Written evidence submitted by Alderton Parish Council [NPP 199]
Alderton is a small rural parish in north Gloucestershire with 268 houses within the main village envelope and some outlying housing to the east and south. The northern side is AONB with some Special Landscape Area.
Alderton Parish Council is facing an onslaught of speculative planning applications from developers and should these all receive permission for development then the village could increase in size by around 70%. (See map at the end of this document).
Representatives of Alderton Parish Council recently took part in a Planning Appeal (APP/G1630/A/13/2209001) under Rule 6 Party status as we believed that the application by Charles Church failed to address the sustainability of their proposed application in the small rural village of Alderton. We are currently awaiting the outcome of this Appeal.
The Parish Council have produced a Village Design Statement and are now undertaking a Neighbourhood Development Plan. Alderton residents are not against development per se and through the NDP will identify how the Parish can accommodate some sustainable development over the next 20 years.
This evidence is being submitted as the Parish Council feels that the NPPF has created a developer led planning system that fails to address the key issue of the sustainability of housing in small rural locations.
Below it the closing summary that Alderton Parish Council submitted to the Planning Inspector at the Charles Church Appeal (APP/G1630/A/13/2209001) which details our view that the NPPF fails to address small-scale, sensitive development in rural villages which allows the community to absorb further residents on a sustainable basis.
Closing Summary - Alderton Parish Council
Charles Church Appeal, Alderton
As representatives of Alderton Parish Council we wish to give our sincere thanks to the Inspector for allowing us to present our objection to this proposal at this Enquiry.
Alderton Parish Council's objection to the proposed Charles Church development is centred on the unsustainable aspects of the proposal.
We have listened with care and respect to points made by our learned friends but have heard nothing that changes our core argument. We reiterate that the proposal does not meet the Core Principles of the NPPF in relation to housing, transport and employment. In addition, we would like to register our support for Tewkesbury Borough Council and fully endorse their stance in respect of the AONB.
In our submission we looked at housing, transport and employment and explained why we felt these three issues combined together rendered the proposed development unsustainable, and have referenced our arguments consistently against the NPPF.
Housing
We emphasised the need to attribute proper weight to the terms 'sustainable development' and raised questions around building affordable houses in unsustainable locations where the requisite local services and infrastructure are lacking.
The provision of services within Alderton was clearly outlined, with evidence provided to show that these would not be sufficient to support a development of this size. The lack of sympathetic design and layout, coupled with little attempt to connect it to the countryside surrounding it, do not in our view make it a credible proposal. It is a standard Charles Church blue print urban design and it is in effect a housing estate bolted onto a village in a rural setting. The proposed designs such as Knowsley, Redelstone, Houghton and Longleat can all be found on Charles Church sites throughout different parts of the country and as such no effort has been made to make the development more representative of the varied design within the village or indeed take into account its demographics.
Transport
We have brought to the attention of the Inspector that the proposed development does not benefit from sustainable transport modes and have shown how it does not meet the requirements of the NPPF.
The use of National Statistics by the Appellant is irrelevant to Alderton's situation and did not in any way counter the argument with regards to sustainable transport modes. It is worth noting that the average distance travelled to work for Alderton residents according to the latest Census is 19.6km which significantly exceeds the England average of 14.9km.
**** Alderton's situation does not offer residents a choice of sustainable methods of transport to access employment or amenities such as medical facilities, not provided within Alderton Parish.
Residents may wish, if able, to walk, cycle or make use of public transport. However, in Alderton's case, distances to walk, poor permeability for cyclists, and timetabling and frequency of public transport, preclude these choices. Therefore, Alderton's residents do not have choices as required by the NPPF as they are reliant on the use of private cars as more sustainable methods of transport are not available to them.
We also demonstrated that the potential increase in traffic flow arising from the development would have the propensity to affect road safety within the village and on major roads around Alderton. Statistical information was provided to support this concern.
Information was provided to show that the infrastructure in and around the village was not sustainable to support a development of this size. All roads in and out of the village are single track lanes and are not able to accommodate significant increases in traffic volumes that this development would create.
