable landscape assessment based on good practice guidelines and the final report has been made publicly available alongside this report.

The Government’s Rural Economy Growth Review (2011)

18. This review was part of the Government’s overall strategy to encourage economic growth. It pointed out that businesses in rural areas make a substantial contribution to the national economy. In England they generate around 22% of employment and 19% of Gross Value Added (GVA), equating to £200bn in 2008. Recent population trends suggest that the importance of rural areas to national growth will increase. Between 2001 and 2009, the population of England’s rural areas grew 10% faster than in urban areas. Counter-urbanisation is a reasonably established trend in England although there is some evidence the trend is slowing.

19. The review pointed out that there are strong interdependencies within rural areas (e.g. market towns and their rural hinterlands) and between rural and urban areas. For example, the 2001 Census showed 2.1m rural residents working in urban areas (compared with 2.3m rural residents working in rural areas) and around 1.1m urban residents working in rural areas. Geographic clustering, even in rural settings, can bring some of the agglomeration economies enjoyed by urban businesses. These localisation economies can arise when multiple firms within the same industry co-locate and benefit from a local pool of labour with specialised skills. Promoting stronger networks across clusters may also bring similar economies.


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20. The Neighbourhood Plan needs to be positive about the potential for local business growth, based upon local assets. These include tourism assets in the historic attractions such as Sudeley Castle and the Winchcombe Pottery, the range of excellent catering outlets and independent retail stores, and the GWR tourist railway. Other assets include accessibility and quality of life in the town as a place for homeworking, and the provision of services to the older people who feature strongly among those looking to buy homes in the area. There would be benefits in the Winchcombe Business Forum and the Winchcombe Tourism and Retail Association creating a business growth strategy to identify how the geographic clustering mentioned in the Review might be encouraged through suitable development opportunities and infrastructure. The Neighbourhood Plan should itself be exploring the need for future retail and commercial business space.

Regional and Local Policy Context

21. Regional strategies and plans have been reviewed and incorporated where appropriate into the Sustainability Appraisal objectives. The key publications are:

The South West Regional Spatial Strategy

22. This guidance to be taken into account in development plan preparation across the whole of South West England is no longer extant and was never formally adopted.


23. It is only relevant to the extent that the baseline data used in its preparation were formally “tested”.

The Joint Core Strategy for Gloucester Cheltenham and Tewkesbury

24. The Joint Core Strategy is the document that will guide the development of the wider area of Cheltenham, Gloucester and Tewkesbury. It will establish how the three local authorities will respond to the pressures and challenges that the area faces, ensuring that it is able to compete with other areas of England. The three councils have produced their own objective assessment of need based upon local demographic information with reference to economic forecasts, leading to local growth projections to guide the development of the area – including housing and employment targets. The draft Joint Core Strategy has been submitted to the Secretary of State and, compared with the draft considered at the time of the Scoping Report publication, is not amended in any way that would potentially affect the draft Neighbourhood Plan policies.


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25. The Joint Core Strategy establishes a clear set of ambitions for the area and sets out a spatial strategy to meet the needs of the three JCS authorities which focuses development at the key urban centres of Cheltenham and Gloucester and in urban extensions to these centres to help towards meeting their unmet needs. In addition, the Joint Core Strategy proposes to allocate two strategic allocations at the wider Tewkesbury/Ashchurch area. The focus is on a predominantly brownfield MOD site, which is a significant opportunity in development terms to be released during the lifetime of the development plan. It also recognises the important role that the more rural parts of Tewkesbury Borough have to play is supporting wider development needs of the Borough and the crucial role which the rural settlements play in the heritage and individuality of the area both at present and in the future. The section on the rural service centres and service villages recognises that Winchcombe has been acknowledged as a settlement that provides an important role in serving both its immediate and wider rural community.

Gloucester City Council, Cheltenham Borough Council & Tewkesbury Borough Council Infrastructure Delivery Plan

26. The objective of the Joint Core Strategy Infrastructure Delivery Plan was to evaluate the transport, utilities, community and green infrastructure and services that will be required to support the levels of housing and employment growth proposed in the Core Strategy.

27. This has particular significance for the potential use of Community Infrastructure Levy (CIL) funds for roads and other transport facilities, flood defence, schools and educational facilities, medical provision, sporting and recreational facilities, open spaces, and affordable housing.


28. The Winchcombe and Sudeley Neighbourhood Plan should take the principles set out in the plan into account. This means assessing the future impacts on infrastructure that may result from development over the next 15-20 years, and identifying how new requirements will be funded.

Final Draft Strategic Housing Market Assessment: Local Authorities of Gloucestershire (October 2013)

29. The Strategic Housing Market Assessment (SHMA) Update provides a quantitative and qualitative profile of the current and future housing market identifying both the housing needs of local residents and the nature of additional housing required to best provide for the whole population. This was undertaken


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using a range of data so that the outputs would provide robust evidence to inform local housing strategies and planning policies. The outputs are provided at County-wide level. Previous work has broadly identified the County of Gloucestershire as constituting a housing market area, as well as the constituent authorities.

30. In accordance with the latest government guidance a variety of existing data sources were used to provide a diverse evidence base. These included published local and national secondary data, making use of a recent household survey previously undertaken across the study area, obtaining new primary data on the cost of housing locally and the local drivers of the housing market to fill gaps in the secondary data and via stakeholder consultation - stakeholder views have been sought through the process and incorporated into the study. Stakeholders were consulted at an event after the draft report and via online consultations after the first and final draft of the report.


31. The outcome of this work has been wrapped into the draft Joint Core Strategy, with which the Neighbourhood Plan has generally to conform.

Tewkesbury BC Strategic Housing Land Assessment (August 2011)

32. This document is a study of sites to establish their potential contribution to delivery of housing development to 2026 and beyond. The assessment formed part of the evidence base for the preparation of the Tewkesbury BC Local Development Framework and was intended to help the Council to identify specific sites that may be suitable for allocation for housing development in Development Plan Documents.


33. The conclusions reached by Tewkesbury Borough Council were carried forward into their first combined Assessment of Land Availability (see separate section below).

Joint Core Strategy Rural Area Settlement Audit (revised version August 2013)

34. This paper reports on a study to audit the services within, and access to settlements within the JCS area and thereby achieve clarity on each settlement’s role within the study area. Each settlement was audited against criteria including primary services, secondary services, accessibility and population. A settlement's position within the hierarchy does not mean that development is appropriate and deliverable, or that it is to be avoided. Other factors must be considered such as environmental constraints, available development sites and


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local character. This audit must therefore be viewed within the context of the wider JCS evidence base.


35. Winchcombe was found to be the third most significant service location within the Borough (after Tewkesbury and Bishops Cleeve), while Greet was 30th

and Charlton Abbots 67th. Winchcombe and Bishops Cleeve are therefore proposed in the Joint Core Strategy as the two rural service centres where the majority of rural housing should be developed. Other rural villages in the Tewkesbury Borough area were specifically identified as capable of taking some development, but Greet and Charlton Abbots were not mentioned as being suitable for housing development.

Gloucestershire First LEP Economic Strategy

36. Gloucestershire First’s draft Strategic Economic Plan (SEP) outlines proposals to grow the county economy by 2022 and drive growth of 4.8% GVA per annum, averaged over the period of the plan. It explains how Gloucestershire First will support businesses and develop skills in high growth sectors; this includes helping start-ups, as well as maximising the connections and opportunities of the motorway corridor. It aims to enhance the natural environment associated with newly built developments, thus bringing benefits for residents, businesses and wildlife. Tewkesbury Borough Council has an Economic Development and Tourism Strategy to help deliver the LEP Strategy.

37. Gloucestershire First’s EU Structural and Investment Funds Strategy, submitted to Government at the end of January 2014, formed the European Funding part of the SEP for Gloucestershire and will contribute large sums to invest in the economy and environment of Gloucestershire between 2014 and 2020. Rural development funding is also coming on stream through the EU Common Agricultural Policy (both through Rural Development Grants, administered by the Local Enterprise Partnership) and the LEADER approach (with small grants available through the Forest and Tewkesbury LEADER partnership).


38. The strategic documents mentioned above appear to contain little about the rural economy, despite this being crucial to Winchcombe’s vitality as a working town. Clarity about potential funding for business growth and support locally was only emerging as the draft Neighbourhood Plan was being finalised. Economic development in Winchcombe and Sudeley could however qualify for funds under the Forest of Dean and Tewkesbury LEADER partnership scheme.


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Gloucestershire First report on Tewkesbury Borough Vitality, Viability & Vulnerability (VVV) Study (2008)

39. This GFirst study reviewed in detail the town centre, tourism and business parks of Tewkesbury, Winchcombe and Bishops Cleeve to identify the key issues and opportunities for improvement. It considered Winchcombe to be an attractive town with character and historic style. It contained much of its original character providing a good quality streetscape.

There were opportunities for improvement through: more signage in keeping with and complementing the historical character of the town replacing and improving street furniture improving pavements and making some areas of road surfacing similar to the pavements to create a “village square” feeling in the area of the museum

For tourism and leisure, it suggested better synchronised opening of restaurants and tea rooms to coincide with visitors consistency of car parking charges improved public transport links

For business growth, it suggested development of Isbourne and Withytrees industrial estates


40. Where feasible under planning legislation, the draft Neighbourhood Plan could include these ideas through Section 106 agreements of appropriate use of the Community Infrastructure Levy. The proposed economic development locations needed to be reflected in the draft Neighbourhood Pln.

Tewkesbury Borough Council Strategic Employment Land Availability Assessment (Published April 2013)

41. The SELAA is a study of sites that are considered to have the potential for employment use development over the next 15 years and beyond. It was prepared following a similar methodology to the Strategic Housing Land Availability Assessment (SHLAA). The potential employment sites assessed have been collated from a number of different sources, including: Local Plan allocated employment sites; SHLAA sites considered potentially suitable for employment purposes; officer identified sites; sites identified in the JCS Review of Business Parks (2011) and JCS Employment Land Review (2011); a ‘call for sites’ in 2010 and a further SELAA ‘call for sites’ in 2012.


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The assessment found 72 sites to be suitable, available and achievable for employment use, providing a potential supply of approximately 2721 ha of employment land. About 40 of these sites could come forward for development in the next five years. The assessment ruled out as unsuitable all sites in the rural areas covered by AONB or Special Landscape Policy, but without indicating where economic development might be encouraged in the Winchcombe area.


42. Two sites in Winchcombe were considered and rejected as unsuitable for development including: Land east of Broadway Road (in the AONB and partly in the sewage treatment odour zone) considered unsuitable for development Land east of Greet Road (Pennylands and the Dell), now under residential developmentThe exercise did not go on to assess the suitability of other sites in the Winchcombe and Sudeley parishes.

Tewkesbury Borough Council Assessment of Land Availability (published January 2014)

43. This report is the first combined Assessment of Land Availability prepared for Tewkesbury Borough. It updated the 2012 Strategic Housing Land Availability Assessment (SHLAA) and Strategic Employment Land Availability Assessment (SELAA) to provide a comprehensive review of sites within the borough for both housing and employment development.

44. It makes clear, however, in respect of the AONB areas of the Borough that further site specific work will be carried out to inform the Tewkesbury Borough Plan – which may result in sites that are deemed ‘unsuitable’ by the current JCS methodology being carried forward for consultation as part of the emerging plan.


45. Only two sites feature in the list of suitable, available, achievable sites – those currently being developed for housing by Bloor Homes and Redrow Homes respectively. All three others put forward were regarded as unsuitable.

46. A rather more negative assessment is offered for a 1.95 hectare site west of Gretton Road capable of taking 57 homes. The owner is reported as no longer promoting this site, which is within the AONB, but with fair access to public transport, services, employment and facilities.

47. A further housing site of 13 hectares to the west of Winchcombe, also within the AONB, is also assessed as capable of giving fair access to public transport, services, employment and facilities. Tewkesbury Borough Council


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had concerns about viability and build issues related to topography of this site, which is indicated as having the potential to deliver 295 units.

48. Finally, a site on allotment land opposite the Winchcombe Garage was assessed as not suitable or achievable – being within the AONB, removed from the existing settlement and unattractive to the market, as well as being within the cordon sanitaire around the sewage treatment works.

Tewkesbury Borough Council’s housing policies

49. The Borough’s strategic housing and enabling officer has advised that the housing department is concerned with addressing the housing needs of local communities through the delivery of the Housing & Homelessness Strategy 2012-16 and successive strategies to:

Increase housing supply Deliver good quality affordable housing Address homelessness in the borough and develop prevention

initiatives Support housing to meet the housing needs of specific groups Address neighbourhood issues Increase housing standards

50. Development in Winchcombe has delivered valuable new homes for the borough of Tewkesbury and consequently has gone some way to meeting the affordable housing1 needs of our residents through Section 106 planning obligations. The delivery of several rural exception sites has met a specific affordable housing need for the residents of the town of Winchcombe and a final site started in April 2014. Tewkesbury Borough Council’s housing department has welcomed the current developments in Winchcombe that support the housing needs of residents locally and from around the Borough.

Action for Market Towns Town Centre Benchmarking Report (2013)

51. A locally commissioned report for Winchcombe Town Council and Winchcombe Business Forum captured data on 12 Key Performance Indicators selected by town centre management experts to explore the health of Winchcombe’s retail sector.


52. This showed that Winchcombe has several key indicators of a healthy town centre – a low vacancy rate, good business performance, good physical appearance, good variety of shops, good leisure/culture offer and high satisfaction with the provision of shops and restaurants. The only negative indicators were concerned with car parking charges, given the degree of vacant capacity on even the busiest days.

1 Affordable housing is as defined in the NPPF 2012: Annex 2


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Winchcombe Town Council; Consultancy Advice on the Potential for Food Shopping (2013)

53. The purpose of this study by England and Lyle, prepared for the Town Council, was to assess the need for improved food shopping in Winchcombe, decide how any need might be met and assess the impact that new food shops could have on other trade in the town centre. The study included a telephone survey of 250 residents.


54. The report found no case for an out of town supermarket, but that a new store located on the edge of the town centre would have positive spin-off benefits because it would generate linked trips to businesses in the town centre, more than offsetting the reduction in trade in the already cramped Co-op store. Even allowing for the predicted trade diversion from the Co-op store, the overall convenience turnover in the town would increase significantly. The retention of a larger amount of spending in the town would also have benefits for existing shops and services.

Tewkesbury Borough Local Plan to 2011 (March 2006)

55. There are “saved” policies from the Tewkesbury Borough Local Plan to 2011 (March 2006), which continue to apply until such time as they are superseded by a Joint Core Strategy and new Tewkesbury Borough Plan.


56. One saved policy of particular relevance is the policy LND2 which makes clear that in the Special Landscape Area proposals will only be permitted if “they do not adversely affect the quality of the natural and built environment, its visual attractiveness, wildlife and ecology, or detract from the quiet enjoyment of the countryside”. This policy is justified on the basis that the area is of a quality worthy of protection in its own right, and because they play a role in protecting the foreground setting of the AONB.

Tewkesbury Borough Health and Wellbeing Strategy 2013-16

57. The overarching aim of this Strategy is to improve the health and well-being of communities in order to improve their quality of life. It sets out a range of actions under three main strands: To support, encourage and enable healthy, active lifestyleso identify and address health needs across the Borough o work in partnership to provide accessible and beneficial opportunities


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o make the best use of technology to improve the way we communicate with our communities and increase participation o provide a clear identity for the Borough’s Health and Well-being service o increase the number of volunteers to encourage healthy lifestyles o support, encourage and enable the voluntary sector to increase participation in healthy lifestyles o promote community health and well-being opportunities o ensure that leisure and cultural facilities and activities are open to all sectors of the population To facilitate opportunities for children and young people o use activities as a diversion from anti-social behaviour o work with partners to enable or provide opportunities that excite young people into being active o assist youth organisations in response to the county council youth service changes To provide an infrastructure that makes it easier to be healthy o assess and respond to health and well-being infrastructure needs for existing and new communitieso maximise the potential of outdoor spaces for the community to use and enjoyo where relevant, to make best use of Section 106/Community Infrastructure Levy for communities


58. The draft Plan supports the further development of indoor and outdoor sports facilities, and ensures that public buildings and open spaces are available for physical activity and social interaction by people of all ages and abilities. Future development is encouraged where it would permit easy access by foot or bicycle to the town centre and schools, and would not reduce in any way the potential of outdoor spaces for walking more widely in the countryside around town. S106 payments under the draft Plan and Community Infrastructure Levy receipts could be directed in part to promoting healthy, active lifestyles.

59. The Plan includes the retention and further provision of facilities for young people to purposeful and healthy activities outside of school hours.

60. The Plan looks to encourage the local Clinical Commissioning Groups and NHS England to expand the medical facilities in town to meet the needs of the growing population.

National Planning Practice Guidance, Health and Wellbeing, revised 6 March 2014

61. The Guidance lists a range of issues that could be considered through plan making and decision making processes, namely:


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development proposals can support strong, vibrant and healthy communities and help create healthy living environments which should, where possible, include making physical activity easy to do and create places and spaces to meet to support community engagement and social capital; the local plan promotes health, social and cultural wellbeing and supports the reduction of health inequalities; the local plan considers the local health and wellbeing strategy and other relevant health improvement strategies in the area; the healthcare infrastructure implications of any relevant proposed local development have been considered; opportunities for healthy lifestyles have been considered (e.g. planning for an environment that supports people of all ages in making healthy choices, helps to promote active travel and physical activity, and promotes access to healthier food, high quality open spaces and opportunities for play, sport and recreation); potential pollution and other environmental hazards, which might lead to an adverse impact on human health, are accounted for in the consideration of new development proposals; and access to the whole community by all sections of the community, whether able-bodied or disabled, has been promoted.

Implications of the Winchcombe and Sudeley Neighbourhood Plan

62. See the previous section for factors taken into account.

Gloucestershire Local Flood Risk Management Strategy 2014

63. The aim of the Local Strategy is to work in partnership with local communities, and organisations responsible for managing flooding, in order to better understand and reduce local flood risks in Gloucestershire where it is economically, technically, socially, and environmentally feasible to do so.

64. The Strategy aims to: Improve understanding of local flood risk; Put in place plans to manage these risks; Avoid inappropriate development taking place, and ensure new development does not increase flooding elsewhere; Increase public awareness of flooding and encourage local communities to take action; Ensure close partnership working and co-ordination between risk management authorities in Gloucestershire; and Support response to, and recovery from, flooding incidents.



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65. The Plan does not positively promote development on the functional floodplain (map available from the Environment Agency), or likely to increase flooding elsewhere as a result of surface run-off. In an ideal world, the County and Borough Councils suggest that Winchcombe and Sudeley Councils should map the local land drainage systems to show local ditches and watercourses, especially those that cause most concern at times of flooding. Riparian owners should be identified and reminded of their responsibilities for maintaining watercourses. These suggestions cannot reasonably be delivered through the Neighbourhood Plan.

66. The draft Plan does, however, include proposals (where individual development proposals can deliver them) works or planting to manage flows in the Isbourne and Beesmore Brook catchments, as an adaptation strategy to assumed increases in stormwater flows as climate change increases the intensity of rainfall.

Tewkesbury Borough Council Strategic Flood Risk Assessment for Local Development Framework (September 2008)

67. The purpose was to assess and map all forms of flood risk from groundwater, surface water, impounded water bodies, sewer, river and tidal sources, taking into account future climate change predictions, to allow the Borough Council to use this as an evidence base to locate future development primarily in low flood risk areas.


68. As in the previous section.

Tewkesbury Borough Council Flood & Water Management Supplementary Planning Document 2013

69. This Supplementary Planning Document presents a user-friendly guide to assist applicants in making better planning applications; to aid infrastructure delivery; and to help the general public and other stakeholders to gain a better understanding of the Council’s commitment to minimising flood risk. It is designed to be read in conjunction with national and local planning policies and guidance.


70. As in the previous sections. The specific objectives adopted in preparing the draft plan policies were:

1. To steer new development to areas with the lowest probability of flooding.


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2. To ensure that new development does not increase the risk of flooding either on a site or cumulatively elsewhere; and to seek betterment, where possible.3. To require the inclusion of Sustainable Drainage Systems (SuDS) within new developments; designed to control surface water run off close to where it falls and mimic natural drainage as closely as possible (e.g. permeable paving, planted roofs, filter drains, swales and ponds) and provision for their long-term maintenance, in order to mitigate the risk of flooding.4. To ensure that development incorporates appropriate water management techniques that maintain existing hydrological conditions and avoid adverse effects upon the natural water cycle.5. To encourage on-site storage capacity for surface water attenuation for storm events up to the 1% probability event (1 in 100 years) including allowance for climate change.6. To encourage the use of water efficient and recycling devices within new developments.

The draft Neighbourhood Plan also reflects the priorities of the European Union Water Framework Directive including: 1. To prevent deterioration in the status of aquatic ecosystems, protect them and improve the ecological condition of waters;2. To achieve at least good status for all waters by 2015. Where this is not possible, and subject to the criteria set out in the Directive, aim to achieve good status by 2021 or 2027;3. To conserve habitats and species that depend directly on water;4. To reduce or phase out the release of individual pollutants or groups of pollutants that present a significant threat to the aquatic environment;5. To reduce the pollution of groundwater and prevent or limit the entry of pollutants;6. To help reduce the effects of floods and droughts.

Cotswolds Area of Outstanding Natural Beauty Management Plan (2013-18)

71. This is a statutory guide for local authorities, statutory agencies and other bodies such as businesses and individuals working within the AONB. It covers the wide range of issues that affect the area including; development and transport, rural land management, natural resources, biodiversity and the historic environment. It also provides a vision for the future of the AONB over the next twenty years. Conserving and enhancing the Cotswolds environment provides a wide range of benefits (including monetary value through the contribution of landscape to the local economic activity) and become of ever-greater importance as the surrounding urban population grows and rates of change in the wider world accelerate. Access and enjoyment have the potential, if appropriately managed, to increase respect for the special qualities of the Cotswolds and, in so doing, to raise environmental awareness in general. The Management Plan acknowledges the importance of a thriving local economy and


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society to protecting and enriching the AONB environment. The AONB Landscape Character Assessment and Landscape Strategy and Guidelines published by the Cotswolds Conservation Board contain detailed advice regarding landscape and development management.