Employment
Our argument put forward was to evidence that opportunities within Alderton and the Local Authority Ward for Winchcombe are extremely limited and that development of the proposed site by Charles Church would not create a significant number of long standing jobs in the local community.
With reference to the NPPF we argued that housing should be located where people can walk, cycle or use public transport to travel to work. The very limited public transport services to and from Alderton does not make this possible as indicated above.
We have shown that the current employment opportunities in Gloucestershire both full time and part time exist in sectors that typically require employees to be flexible and work evening and / or weekend shifts. Once again the lack of flexible public transport system restricts opportunities for people without a private car, to apply for such roles. People should have the choice to use public transport, walk or cycle if they wish to.
Madam, we would like to take the opportunity to clarify the position of the Parish Council with regards to development within the village. Objections to development proposals submitted to date have been on the grounds of unsustainability. The Parish Council are seeking proposals that are proportionate, phased and relevant to the infrastructure of the village and that are able to be absorbed without undue detrimental effect on the existing community. The Chairman instigated the formation of the Service Village Forum in order to expedite the allocation of the 880 houses under the Joint Core Strategy across the identified Service Villages. This is an indication of the positive approach the Parish Council is taking.
In addition the question arose around Affordable Housing and we would like to bring to the Inspector's attention that the Parish Council has been proactive in looking to provide Affordable Housing on suitable Rural Exception Sites. If the present development applications were not in course, local Affordable Housing requirements could be fulfilled, as we have come across a site that would fulfil the local need. However, the Parish Council is not able to proceed because of the various development proposals recently submitted and the volume of allocation that has been proposed under these proposals.
As already highlighted in my colleague’s presentation on Housing, the information used within the Tier 3 audit is inaccurate and we are grateful to the Inspector for the opportunity to clarify this further. We would like to stress the point that Alderton is in no way comparable with Bishops Cleeve and Winchcombe; Alderton is a rural village of approximately 270 dwellings, neither a sprawling urban development, nor an expanding market town and therefore needs to be looked at on its own merits.
Much has been made of TBC's lack of a 5 year land supply and it is of course true that this is not where it should be. However, it is the Parish Council's opinion that this should not mean building at any cost, anywhere, particularly in unsustainable locations. A presumption in favour of sustainable development does mean choosing with care, being location aware, understanding what it is like to live in that place, and taking into account what the disadvantages would be for new residents as well as the advantages. Of course it also means not allowing objections based purely on selfish local interests.
However, that is not what we are doing here. We are weighing the harm against the good. It is our argument that the potential harm of disproportionate scale building in Alderton will destroy what new residents could expect to obtain by moving there. It will do nothing to reduce the carbon footprint, rather it will add to the traffic movements already occurring around here on an increasing scale.
It is our case that Alderton is a location for small-scale, sensitive development that can be absorbed without strain on everyone concerned. It is not a place to build a new Bishops Cleeve without significant alteration to every aspect of infrastructure: roads, school, shops, medical services, public transport. To do that will undermine, even destroy legislation put in place to preserve valued landscapes. That legislation has been put in place for a reason and has been tested over the period of this Public Enquiry.
Make no mistake, allowing this application will open floodgates which could see Alderton double in size within 18 months. Madam, as you are aware, there are several other applications already in the pipeline and we are advised that Charles Church has an option to develop the site in question today further, signalled by the revised Beckford Road Structural Landscape Planting Plan.
Finally, we wish to make it clear that Alderton residents are not against development per se, and indeed it has taken the lead by working with Tewkesbury Borough Council to formulate a Neighbourhood Development Plan for Alderton Parish, which will seek to identify how the Parish can accommodate some sustainable development over the next 20 years. However, any development must be proportionate to the size and location of the Parish, be introduced gradually to allow the community to absorb further residents on a sustainable basis, all of which is backed up by the recent Community Consultation exercise and its resultant findings.
Alderton matters, this decision matters.