72. As a working town in the AONB, Winchcombe can benefit from the economic potential which the outstanding landscape setting can offer (more details are set out in a report by Cumulus Consultants, published in April 2013, which estimated that the value of AONB designation, conservation and maintenance to businesses operating in the area as £2billion per annum Gross Value Added). The landscape setting should therefore be seen as an asset for business development compatible with the principles of sustainable development.

73. The Management Plan reiterates the national government planning guidance applicable to major development proposals in the AONB area (see the section above under “National Policies”)

Natural England: Natural Character Area Profile 107

74. The Government’s statutory adviser on landscape, biodiversity and countryside recreation – Natural England – prepares sub-regional Profiles for each distinctive natural character area. Their current Profile for the Cotswolds identifies four strategic environmental opportunities: Protect and enhance the highly distinctive farmed landscape, retaining the balance between productive arable, pastoral and wooded elements and the open, expansive views particularly from the scarp, high wold and dip slope. Safeguard and conserve the historic environment, cultural heritage and geodiversity that illustrate the history, evolution, foundations, land use and settlement of the Cotswolds landscape, and enable access to and interpretation of the relationship between natural processes and human influences. Protect, maintain and expand the distinctive character of the Cotswolds and the network of semi-natural and arable habitats, including limestone grassland, beech woods and wetlands along streams and rivers, to enhance water quality, strengthen ecological and landscape connectivity, support rare species and allow for adaptation to changes in climate. Safeguard and manage soil and water resources, allowing naturally functioning hydrological processes to maintain water quality and supply; reduce flooding; and manage land to reduce soil erosion and water pollution and to retain and capture carbon.



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75. Whilst important across the whole area to be covered by this plan, action to conserve and enhance natural character is largely a matter for land managers and outside the statutory scope of any formal Neighbourhood Plan. There are, however, possibilities to be explored in Winchcombe and Sudeley to do more to interpret, communicate and improve access to the cultural heritage of the area through better visitor orientation – alongside tourist information. The built design elements of the Plan applicable to new and extended development will encourage greater use of Cotswold stone and traditional building methods in smaller, incremental developments that sustain local distinctiveness.

The Gloucestershire Nature Map 2011 (prepared by the Gloucestershire Biodiversity Partnership)

76. The Gloucestershire Nature Map is a strategic approach to showing the best places to maintain and extend terrestrial habitats across the county. It is a refined version of the South West Nature Map and presents a detailed local vision for natural environment change. Gloucestershire Nature Map offers a spatial tool for identifying where action to benefit biodiversity should occur. The mapping is based on the inclusion of selected areas of value sitting within locations where the natural environment could be enhanced or restored. It does not include every area of importance for biodiversity such as designated sites, protected landscapes and priority habitats but has taken the distribution of these into account.


77. The area covered by the Plan includes some Lowland Calcareous Grassland, on the higher slopes above Winchcombe and Charlton Abbots; and some Woodland Mosaic through the Sudeley Parish. The Plan should encourage its conservation and extension in connection with any relevant development in the rural areas.

Other wildlife data

78. In relation to the area west of Winchcombe (the lower slopes of Langley Hill, a Cotswold Escarpment Outlier and one of the highest Cotswold Hills) residents have reported counting 50 species of bird in one garden, there have been reports of red kite on the hill, there are regularly two species of deer (roe & muntjac) in the fields, numerous foxes & pheasants, a considerable number of owls (both barn & tawny) as well as cuckoos which return each year (the cuckoo is now on the RSPB red list as in severe decline). There are also numerous wildflowers in these fields that are crossed by mixed hedgerows and have a number of visually important trees.

The Sustainable Community Strategy for Tewkesbury Borough 2008-2028 (refreshed November 2010)


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79. The purpose of this strategy was to set out how, in both the long term and short term, the Tewkesbury Borough Local Strategic Partnership (which brings together key agencies, organisations and partnerships from the public, private, community and voluntary sectors) will ensure that Tewkesbury Borough continues to prosper. The activities outlined were intended to improve the quality of life of all the people of Tewkesbury Borough and to contribute to the achievement of sustainable development through action to improve economic, social and environmental well-being across the area. More specifically it was developed to: set out the aspirations, needs and priorities of the people of Tewkesbury Borough help co-ordinate the actions of the Borough Council and its partners focus and shape the activities of individual organisations so that they effectively meet the needs and aspirations of the people of Tewkesbury Borough contribute to the achievement of sustainable development in the BoroughThis document is no longer “live” although that does not nullify the content of the strategy.


80. The draft Neighbourhood Plan is designed to be compatible with the principles of sustainable development, and should provide a focus for the partnership working envisaged by the Tewkesbury Borough Council strategy. One of the more challenging goals of sustainable development is to reduce the use of non-renewable natural resources, especially in energy use. The Neighbourhood Plan includes measures to encourage cycling and walking, and to deter development proposals in car dependent locations. It also includes policies to encourage renewable energy in buildings, through the application of renewable solar and heat and biomass technologies.

Winchcombe Town Design Statement (adopted as Supplementary Planning Guidance by Tewkesbury Borough Council, December 2004)

81. This identifies the special characteristics of Winchcombe and sets out policies for the design and quality of development of all sizes, both within the designated Conservation Area and outside it. Responding to community concerns (at the time of its preparation) about the natural break between Winchcombe and Greet, one particular element within the Design Statement suggests that new building should respect the “character, individuality and historic separateness of the settlements within the Parish of Winchcombe”.


82. In preparing the Neighbourhood Plan, the Steering Group considered the effectiveness of these policies and whether they were still fit for purpose or


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needed further elaboration to deliver a built environment that future generations will thank us for.

Winchcombe Housing Needs Survey 2012

83. This survey was carried out in order to update the demand for affordable houses for those living in Winchcombe or having specific connections here. A total of 2276 questionnaires were sent out and a 36% response rate was achieved. The questionnaire covered length of residency within Winchcombe, type of home, number of bedrooms and occupants, type of tenure, affordable needs and age distribution. Under age distribution it was very clear that the largest band related to those aged between 60 and 75, but there was a good general spread of all other groups.


84. Between 2007 and 2013 a total of 66 affordable houses were constructed in Winchcombe and the current Bloor, Redrow and Mount View developments will jointly generate an additional 86 such homes. The survey established that the stock of affordable homes available in 2012 was 347, when there was a shortfall in demand of 40 such homes. More recently, it was reported that affordable housing in Winchcombe was being offered to families from outside the area as there were no more local households in need. This indicates that Winchcombe may currently be providing more affordable homes than needed for local residents or their offspring. A new assessment will be needed soon.

Winchcombe Town Council Vision Statement 2009

85. This document set out Winchcombe Town Council’s vision of how our parish should develop over the period to 2013. It was based, in part, upon the Town Appraisal, published in 1999, the Housing Needs Surveys, published in 2002 and 2008, and the Town Design Statement, published in 2005, and now adopted by the principal authority, Tewkesbury Borough Council. These documents gave Winchcombe Town Council, through the process of public consultation, a strong indication as to what the Town’s people think about key issues.


86. Neighbourhood Plan preparation has enabled the Town Council to review this strategy and the extent that it has been delivered, in line with the community’s expectations five years ago. Going forward, much of the substance is included and extended in the Neighbourhood Plan.


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4. Screening: the environmental and socio-economic factors

Baseline context

87. This section of the report summarises the environmental baseline information available for Winchcombe and Sudeley – as well as socio-economic considerations that are relevant in the context of sustainable development. It provides the basis for predicting and monitoring the impacts of any development and helps to identify sustainability opportunities and challenges. This information was used to identify different options considered in the preparation of the draft Plan. 88. Without a Neighbourhood Plan, in Winchcombe Town Council’s view, there is a material risk of development being approved that would have an adverse impact on environmental assets of recognised importance (as evidenced by the Secretary of State’s decision on an appeal to permit 123 homes in the Special Landscape Area designed to protect the statutorily designated Area of Outstanding Natural Beauty).

Nature conservation and landscape

Nature conservation

89. There are no Nature 2000 sites or European sites (ie Special Areas of Conservation) within the Neighbourhood Plan boundary, or anywhere that may be impacted by development that may take place in or around Winchcombe.

90. Sites of Special Scientific Interest (SSSI) are a conservation designation denoting a protected area - the basic building block of site-based nature conservation legislation. They can be biological or geological. The government produced map http://magic.defra.gov.uk/MagicMap.aspx?layers=Designations,9,10&box=-288417:46530:777997:746530 shows Sites of Special Scientific Interest. Those that lie within the Neighbourhood Plan boundary are well removed from likely locations for development and will not be adversely affected by any policy in the draft Neighbourhood Plan..

Details of key Wildlife Sites and Regionally Important Geological Sites in the vicinity are available from GCER see http://www.gcer.co.uk/ and the GGT see http://www.glosgeotrust.org.uk/

Landscape

91. Winchcombe lies in a gap in the dramatic Cotswold escarpment close to Cleeve Hill (the highest point in the Cotswolds) and Langley Hill (a significant


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http://www.glosgeotrust.org.uk/

http://www.gcer.co.uk/

http://magic.defra.gov.uk/MagicMap.aspx?layers=Designations,9,10&box=-288417:46530:777997:746530

http://magic.defra.gov.uk/MagicMap.aspx?layers=Designations,9,10&box=-288417:46530:777997:746530

http://en.wikipedia.org/wiki/Legislation

http://en.wikipedia.org/wiki/Nature_conservation

http://en.wikipedia.org/wiki/Protected_area

http://en.wikipedia.org/wiki/Conservation_designation

http://en.wikipedia.org/wiki/Conservation_designation

escarpment outlier). With the neighbouring parish of Sudeley, it is surrounded by hills, creating a secluded landscape, distinct from neighbouring communities. That landscape is well wooded and the farming is mixed, with an emphasis on sheep production that reflects the area’s wool producing past.

92. Tough development criteria set down by national Government apply in the Cotswolds Area of Outstanding Natural Beauty AONB, which includes all of Sudeley Parish and most of Winchcombe. The only area not covered is a segment between Broadway Road and Gretton Road, which is designated by Tewkesbury Borough Council as a Special Landscape Area to protect the setting of the AONB (see map below). Details of these policy approaches are set out in section 2 above.

Figure 1 Landscape designations: blue is AONB; buff is Special Landscape Area

Tree Preservation


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93. Tree Preservation Orders are in force at a number of locations across the two parishes.

Built heritage

94. There is a substantial Conservation Area within the Neighbourhood Plan area, reviewed and extended as shown on the map below. The town centre contains a high proportion of stone-built properties lining the main streets, hiding a patchwork of private gardens. Many of them are listed. The town also boasts an ancient Saxon defensive mound. And there are other aspects of historic townscape, including individual buildings or structures, outside the Conservation Area area which have value in defining local historic character. This may be of particular relevance when responding to the concern expressed about the threat to Winchcombe’s historic centre by traffic flows from new development.

Figure 2 Winchcombe Conservation Area shaded


This map is reproduced from Ordnance Survey material with the permission of Ordnance Survey on behalf of the Controller of Her Majesty's Stationery Office Crown copyright. Unauthorised reproduction infringes Crown copyright and may lead to prosecution or civil proceedings. Tewkesbury Borough Council, Licence No. 100025298

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Winchcombe Abbey and other Scheduled Ancient Monuments

95. The site of Winchcombe Abbey designated as a Scheduled Ancient Monument (SAM) covers a significant area of the town centre, between Back Lane, Cowl Lane, Abbey Terrace, St Peter’s Church and the Abbeyfields Community Centre. Gloucestershire County Council has information from excavations over the years. Development at the site is controlled by a hierarchy of national and local policies, which seek to afford the highest protection to archaeological sites and monuments of national importance. The current management regime works relatively well and the monument suffers minimal erosion. There is currently little threat to the site other than from possible development at the school, as the owners of properties within the monument are aware of its legal status and consequent restrictions on works that may cause damage to the monument. Small scale development by individual owners along Cowl Lane do not represent a significant threat in themselves, but could, however, have a cumulative and detrimental impact. 96. Other SAMs include a Roman-British villa, 170m south west of Winchcombe School, a camp on Langley Hill, the tithe barn at Postlip Hall, Wadfield Roman Villa, Spoonley Wood Roman Villa and Belas Knapp and a nearby bowl barrow.

Sudeley Castle and Park

97. Sudeley Castle and its designated parkland is a nationally significant heritage asset in the ownership of a family trust. It may potentially be affected by development some distance away, but it is also important to take account of the overarching statutory desirability of conserving and enhancing heritage assets, and the need to use assets in ways that can fund maintenance. Emerging proposals should therefore be tested against this objective too.

Other archaeology interests in Winchcombe and Sudeley

98. In respect of Almsbury Farm, some archaeological evaluation was undertaken before previous proposals for economic development on this site was permitted (this permission has now lapsed). The field to the east of Almsbury Farm and the area around Almsbury Lodge and the edge of the park have been shown to without any archaeological interest. The main archaeological interest is to the west of the road, where there is some dispute about the age of a “hollow road”. An assessment identified a bank and ditch crossing the field to the west of Almsbury Farm - the bank measuring approximately 3m wide and 2m high from the base of the ditch which runs around its southern side. The bank and ditch to the west of Almsbury Farm, contrary to expectations that it might be a Saxon mound, was thought to be a remnant of a sunken way of medieval or post-medieval origin. But a later


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assessment suggested it was linked with a Roman building, about 400 metres south of St Peter’s Church.

On Greet Road there is a Romano- British settlement, evaluated archaeologically prior to Redrow Homes’ application for housing. The results showed a well preserved sequence of archaeology; a management plan was produced as part of the planning process and works have started now on site. In the view of English Heritage, there is no possibility of this Scheduled Ancient Monument site being built on for housing – even after a full excavation. There has been no assessment of the fields to the north of this site.

Air and Climate

Traffic and transport

99. Any new development has the potential to impact on the road network due to an increase in the number of trips made by car. An increase in car journeys can also have a negative impact upon air quality within the parishes. As such public transport accessibility and the potential to increase bicycle use and safe walking to facilities, all have an important role to play in maintaining Winchcombe’s air quality.

Travel to school

100. Travel to school can cause major traffic impacts and can account for a large number of journeys at peak times. In Winchcombe the secondary school serves a large catchment, taking in pupils from Cheltenham, many of whom travel by bus. There is also considerable traffic generated by the Primary School from parents within the catchment. What’s more, the Primary School is full in some years and this generates traffic journeys at peak times to other village schools. School travel plans help parents and others reduce unnecessary fossil fuel use.

Air quality

101. Winchcombe does not currently have any Air Quality Management Areas (AQMA). Under the local air quality management regime there is a need to undertake regular screening of air quality and report it to DEFRA. Tewkesbury BC’s monitoring in North Street, Winchcombe has revealed no problems.


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Water

Flooding

102. Winchcombe is at the pinchpoint in a bowl mainly covering the wider rural area of Winchcombe and Sudeley Parishes. The Beesmore Brook and the River Isbourne meet in the Castle Street area of the town. Under the Flood and Water Management Act 2010 Gloucestershire County Council has become the Lead Local Flood Authority (LLFA), with responsibility for managing local flood risk from surface runoff, ordinary watercourses and groundwater.

103. The main risks to Winchcombe are from surface water flooding at times of high intensity rainfall, and watercourse flooding along the Isbourne when it cannot hold the volume of water that drains to it from surrounding land. In 2007, about 100 properties flooded in Winchcombe and a further 23 in Greet, predominantly from roads where drains/gulleys were not properly maintained and the Isbourne.

104. The Environment Agency map http://maps.environment-agency.gov.uk/wiyby/wiybyController?value=GL54+5JN&submit.x=11&submit.y=11&submit=Search%09&lang=_e&ep=map&topic=floodmap&layerGroups=default&scale=9&textonly=off shows the floodplain through Winchcombe. There is also mapping of the risk of surface water flooding at http://watermaps.environment-agency.gov.uk/wiyby/wiyby.aspx?lang=_e&topic=ufmfsw&layer=default&scale=10&x=402493&y=228565#x=402441&y=228525&scale=9 .

The area at risk is largely confined, due to marginally higher ground on either side of the river. With climate change, the incidence of high intensity rainfall in Winchcombe is likely to increase in spring and autumn. The functional floodplain may become inundated more frequently, and pressure on bridges at various points may increase. Although the flood depth may increase as a result of climate change peak rainfall, the flood risk remains low overall with no significant increase in numbers of people or properties at risk. The flood extent is unlikely to increase significantly. Upstream measures in the catchment, such as attenuation basins, increased woodland planting and new hedgerow planting may help mitigate flooding and ensure that the flood risk in Winchcombe does not increase as a result of new development draining into the Isbourne. A group has been formed by town and parish councils in the catchment to create a detailed survey to identify the most effective locations for modest intervention schemes designed to reduce peak flows during storms at times when the ground is already waterlogged..

Development increases the amount of impermeable area and therefore an increase in the subsequent surface water runoff if no mitigation measures are put in place. It is for this reason, in line with the NPPF that planning applications should demonstrate evidence that the overall level of flood risk in the area and beyond is reduced and


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http://watermaps.environment-agency.gov.uk/wiyby/wiyby.aspx?lang=_e&topic=ufmfsw&layer=default&scale=10&x=402493&y=228565#x=402441&y=228525&scale=9



http://maps.environment-agency.gov.uk/wiyby/wiybyController?value=GL54+5JN&submit.x=11&submit.y=11&submit=Search%09&lang=_e&ep=map&topic=floodmap&layerGroups=default&scale=9&textonly=off



water quality improved, through the layout and form of the development and the appropriate application of sustainable drainage systems (designed to control surface water run off close to where it falls and mimic natural drainage as closely as possible).

Wastewater

105. There is an existing sewage treatment works within the Neighbourhood Plan area. The operator confirms that new development may require increased infrastructure capacity in some parts of the town, and that they can deliver this.

106. It is important that the development of the Neighbourhood Plan is based on liaison with the operator to ensure sufficient time to undertake any modelling needed to develop and then deliver an asset implementation plan. Land is available to expand the sewage treatment works if required.

Soil

Agricultural land quality

107. The agricultural farmland around Winchcombe is primarily grade 3 (good to moderate quality) around the various watercourses and grade 4 (poor quality) on the uplands, with a small area of grade 5 land near Postlip. In particular, the Bloor and Redrow development sites granted permission for development to the north of Winchcombe were classified grade 3b in terms of the Post 1988 Agricultural Land Classification (England).

Allotments and food production

108. There are allotments behind Dent’s Terrace and the almshouses off Queen’s Square. There are also allotments to the north of Winchcombe off Broadway Road, but no water is available at this site. Should more allotments be needed, Winchcombe Town Council has suitable land available off Gretton Road – which will have a water supply. There are no allotments in Sudeley Parish, where most homes are rural and have gardens.

Human population, health and wellbeing

109. The main challenges to health and wellbeing, nationally and locally, are the ageing population, and health inequalities

Ageing Population

110. In both males and females, Winchcombe has a disproportionately higher number of over 65’s compared with Gloucestershire, which itself is higher than


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England and Wales. Between 2010 and 2035 in Gloucestershire (projections at electoral ward level are not available): over 65’s will increase by 70% [from 18% to 28% of population] …... 75’s……………….. 90% ……85’s………………. 150%This is mirrored by a fall in 0 -19 year olds of approximately 5%.

111. The impact on health services locally will be a significant increase in the morbidity within the elderly population, but the bulk of these problems are avoidable, primarily by addressing lifestyle issues.

112. Although the incidence of such health issues is low in the Winchcombe Medical Practice, the prevalence is high, compared with both county and national figures. Such evidence also points to the need to deliver new housing designed specifically for older people, and care homes for when they cannot cope at home.

Health Inequalities

113. The mainstay of analysis is from the Indices of Deprivation [2004] – a comprehensive national investigation. It comprises seven domains of deprivation [income, employment, health, education, barriers to housing and services, environment and crime], each with further subdivisions.

114. A weighted score provides an Index of Multiple Deprivation [IMD]. For small area statistics, Super Output Areas [SOA] have replaced the old electoral ward boundaries – approx. population 7,500. The SOAs are further subdivided into Lower Super Output Areas [LSOA] - not yet named or numbered – approx population 1-2,000


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Winchcombe Super Output Area showing the four Lower Super Output Areas

115. For our purposes, Winchcombe SOA approximates to the old Winchcombe electoral ward, which again is virtually congruent with the boundaries of the Winchcombe Medical Practice. Winchcombe SOA is further subdivided into four LSOAs: three rural [which absorb the Winchcombe town periphery], and a central residential quadrant, delineated approximately by Gretton Rd to the east, and Gloucester St. to the south

116. It is within this framework that the true inequalities lie. There are currently 32,844 LSOAs in England, which are ranked according to IMD: these are divided into quintiles: quintile 1 is the most deprived 20% of the population, and quintile 5 the least deprived.Winchcombe’s three rural LSOAs are in quintile 5 for IMD, with only occasional individual domains outwith 4 or 5 [the one exception is barriers to accessing to services]. However, Winchcombe town LSOA drops into quintile 3 for IMD, with three domains languishing in quintile 2 [income; education; employment] Local comparisons with Tewkesbury District LSOA’s is even gloomier. A Classification of Residential Neighbourhoods [ACORN] identifies households with ‘existing health problems’ [levels of ill-health above the average]. Winchcombe town has more than one third of households thus identified – only 6 out of 48 LSOAs in the Tewkesbury District fall into this category

Winchcombe LSOA

117. In the various consultation exercises, people have said that they believe access to healthcare could be a potential problem should housing numbers increase, especially given the older age profile of the town compared with the county average.


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118. Data on GP provision shows that the number of GPs per head of weighted population in Winchcombe is lower than the national average. The 2009 national average was 1,913 patients per doctor and the Winchcombe practice was slightly below this figure.

Tackling Health Inequalities

119. A cross-government programme proposes twelve national indicators grouped into four main themes:


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supporting families, mothers and children; engaging communities and individuals; preventing illness and providing effective treatment and care; addressing the underlying determinants of health

120. In addition, the overriding priorities for individuals (with appropriate support) are to: reduce the number of smokers reduce obesity and improve diet and nutrition increase exercise encourage and support sensible drinking improve sexual health improve mental health Indices of multiple deprivation

121. The index of multiple deprivation represents a combined measure of deprivation. It is made up of a number of factors that affect deprivation, including: employment, income and access to services. In the latest Index of Multiple Deprivation (IMD) this area was ranked 18,472 out of 32,482 in England, where 1 was the most deprived and 32,482 the least. This is broken down further by income; employment; education, skills; health; barriers to housing and services; the living environment; and crime (England).

Overall: 56% Winchcombe is better than 50% of areas in England

Income Deprivation: 38% Better than 30% of areas in England

Employment: 40% Better than 40% of areas in England

Health: 88% Better than 80% of areas in England

Education: 36% Better than 30% of areas in England

Barriers to Services: 93% Better than 90% of areas in England

Living Environment: 55% Better than 50% of areas in England

Crime: 78% Better than 70% of areas in England

Housing

122. Winchcombe has grown at a steady pace over the last few decades –


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although recent developments have been of an ever larger size. The 1999 Town appraisal cited the fact that Winchcombe’s housing stock was three times greater than in the 1950s. Since then about 170 new homes were built in the 2001-2011 period and a further 250 in the four years since 2011. Over the period since 1990, population growth in Gloucestershire has averaged about 0.7% per annum – which, translated into need for new housing, represents about 16/17 per annum in Winchcombe. This pace was broadly achieved over the period 2001-2011. The homes built in the last four years however (the first four years of the putative Tewkesbury Borough Plan for 2011 to 2031) therefore represent about 16 years of supply – if the need for new housing follows broadly the growth in population.

123. While such growth has been absorbed, the overall numbers produced in similar styles on the new “estates” is undermining Winchcombe’s historic sense of place – as a town that has grown incrementally over the decades. Winchcombe’s character as an “authentic” Cotswolds town has also changed because new local employment has failed to match the growth in population; the 2011 Census shows that commuting to jobs in other places has increased markedly.

124. Many of Winchcombe's residents are of retirement age, while it seems that people in their twenties cannot afford to live here or choose not to. On the other hand, recently completed affordable housing (social rented, affordable rented and intermediate housing, provided to households whose needs are not met by the market) has exhausted takers from the Winchcombe community and has also therefore helped to serve the needs of others in the county that could not be met because insufficient market housing was being delivered to contribute affordable homes on the scale needed within their neighbourhood.

125. Our survey of residents showed (2013) that most people value life in our community, and show no signs of wanting to move away. This blocks access to homes for younger families and the need for a heterogenous community suggests that new housing should be targeted at: new young households, especially those with modest incomes; the needs of this sector are being addressed to an extent through affordable housing provision. However, some existing residents in need are missing out on affordable housing opportunities that exist (some schemes are not well-known) and often feel forced into the private rental market. The price of even the most modest homes is difficult to attain for many young people, without parental help. And the town is especially short of apartments suitable for one or two. retired people looking for more modest homes (to enable those living infamily sized homes to downsize); this is an area of need becoming increasingly evident through Parish Housing Needs Surveys and other resident consultations - many older people in our rural communities are seeking to downsize from larger family homes. Those households able to satisfy their housing need on the open market [through the sale of their current homes] are unlikely to be eligible for an affordable home under the definition of affordable housing in the NPPF or Tewkesbury Borough Council’s local housing policies. The need, according to


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Tewkesbury Borough Council, is therefore to establish a suitable proposal for modestly priced market housing to be built to satisfy this need. serviced accommodation for semi-independent living; This is another necessary housing requirement in Tewkesbury Borough where, in sustainable areas, such accommodation for older people looking to retire will meet both a market and affordable housing need. other needs; other households have special or non-general needs requirements i.e. people with learning disabilities, physical disabilities, multiple-complex needs, mental health issues, younger people and the needs of Gypsies and Travellers. Whilst these groups may not be considerable numbers within the Winchcombe and Sudeley household make-up, some consideration needs to be given to cover any underrepresented groups and their bespoke needs.

126. High house prices (and very few flats locally) make living in Winchcombe difficult for younger families, those on lower incomes, and for children growing up here to stay in town. Tackling health inequalities is also part of Tewkesbury Borough Council’s work to establish clear links with health and social care partners so residents are able to live fulfilling lives. Poor housing standards and deprived neighbourhoods contribute to how people live their lives and their overall health. Ensuring quality new housing is developed is essential to deliver appropriate provision for the changing needs of residents as they age or medical condition worsens. The provision of health and social care fits alongside the housing needs of residents in addition to suitable community leisure facilities including parks and green spaces, and play spaces to guarantee the health and social inclusion. The concept of regeneration and making best use of existing land is essential to revive communities and in the creation of a sense of place for residents. Working from home has become widely supported by not only employers but many developers are taking note of the need to provide homes with office space. This is a requirement for many households in the Borough across all the tenures. With many households in employment it is important to recognise the need for appropriate transport and commuting mechanisms i.e. suitable road networks and appropriate levels of parking provision with all new housing. It is therefore essential for new housing in our borough to consider the changes in people’s lives and how we now live, work, travel, and communicate as a society.

127. Eighty eight households are logged in the latest Homeseeker register (September 2015) as needing new homes in Winchcombe and Sudeley. Of these, over half need a one bedroom unit, and about one third need a two bedroom unit. This emphasises the need for new affordable housing and underlines the need for policies that discourage the construction of larger homes, or the extension of smaller homes.

Leisure and Community Facilities

128. Many community organisations in Winchcombe use the Abbey Fields Community Centre for physical fitness, dancing, music and other leisure


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activities. There is an indoor sports hall used for badminton and other sports, in Gretton Road, behind a building used partly by the youth club and Winchcombe Community Radio. There are also Scout and Guide Halls, the Methodist Hall and a Conservative Working Mens’ Club. At the Isbourne Business Park there is a privately operated gym. Activities also take place at the senior school.

129. In terms of outdoor sports and recreation space, the town will shortly gain a significant additional football pitches alongside the Bloor Homes development, thus meeting Tewkesbury Borough Council’s playing pitch strategy outcomes. A recent community consultation (2014) identified this point as also the best location for a skateboard park and BMX bike humps – given its proximity to the minor injuries unit at the Medical Centre. The secondary school also has extensive sports areas and an all-weather floodlit pitch shared with the community.

130. Winchcombe and Sudeley parishes do not contain a swimming pool of any kind available for public use. Although recent developments have provided Section 106 money for such facilities, which has been used to support the Cascades Leisure Centre and Swimming Pool, the majority of people locally who want to swim travel to Cheltenham.

131. Initial consultation with local people suggested that the town lacks a suitable venue for music and other arts and cultural events. There was also a common desire to have an indoor swimming facility in the town. In Victorian times there was an outdoor pool in town, and more recently by the senior school.

Open space and recreation

132. Winchcombe has good connections to the countryside, where people can enjoy a rural area providing food from crops and farm animals, biofuels from the woodland, a source of clean water, opportunities for field sports and riding, walking and management of water in a way that keeps the town from flooding in most storms. The ‘Walkers are Welcome’ group in Winchcombe promotes the footpath network nationally and internationally. The Cotswold Way long distance footpath passes through the parishes.

133. According to Government guidance, planning policies should protect and enhance public rights of way and access –to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails. Initial consultation with local people suggested that safe road and off-road cycling opportunities would be popular. Access to the hills west of the town is more difficult for people living in the newer developments north of the town centre.

134. Other important open spaces include the Abbey Fields scheduled ancient monument, the parkland associated with Sudeley Castle (and especially its hard surfaced drive which residents and visitors enjoy as a safe leisure walk, free from


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mud) and the open fields around the town accessible by public footpaths. New public open space will be created in conjunction with the current Bloor and Redrow developments.

135. There are play spaces for young people at the Abbey Fields and in Greet, and at the George V Playing Field alongside the River Isbourne off Mill Lane.

Employment and jobs

136. Within the two parishes, the single largest employer is Postlip paper mill . Otherwise, the majority of jobs are with small businesses – especially the service and retail sectors. Winchcombe’s retail sector comprises mainly independent businesses. There are several good restaurants catering to visitors, many attracted by Sudeley Castle, the Gloucestershire Warwickshire Railway, Winchcombe Pottery, the Cotswold Way and other destination attractions.. The distinctiveness of the town is important, along with its regular festivals and events, and the promotion delivered through the Tourist Information Centre at the old Town Hall.

137. According to the 2011 Census (QS701EW), 2892 residents in the Winchcombe ward were in employment. Of these, 322 worked at home, 283 walked to work, 27 cycled and 103 used public transport. A car was used by 1963 people (68% of the working population). This was similar to the Tewkesbury Borough proportion overall (69%) and reflects the rural nature of the area (the national figure being 57%). At the time of the census, 3427 Winchcombe residents were aged between 18 and 65 but the travel to work statistics suggest that only about 600 people were not driving or using public transport to get to work and therefore likely to be home based or working locally. In other words the town is acting as a commuter base for jobs elsewhere – and since fewer homes is not an option compatible with the Joint Core Strategy, creating more business opportunities should be.

138. Over the past 15 years there has been a regular turnover of businesses operating from the Isbourne Business Park – partly stimulated by a local storm drainage problem currently being addressed. The architectural reclamation yard next to it has been a significant new development. More recently, basic units have become available at Withytrees Farm opposite; while in the AONB, this was a brownfield site. Small units are also available locally on the Parks Farm site (just outside the Town boundary beyond Littleworth), in Greet at the Station Yard, and at the Old Dairy Farm, Sudeley. It is likely that the garage blocks behind housing in Back Lane also contribute to the vitality of local businesses.

139. The Winchcombe Business Forum have suggested that there is a need for a serviced small business centre; and that more attention should be paid to the needs of home-based businesses (which would be encouraged by the arrival of faster broadband within the next two years).


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140. Apart from vacant space above retail units and underused space in the Telephone Exchange, there is little obvious accommodation to meet the demands for small serviced office space.

141. Two studies commissioned by the Town Council in 2013 showed that Winchcombe has a relatively successful independent retail sector, reflected in relatively few vacate shops in town. But they also said that there was some potential to add further convenience floorspace – up to a development of about 1300 sq m gross floor area (about 600 sq m net retail floorspace).

Education and skills

142. Of residents over 16 years of age, 36% are educated to degree level, compared with 27% in England and Wales as a whole. On the other hand, 20% of residents had no qualifications – just less than the average for England.

Issues and problems

Consultation with local people

143. The process of creating Winchombe and Sudeley’s Neighbourhood Plan, has involved a number of consultation events with local people. These including: the launch at the Winchcombe Flower Show in August 2012, followed by a postcard questionnaire through every door asking people what they liked about the town and what might be better; just over 100 responses were received by postcard two workshops facilitated by Gloucestershire Rural Community Council in April/May 2013 attended by invited community leaders – to consider the challenges facing Winchcombe and Sudeley and the potential solutions; about 70 people attended presentations to various interest groups in the town, including the Winchcombe Business Forum and the Friends of Winchcombe engagement with pupils at both the primary and secondary schools in Winchcombe - reaching most of the secondary school pupils through a special assembly the creation of websites through Facebook and Wordpress to supplement the Town Council’s principal website the publication of regular articles/reports in Winchcombe Matters, the Council's publication which is delivered to every door, and in Winchcombe Life regular appearances on Winchcombe Radio and some coverage on Radio Gloucestershire monthly reports to the Town Council, meetings where there is often lively public participation a telephone survey of 250 local residents to learn more about their use of the town centre for shopping a 16 panel exhibition seen by about 1000 people during more than a week on


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display at the Community Centre and then the Public Library, putting forward ideas and inviting views

144. The box below summarises issues of particular relevance raised by local people. These are a very important part of the neighbourhood planning process and reinforce the issues identified through the review of the evidence base. In the following sections are:

a summary of the questions that the draft Plan has therefore sought to address

an assessment of potential development sites, including their impact on protected landscapes


EnvironmentOne of the biggest and clearest responses was the value that local people place on the landscape setting of Winchcombe, and the contribution this area makes to its image, identity and quality of life; in addition, local people value easy access from town to the surrounding countryside.Movement and TransportWhilst many local people valued the ease of travelling by private car, there was concern about traffic congestion and public transport. The problems included parking and loading in the centre of the town. Many people wanted an evening and Sunday bus service to/from Cheltenham.Jobs and Economy The town centre has a range of (mainly independent) shops, but there was a demand expressed for a better convenience store and a greengrocer. There was significant opposition to any kind of out of town supermarket.CommunityPeople felt there was a strong sense of community within Winchcombe but some looked for more leisure and community activities for all ages – for example a swimming pool. There was also concern about the capacity of the educational and medical services to cope as more homes are built around town.

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5. Summary of sustainable development issues and evidence

Sustainability issue/problem

Relevant evidence of the issue/problem

Environmental

Climate Change Globally, climate change is the most severe problem. Communities everywhere need to act to reduce greenhouse gas emissions significantly - at home, at work and when travelling. There is also slow progress in the development of renewable energy sources. In Winchcombe, one significant climate change issue is the lack of local employment - a factor in causing 68% of economically active people to drive to work elsewhere

Energy consumption in buildings

Existing buildings are not energy efficient, and whilst standards are improving in new buildings, there is a need to do better. There is a need to reduce energy use, and - at the same time - make use of alternative energy supplies.

Loss of biodiversity Areas not intensively farmed may contain some sites of ecological value. It is important that these are identified, protected and, where possible, enhanced.

Loss of landscape quality

The national importance of the town setting and the wider Sudeley countryside is recognised through AONB and SLA protected landscape designations. The boundary is not, however, an obvious breakpoint between outstanding and lower quality landscape. Development immediately adjacent to AONB designated land may have a greater impact on the designated land than other sites within the designated area.


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Flood risk Some areas adjacent to the River Isbourne are subject to flooding and are designated flood risk zones. It is important that no new development is directly sited in the designated flood risk area and all other new development is designed to reduce the risk of flooding, including from surface water run-off. A catchment wide approach to manage river flow could reduce the risk of strormwater floods along the Isbourne.

Water resources The availability of water is not a constraint to development and the existing sewage treatment works has room to expand should further capacity be required.

Air quality Winchcombe and Sudeley do not currently have any Air Quality Management Areas (AQMA). However, traffic from new developments could have a negative impact on town centre air quality unless mitigated by alternative means of transport.

Protecting land and soil quality

Agricultural land in Sudeley Parish and around Winchcombe is predominantly Grade 3 (good to moderate quality), with areas of Grade 4 (poor quality). For local food production, there is a need to protect the better agricultural land and protect soil quality.

Optimising use of previously developed land

Reuse of brownfield land is a national and local priority. Only two sites seem to fall into this category in Winchcombe – the buildings at Almsbury Farm and adjacent small fields have been unused for 15 years, despite having planning permission for a significant retail and commercial development; and the telephone exchange building is understood to be significantly underused

Waste There are targets to increase recycling. The main obstacle in Winchcombe is the range of different bins in older properties without storage space

Character, identity Winchcombe’s historic centre is protected


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and quality by a significant Conservation Area. Public concerns are focused on the scale of new development sites, which detract from the sense of a town that has grown modestly and incrementally over 1000 years.

Traffic impacts Public concerns focus on the impact of traffic on the narrow streets in town, often made narrower by parked vehicles and vehicles unloading. The local bus drivers find it difficult to keep to time when there are conflicts with HGV traffic and on street/pavement parking in breach of legal regulations

Social

Health and social inclusion

Winchcombe’s central urban area has only “average” health outcomes

Access to healthcare has been highlighted by local people as a potential problem in the various consultation exercises, should housing numbers increase, especially given the older age profile of the town

Housing Any plan for Winchcombe needs to provide for a fair share of the new homes that the draft Joint Core Strategy suggests will be needed between 2011 and 2031 across Tewkesbury, Gloucester and Cheltenham Borough Council areas. According to the draft Strategy 2,740 new homes will be required within Tewkesbury Borough’s ‘rural areas’ between 2011 and 2031 – of which 900 will be required in Bishops Cleeve and Winchcombe, as the rural service centres (Greet and Sudeley were assessed separately, found to have no local services and therefore excluded from the 2,740 figure) The sustainability challenge lies in high average house prices, which make home ownership difficult for younger families and those with modest incomes (particularly if they need to commute outside of Winchcombe to work). Current developments will provide some new affordable housing, but some modest homes


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are being significantly enlarged in ways that make them less affordable to new entrants.

Serviced housing for older people

Community consultations have identified the need for a dedicated retirement development - so that older people can stay in the town when they want to downsize. Such developments are generally better located within easy walking distance of town centres, providing a handy destination for journeys that encourage personal fitness among residents.

Economic

Employment and economic growth

Sustainable development demands that the town achieves a better jobs/housing balance. Creating more business opportunities in the town should capitalise on its assets – as a tourism base and also as an attractive place for retirement

Visitor economy and tourism

The town lost its only significant sized hotel 25 years ago, while the number of bed and breakfast businesses has reduced in recent years.

Regeneration of deprived areas

The area of town with poorer health outcomes and higher unemployment incidence may require physical and social investment

Town centre retail There is potential for increasing the scale of the convenience store offer (see AMTi benchmarking study and subsequent report by John England, building on material in the JCS Retail Study report)


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6. Scoping: investigating alternative preferred development sites, especially for impact on protected landscapes

143 The draft Neighbourhood Plan set out general policies for development in the Winchcombe and Sudeley Parish areas – over the period to 2031. The previous chapter of this Environmental Report demonstrates how they have addressed the tests for the Plan, identified by the Town Council and published in its earlier “Scoping Document”. Each of the questions starting “Does the plan…” are cross referenced with the draft generic policies, which can be expected to apply to the vast majority of development proposals.

144 This Chapter addresses the question of development which may have a significant adverse impact on the Cotswolds Area of Outstanding Natural Beauty (defined as 10 homes or more, or commercial development of more than 100sq metres).

145 The special character of the town, with its Scheduled Ancient Monuments and Conservation Area, all set in an Area of Outstanding Natural Beauty (AONB) protected by national and more local policies made it very hard to identify sites capable of accepting development. The Town Council needed to take account of the implications of the two types of landscape designation in Winchcombe – the nationally designated Area of Outstanding Natural Beauty, and the Special Landscape Area, an area covered by a “saved policy” from the most recent Tewkesbury Local Development Plan and intended to protect the designated AONB from development with a significant adverse effect on the AONB itself.

146 In particular, the constraint of national policies to protect and enhance AONB landscapes caused the two councils to prepare its earlier sustainability appraisal, incorporating the formal requirements of a Strategic Environmental Assessment. The resulting Scoping Document approved by the Town Council in August 2014 took account of representations by local residents as well as the various statutory bodies such as Natural England and the Cotswolds Conservation Board.

147 It is an important starting point that the Area of Outstanding Natural Beauty designation is not accompanied by the sort of restrictions on development that apply in Green Belts. The National Planning Policy Framework indicates that planning permission for major development should be refused in AONBs except in exceptional circumstances and where it could be demonstrated to be in the public interest.


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148 In looking at sites where development with a significant adverse impact might be envisaged within the AONB boundary the Town Councillors have therefore accordingly taken into account: the need for the development, (including in terms of any national

considerations such as the need for housing that complies with sustainable development principles);

how it would help the local economy; the scope for developing elsewhere outside the designated AONB area, or

meeting the need for it in some other way; and the effects on the environment, the landscape and recreational

opportunities.

149 In considering potential development sites, the Town Council determined that it would be wrong to dismiss all sites in the AONB out of hand. A proper analysis of all the material considerations would be called for, in which the impact of any development policy on the AONB would carry significant weight.

150 The Steering Group advising the Town Council carried out an early assessment of this kind and their results formed the basis of the ideas for future development presented in the public exhibition in January 2014. Although many people welcomed the ideas presented as being acceptable ways of meeting the needs of the area, others were critical and suggested that the Town Council had approved exhibition panels that did not properly reflect the importance of protecting the AONB landscape.

151 The Town Council therefore decided to delay the preparation of the draft Plan and commission an independent Landscape and Visual Sensitivity Study that would provide demonstrably objective advice on the potential landscape impact of development. They made the exhibition panels and the analysis of the public response available to the consultant. But they left it to the consultant himself to identify parcels of land that seemed to him most likely to be brought forward by potential developers or landowners over the period of the plan. This Study was completed in November 2014 and has been published on the Neighbourhood Plan website.

152 The parcels he identified are shown on the map below:


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The colour coding shows different degrees of impact – from “important adverse” (red) through to “moderate beneficial” (green).

The full report is available through the Winchcombe Town Council website.

153 Following a presentation by the consultant, and consideration of his views on each parcel, Town Councillors decided that they would not want to promote any site for major development where the impact would be “important adverse” – whether in the AONB itself or in the Special Landscape Area designated to protect the setting of the AONB - and where they believed that was no reasonable prospect of adequately mitigating that impact. They then agreed each to score the five other parcels against other criteria reflecting the main thrusts of the generic policy goals emerging from the sustainability assessment: effect on landscape, natural assets and setting of Winchcombe’s historic

character;


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effect on Winchombe’s sense of place; degree of re-use of brownfield sites, less productive land and

unused/underused buildings; “connectivity” enabling access on foot to the town centre shops, schools

and the Cheltenham bus service (a crucial aspect in sustainable development);

the capability to help meet the identified needs for new homes for those with modest incomes, and for those of retirement age or approaching it.

Each goal was scored ++,+,0,-,-- . The result of summing the scores (ie ++ scores as 2; -- scores as -2) is set out in the table below on this page. Ten Councillors responded, and the maximum/minimum score for any box is therefore +/-20.

Respects outstanding landscape, natural assets and setting of town(Policy 1.1)

Conserves or enhances historic character and improves Winchombe’s sense of place (Policy 1.1)

Prioritises development on brownfield sites, less productive land and unused/underuse d buildings (1.2)

Good connectivity access on foot to the town centre shops (1.4)

Easy access to the Cheltenham bus service (1.4)

Meets identified need for new homes for younger families (3.4)

Meets identified need for new homes for those of retirement age (3.5)

Parcel 1a – extensive West of Winchcombe -7 -6 -6 -14 -12 +11 +7

Parcel 1b – limited West of Winchcombe

-1 -5 -7 -8 -9 +12 +8

Parcel 3 – Almsbury Farm -3 +10 +15 +16 -9 +6 +15

Parcel 5 – north of Greet -9 -9 -14 -11 -18 +8 +3

Parcel 6 – behind Greet Farm -3 -6 -5 -3 -17 -1 +2

154 Their results indicated that there was one parcel (the brownfield Almsbury Farm site) that represented the best location to meet the need they had identified for a specifically designed supported housing development for elderly people. This location had been judged in the Landscape Study as one where development could lead to a positive improvement of impact – indeed that was the only such site found in the AONB and SLA area to offer that potential. The Town Council concluded that, if well designed and accompanied by a suitable Section 106 agreement addressing flood management, traffic management, foot and cyclepath development and public car parking, such a development would bring benefits to the town and its economy, and improve the protection of historic


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buildings. These benefits would not be achieved to anywhere near the same degree on any site outside the designated AONB area. Moreover, given the unique combination of potential benefits associated with a development tailored for elderly residents (amounting to a justification for development in this part of the AONB area), it would be wrong for the Neighbourhood Plan to suggest that the site should be used for “normal” market housing. Indeed, market housing on any scale here would be unlikely to bring the range of community benefits and would also add more traffic to Vineyard Street, when compared with the more limited traffic flows expected from a retirement community. It would therefore fail the exceptional circumstances test in the National Planning Policy Framework.

155 The Town Council therefore acknowledged the need to look elsewhere to provide further market housing in Winchcombe – if that was needed to enable the Neighbourhood Plan to be judged as in general compliance with the draft Joint Core Strategy and the intentions of the putative Tewkesbury Borough Plan. Taking account of the Landscape Study, there were very few options available that would not have a “significant adverse effect”. Two of the sites with only a moderate impact, and located outside the AONB area were in Greet (a hamlet), and could not be designated to contribute to the obligations on Winchcombe as a Rural Service Centre.

156 The Town Council therefore proposed in its draft Plan to designate just one further site in Winchcombe for development of more than 10 homes – parcel 1b, a limited scale development delineated by the 110 metre contour, Delavale, Orchard and Mercia Roads. This site was judged best to provide a relatively small development of housing designed for first time buyers and younger families looking for easy access on foot to Winchcombe Abbey School. No non-AONB site meeting these criteria could be identified to meet this need. And the impact on landscape would be moderate rather than significantly adverse. The Town Council considered that with good design, the impact on the AONB would not be unduly damaging. And new housing in this location would more easily respect the principles of sustainable development, in that it would encourage access by walking and cycling. Other more distant options (for example on the Special Landscape Area north of the Meadowfort Grange development) would be likely to encourage more driving access to the town centre and add to car parking demands, congestion and air pollution. In terms of pure landscape policy, that site should be preferred over an AONB site; but the principles of sustainable development require other factors to be taken into account.

157 Having provisionally identified these two AONB sites for development, at Almsbury Farm and “West of Winchcombe”, Town Councillors reviewed their conclusions by looking specifically at all land in the Special Landscape Area (even those parcels where potential development had been assessed as likely to have a “significant adverse” effect) to address the question whether it


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could reasonably fulfil the need for new housing as an alternative to the AONB sites. In each case there were concerns about the landscape impact and, crucially, lower scores against other sustainability criteria such as connectivity and easy access to town centre services.

158 The “least worst” non-AONB option, in their view, would be to designate the area between the Redrow Homes site and Greet Road which, while designated as a Scheduled Monument, has not had the benefit of a thorough archaeological study to confirm its importance and therefore the overriding need to keep the land free of any development. At this time, they concluded, it would be inappropriate to include any policy for the development of this Scheduled Ancient Monument.

159 On the basis of this overall assessment, the Town Council subsequently approved a draft pre-submission Neighbourhood Plan on 10th December for public consultation during a period of more than six weeks, ending at noon on Friday 13th February 2015.

160 To summarise, the main reasons for selecting and rejecting sites for major housing development were as follows:

site

Impact on landscapes protected by (national) AONB or (borough wide) Special Landscape Area policies

Other factors conclusion

1a Moderate adverse

Fails to respect historic character or Winchombe’s sense of place Fails to respect outstanding landscape, natural assets and setting of town Very poor connectivity (access on foot to the town centre shops) access to the Cheltenham bus service

Too many adverse factors to meet SEA requirements

1b Low adverse Fails to respect historic character or Winchombe’s sense of place Only modest connectivity

Could possibly meet identified need for new homes for those of retirement age


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(access on foot to the town centre shops)

2a Important adverse

Landscape impact not sufficiently overcome by positive characteristics


2b Important adverse



3 Moderate beneficial in part and otherwise low impact

Prioritises development on less productive land and encourages reuse of unused/underused buildings Very good connectivity access on foot to the town centre shops

Best location for meeting need for new homes for those of retirement age

4a Important adverse



4b Important adverse



4c Important adverse



5 Moderate adverse

Fails to respect historic character, or Winchombe’s sense of place Fails to respect outstanding landscape, natural assets and setting of town Would take large area of productive arable land Very poor connectivity (access on foot to the town centre shops) access to the Cheltenham bus service


6 Moderate adverse

By adding to developed area of Greet, on the Winchcombe side, fails to respect historic character,



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strategic gap or Winchombe’s sense of place

7 Important adverse

Landscape impact not sufficiently overcome by positive characteristics, and would fill the important strategic gap between Winchcombe and Sudeley


8 Important adverse



9 Important adverse



10 Important adverse



161 No other sites were submitted for consideration by the Town Council. The Town Council also took the view that no other sites in the area of the two parishes would be suitable – given the quality of the designated landscape and the national and borough-wide policies in place to protect the open countryside and hamlets without services from large scale development.


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7. Scoping: assessing the effects of draft Plan policies

162 Section 5 of this Environmental Report summarised all the sustainability issues, 21 of them, derived from the evidence taken into account. The table in this section takes the 21 issues and translates them into sustainability objectives for the Plan. Against each, the table shows the criteria for appraisal and specifies the draft policies in the plan that are relevant to achieving that objective. The fourth column then sets out (as required by the Strategic Environmental Assessment Regulations) any likely significant effects on the environment – including short, medium and long-term effects, permanent and temporary effects, positive and negative effects, and secondary, cululative and synergistic effects.

Sustainability objective

Appraisal criteria Draft policies reflecting the objective

Significant environmental effects

1 Address the need to mitigate and adapt to climate change

Does the Winchcombe and Sudeley NP: locate new development – housing and employment - in places that are accessible on foot, by bicycle and by public transport? encourage home working identify ways of improving the provision of and access to public transport:o within the town?o in the wider area with links to trains, to centres of employment and to hospitals? Minimize the need for additional private transport travel require new green infrastructure/open spaces as part of new development? increase the

1.4 Sustainable connections

3.2 Infill development

2.5 Home-based working

3.6 Support for services

1.5 Local Green Spaces

4.5 Walking and cycling routes

Policies that enable the community to function well, economically and socially, without undue dependence on the private car, will make a contribution to reducing greenhouse gas emissions – but there may be some adverse impact on landscape, given that most of the centre of the town is hemmed in by land designated as an Area of Outstanding Natural Beauty.


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potential to increase bicycle use and safe walking to facilities?

2 Reduce energy consumption in buildings, promote energy efficiency and increase the use of energy from renewable resources

Does the Winchcombe and Sudeley NP: promote energy efficiency in new development with clear requirements and targets? identify and promote opportunities for greater energy use from renewable resources? minimise the need for additional private transport travel?

5.7 Resource efficiency



Policies will have a positive environmental benefit

3 Protect and enhance biodiversity and wildlife habitats, fauna and flora

Does the Winchcombe and Sudeley NP: protect existing areas of ecological importance within the NP area by incorporating them appropriately within the spatial plan for growth? encourage biodiversity and wildlife as part of new development? maintain, enhance and increase tree cover and woodlands?

1.1 Development to respect the distinctive character of Winchcombe and its surrounding area

No significant elements of flora and fauna were identified in the analysis of background evidence; the draft policy will contribute in a general way to avoid adverse effects on the environment

4 Develop in ways that enhance landscape, and especially protect the appearance of the town from the AONB and the attractiveness of the AONB from the town

Does the Winchcombe and Sudeley NP: Protect and enhance the highly distinctive farmed landscape, retaining the balance between productive arable, pastoral and wooded elements and the open, expansive views particularly from the scarp, high wold and dip slope? Contain sustainability objectives for the wider landscape and for the conservation


3.4 Meeting local needs for new homes for those with modest incomes

3.5 Meeting needs for new homes for those of retirement age

The general policy presumption in 1.1 will be positive in respect of AONB protection. Some adverse effects will be inevitable as a result of any major housing development envisaged in 3.4 and 3.5 on a scale that involves development within the designated AONB area, or on land outside the designated AONB area where there would be a significant impact on the AONB itself.


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of the Cotswold AONB in its own right

5 Minimise the risk of flooding

Does the Winchcombe and Sudeley NP: adopt a catchment based approach to flood risk reduction? steer development to areas of lower flood risk as far as possible? encourage attenuation basins, treeplanting and other measures upstream of town, to manage the flow at times of storm? incorporate Sustainable Urban Drainage requirements for new development (to address surface water and run off problems)?

1.3 Flood avoidance

5.8 Flood protection

These policies will have positive environmental and public health and wellbeing benefits – especially in the longer term with the projected increase of heavy storm rainfall as a result of sea temperature rising

6 Protect, maintain and improve the quality of water resources, minimise the risk of pollution and improve water efficiency

Does the Winchcombe and Sudeley NP: encourage the efficient use of water in new development (eg through the use of rainwater harvesting)?

5.7 Resource efficiency This policy will have positive environmental and public health and wellbeing benefits

7 Protect air quality where it is of a high standard and to improve it elsewhere

Does the Winchcombe and Sudeley NP: encourage a modal shift to walking and cycling from private cars by:o locating new development in places easily accessible through alternative travel modes?o connecting more parts of the town with good pedestrian and cycle routes?




Air quality is already relatively good in Winchcombe and the policies specified will help maintain that


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8 Reduce the consumption of natural resources

Does the Winchcombe and Sudeley NP: encourage more use of local food and biofuels

1.2 Development to minimize loss of productive land

2.8 Encouragement of outlets for local producers

Modest positive effects

9 Protect land and soil quality

Does the Winchcombe and Sudeley NP: minimise the amount of agricultural land taken by development? Provide for sufficient allotments?


This policy is positive in encouraging local agricultural and forestry uses of land

10 Optimise the re-use of previously developed land and buildings

Does the Winchcombe and Sudeley NP: maximise the amount of previously developed land for new development?


This policy is positive in encouraging optimum use of previously developed land and sustaining local agricultural and forestry uses of land

11 Achieve sustainable waste management by reducing the production of waste, increasing opportunities for recycling and reducing the amount of waste being sent to landfill

Does the Winchcombe and Sudeley NP:

encourage the provision of recycling facilities in both existing places and new development? require bin and recycling storage to be designed into residential developments?

5.9 Waste reduction Environmentally positive

12 Preserve and enhance sites, features, areas and settings of archaeological, historical and cultural heritage importance

Does the Winchcombe and Sudeley NP: protect Scheduled Ancient Monuments from development? preserve and enhance the town’s listed buildings, including the Town Hall? preserve and enhance the


2.9 Sudeley Castle

2.11 The Old Town Hall

2.10 Winchcombe Pottery

Important in avoiding significant environmental damage in respect of cultural heritage, including architectural and archaeological heritage


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Conservation Area and non-designated built heritage assets? provide the infrastructure and settings needed for festivals and events? generally safeguard and conserve the historic environment, cultural heritage and geodiversity that illustrate the history, evolution, foundations, land use and settlement of the Cotswolds landscape, and enable access to and interpretation of nature and human influences?

2.12 The Gloucestershire Warwickshire Railway

5.1 Design of new development

5.2 Winchcombe Conservation Area

5.3 Illuminated signs and shop fascia

5.4 Extensiona and alterations to existing buildings

13 Protect, enhance and manage the character and appearance of the landscape and townscape, maintaining and strengthening local distinctiveness and sense of place

Does the Winchcombe and Sudeley NP: enhance key areas, individual buildings or structures that contribute to local distinctiveness? embrace design policies from the current Town Design Statement? prioritise and enable modest incremental developments rather than extensive estates in a single style?




3.1 Incremental growth


5.1 Design of new development

5.2 Winchcombe Conservation Area

5.3 Illuminated signs and shop fascia

5.4 Extensions and alterations to existing buildings

Important in avoiding significant environmental damage in respect of cultural heritage, including architectural and archaeological heritage

14 Improve human health and social inclusion,

Does the Winchcombe and Sudeley NP: promote better use of allotments support existing

4.1 Protection and improvement of community facilities

4.2 Indoor sports and

Positive benefits for human health and wellbeing, with no risk of adverse environmental impacts


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whilst reducing inequality, and valuing diversity and equality

social and community activities through facilities? encourage provision of new leisure facilities for all sectors of the population? support the continued improvement of schools?

youth facilities

4.3 Facilities for older residents

4.4 Facilities for younger residents

4. Allotments


15 Provide sufficient housing to meet identified needs including affordable housing, and specialist groups

Does the Winchcombe and Sudeley NP: provide enough new housing to meet the needs of the town, as determined through the JCS and Tewkesbury Borough Plan? create a sustainable and mixed community, by encouraging a range of housing types to meet the needs of a range of different households, including:o affordable market housing (for sale and/or rent) for those on lower incomes?o younger households, ando supported apartments for elderly people?

3.1 Incremental growth


3.3 Regeneration

3.4 Meeting local needs for new homes for those with modest incomes

3.5 Meeting needs for new homes for those of retirement age

Some adverse effects as a result of housing development envisaged on a scale that involves development on land within the designated AONB area, or on land outside the designated AONB area where there would be a significant impact on the AONB itself.

16 Create a safe environment to live in and reduce the fear of crime

Does the Winchcombe and Sudeley NP: require the design of all new development to accord with ‘Secure by Design’ principles? promote opportunities to improve road safety in existing places,

5.6 Safety


No adverse effects on the environment


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especially for pedestrians and cycle users?

17 Support sustainable economic growth and competitiveness, and provide opportunities for ongoing private sector investment

Does the Winchcombe and Sudeley NP: encourage new business investment to grow the local employment base by protecting and providing employment land? support and strengthen local employment base by improving access to customers and for employees, and to infrastructure? help attract a wide variety of businesses to invest in the town and its rural hinterland? support ways of upskilling local people to meet the needs of existing and new businesses?

2.1 New Commercial and Light Industrial Development

2.2 Postlip Paper Mill

2.3 Protection of business premises

2.4 Buildings for rural businesses

2.6 Tourist accommodation

2.7 Retail development


2.9 Sudeley Castle


No adverse effects, in that the sites designated for economic development are already part developed; extending those sites would be less damaging than identifying new sites in or near the AONB

18 Develop and enhance the visitor economy/tourism

Does the Winchcombe and Sudeley NP:

improve the image and attractiveness of the town as a whole by:o positively marketing the town?o improving existing buildings, streets and spaces?o creating new high quality buildings, streets and spaces?o encouraging new and improved tourist facilities and attractions?


2.8 Promotion of local products

2.12 The Gloucestershire Warwickshire Railway

A vibrant tourism economy provides an economic rationale for conserving, maintaining and enhancing the outstanding landscape around the town, as well as the cultural heritage of historic buildings and designated parkland at Sudeley Castle

19 Promote regeneration of deprived areas and deliver urban / rural

Does the Winchcombe and Sudeley NP: support the regeneration of deprived parts of the town?

3.3 Regeneration Human health will benefit from the application of this policy, which has no adverse environmental impact


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renaissance and improve image

20 Maintain and improve the vitality and viability of the town centre of Winchcombe

Does the Winchcombe and Sudeley NP: encourage the improvement or redevelopment of shopping to meet the needs of local people and visitors? promote market stalls in the town centre?

2.7 Retail development


A strong retail economy provides an economic rationale for conserving, maintaining and enhancing the outstanding landscape around the town, as well as the cultural heritage of historic buildings and designated parkland at Sudeley Castle. It also encourages residents to shop locally, thus reducing the need to drive to more distant supermarkets.

21 Monitoring impacts over time

Does the Winchcombe and Sudeley NP: provide suitable monitoring arrangements to meet the legal requirements?

6. Policies for monitoring plan implementation

Discourages adverse environmental effects and encourages further action where needed to address unforeseen effects relevant to the Strategic Environmental Assessment.

163 The Town Council therefore concluded that the policies and Plan as a whole are likely to lead to relatively modest environmental impacts. There were also few negative tensions in the inter-relationship between policies. Some impact on landscape interests would result from using the site identified to meet the need to provide housing to meet Winchcombe’s share of the likely assessed need for “Rural Service Centres”, as envisaged in the Joint Core Strategy and first draft Tewkesbury Borough Plan. The Town Council did assess all other potential sites for such development (see Section 6 above) and in finalizing the policy included a demanding set of conditions on any such development by way of mitigation. Leaving this policy out of the Plan altogether would be likely to result in a Plan failing to meet the housing delivery target of the emerging Tewkesbury Borough Plan. And without a Plan at all, the opportunity to achieve the sustainable development goals identified in the table above would be very much less.


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8 Final Environmental Statement taking account of responses to the December 2014 consultation version of the Neighbourhood Plan

164 A draft Environmental Report was approved by Winchcombe Town Council in 2014, taking into account the results of informal public consultation over a two year period. The draft was updated and made available alongside the formal consultation draft plan published at the end of December 2014. No issues concerning the draft Environmental Statement itself were raised in response to the formal consultation.

165 In the light of responses to the draft Neighbourhood Plan, however, the Town Council concluded that there was not enough evidence of the need for housing for younger families to demonstrate how the NPPF tests for major development in the AONB could be met. Sites 1a and 1b were therefore not designated in the submission plan. Instead, the draft Plan was amended to include a commitment to review by 2020 the need for starter homes for younger families with a view to identify the need, and a suitable site, in the period 2021-2031. A number of other, less significant policy amendments were also made at that stage – as described in the separate consultation statement accompanying the Plan version sent to Tewkesbury Borough Council in November 2015.

166 This Environmental Report accompanies the submission draft Plan. The main conclusions of the assessment leading to this Environmental Report, following formal public consultation by Winchcombe Town Council on a draft Neighbourhood Plan can be summarised as follows:

Overall, the plan has been put together in a way that delivers a high level of protection of the environment and integrates considerations of the environment into all relevant policies

During plan preparation, the main issue of concern was the potential impact of housing development affecting the nationally designated Area of Outstanding Natural Beauty and having a significant adverse environmental impact; the policy presumption was clear – that such development should not be permitted unless there was a clear need and no satisfactory alternative locations

Borough policy was nevertheless driving the need to find sites for housing development in or adjacent to Winchcombe

During the development of the Plan, two specific local needs were identified – provision of housing for older people looking to downsize, and starter homes for younger households – sites were identified


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where those needs might best be met (at Almsbury Farm and in an area behind Mercia Road (known as “West of Winchcombe”)

Following public consultation, the Town Council concluded that there was not enough evidence of the need for housing for younger families (on the West of Winchcombe AONB site) to meet the National Planning Policy Framework tests for major development

Instead, the draft Plan was amended to include a commitment to review by 2020 the need for starter homes for younger families with a view to identify the need, and a suitable site, in the period 2021-2031

On the other hand, the Assessment showed that those national policy tests could be met by a proposal to develop dedicated housing for older people and a care home on land at Almsbury Farm - a development would also bring offsetting benefits in the shape of new uses for a long disused barn and land no longer used for agriculture

The overall impact of the plan policies proposed was likely to be positive (by comparison with not having a Neighbourhood Plan). The Plan would enable Winchcombe to thrive as a living, working town set in an outstanding environment and conserving its historic character. New jobs, better protection of natural assets, better design and improved working and living conditions would all be encouraged by the Plan. The community would be stronger as a result of its engagement with the process to positively shape and direct development that is outside the strategic elements of the Tewkesbury Borough plan.

If the Almsbury Farm site was to be excluded, there was no other suitable site available or potentially available with the same advantages of bringing listed buildings back into economic use.

If there was no plan at all, the goal of strengthening the community through engagement in its own development needs (the goal set out in the National Planning Policy Framework would) not be met and local people would remain disengaged from development control decisions.


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ANNEX

Screening Matrix (based on: European Commission, 2001 – Figure 1#)

1. Name of project or plan WINCHCOMBE AND SUDELEY NEIGHBOURHOOD PLAN

2. Brief description of the project or plan

PLAN FOR DEVELOPMENT IN WINCHCOMBE AND SUDELEY

3. European Site (brief description of the site that has been identified)

The nearest European Site to the Winchcombe and Sudeley NP boundary is Dixton Wood Special Area of Conservation (SAC). This site is outside of the NP area, lying approximately 3km to the north west of Winchcombe parish boundary.

Assessment Criteria4. Describe the individual elements

of the project (either alone or in combination with other plans or projects) likely to give rise to impacts on the European Site.

Having considered the types of development proposed in the NP, the location of that development, and the distance from the SAC, it is considered unlikely (alone or in-combination) that the W&S NP will have an impact on this site. There are none likely to give rise to such impacts

5. Describe any likely direct, indirect or secondary impacts of the project (either alone or in combination with other plans or projects) on the European Site by virtue of:

Size and scale; Land-take; Distance from the

European Site or key features of the site;

Resource requirements (water abstraction etc);

Emissions (disposal to land, water or air);

Excavation requirements; Transportation

requirements; Duration of construction,

operation,

NONE


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decommissioning etc; Other.

6. Describe any likely changes to the site arising as a result of:

Reduction of habitat area; Disturbance to key species; Habitat or species

fragmentation; Reduction in species

density; Changes in key indicators

of conservation value (water quality etc.);

Climate change.

NO CHANGES OF THIS KIND WILL BE EXPERIENCED BY ANY DESIGNATED EUROPEAN SITE

7. Describe any likely impacts on the European Site as a whole in terms of:

Interference with the key relationships that define the structure of the site;

Interference with key relationships that define the function of the site.

NO IMPACTS ARE LIKELY ON ANY EUROPEAN SITE

8. Indicate the significance as a result of the identification of impacts set out above in terms of:

Loss; Fragmentation; Disruption; Disturbance; Change to key elements of

the site (e.g. water quality, hydrological regime etc).

NOT APPLICABLE

9. Describe from the above those elements of the project or plan, or combination of elements, where the above impacts are likely to be significant or where the scale or magnitude of impacts is not known.

NOT APPLICABLE


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10. Outcome of screening stage (delete as appropriate).

Not likely to have a significant impact on a European Site alone or in-combination with other plans/projects.

11. Is the appropriate Nature Conservation Body in agreement with this conclusion?

YES as confirmed by Natural England email to Tewkesbury Borough Council dated 15/1/14 – ‘I would not anticipate significant impacts on statutory nature conservation sites such as SSSIs or European protected sites’.


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