What will cabinet and councillors vote to do with the Revised Core Strategy this week? We are urging them NOT TO ACCEPT the strategy for Thornbury.
Core Strategy Submission for Thornbury: Vital information & questions for SGC Cabinet – 13th December, 2010.
You are being asked today to consider the revisions and recommendations that form South Gloucestershire’s Core Strategy. Our focus is on the Thornbury section, which received 739 representations during the consultation, 96.5% of these were against housing development at Park Farm.
Save Thornbury’s Green Heritage do not believe that the changes made to the Core Strategy address the issues facing the town, and the ‘preferred’ location for development at Park Farm is simply not justified by the evidence. There has been insufficient evidence gathering and a lack of consultation about the options – certainly no basis to make critical decisions that will change the town forever.
Vital information and questions we believe you should address at this stage before accepting the Core Strategy include:-
1. The so-called ‘defensible boundary’ of Morton Way (SA para. 4.41a/c and 4.42)
Where did the phrase ‘the community’s desire to protect land beyond Morton Way from development’ spring from? When was Thornbury asked this question? In the TTC residents’ housing questionnaire in 2008, a majority of the people who responded preferred Morton Way for development – in fact giving it more votes than for all other sites combined. If it is the Thornbury Town Councillors’ desire to allocate a ‘defensible boundary’ to protect land beyond Morton Way, this should have been made clear. The 700+ representations objecting to the proposals for Park Farm in the Core Strategy demonstrate the community’s strong desire to protect land at Park Farm. A petition of 100 Morton Way residents did not want development at Morton Way, but they did not want it at Park Farm either.
Who has decided that the Park Farm site ‘…is set by physical boundaries which will limit the extent of development, therefore a precedent would not be set for longer term expansion and there would be less likelihood that development here would encourage an unsustainable commuter suburb’? Where are these boundaries? If a road really is a limit to development, there is Oldbury Lane and Butt Lane to the north, but what on the west? Kington Lane? The River Severn? Surely this is a recipe for Oldbury and Thornbury to be combined into one commuter sprawl.
There is no justifiable evidence regarding ‘defensible boundaries’ to show that Morton Way sites are not sustainable, but Park farm is sustainable.
In addition to this, during the ‘issues and options’ phase of the Core Strategy, the ‘options’ for Thornbury were not properly investigated, resulting in a Sustainability Appraisal which wasn’t published until March 2010, after Park Farm had been selected. The other options for Thornbury have therefore been dismissed before being properly investigated. There has been no level playing field.
2. Park Farm is NOT the only option capable of enabling the Castle School to consolidate (SA para. 4.41c)
Your officers are saying that Option 6 is the only option capable of realistically enabling the Castle School to consolidate onto a single site at Park Road. Have you challenged them to justify this statement? Other options could allow for this to happen, so why are these statements being made? In any event, the Core Strategy should be about meeting Thornbury’s housing needs, not those of one school.
In addition, are you sure that the updated plans have the support of the Castle School’s Governing Body? We believe they do not. In fact, we are aware of governors who have been told nothing of the changes proposed and how it will impact the school (including a road going through their playing field to Park Road from the housing development).
The role of land at the sixth form site being used in the negotiations also needs investigating. (If Barratts are being offered land here in exchange, it may be in breach of Article 107(1) of the EC Treaty in relation to state aid. Open market values on the land should be sought through open competition (as with the recent situation between Bristol City Council and Bristol City Holdings Ltd).
3. No longer any valid justification for Park Farm Option 6 (para. 4.42)
In paragraph 4.42 the updated version crosses out many of the justifications made in the draft SA for supporting the Park Farm site – because they aren’t true! It isn’t closer to the town centre compared to Morton Way sites; it doesn’t have community support; it isn’t the only site not in a conservation area!
In addition, there is incomplete evidence for justifying housing development at all on the basis of falling primary school rolls and improving town centre vibrancy (also para. 4.42). The empty shop premises (which conveniently exclude Tesco as it is deemed to be ‘out of centre’) are way below national and Bristol averages (9.52% in Thornbury, 13% nationally, and 15% in Bristol), and primary school numbers are now rising significantly! One primary school in Thornbury (St Mary’s) has had to go to appeal this autumn to expand its places.
4. The destruction of an historic deer park adjoining Thornbury Castle, St Mary’s Church and the Medieval Fishponds (para. 4.42)
Are you actually aware of the historical significance of this site? (If not, STGH have a map available).
Are you aware of the five 300 year old hedgerows, the three listed monuments, the six listed buildings, the streams, the wet woodlands, the SNCI Parkmill covert? Are you aware that English Heritage (which advises the Government) has submitted objections to this site being developed – saying not enough baseline evidence has been collected on the historical and environmental character of the area to inform plans? They also support the scheduling of the Medieval Fishponds.
Building houses here – however carefully landscaped – will eliminate the kingfishers, egrets, curlews and lapwings, and destroy a significant area of historic parkland forever.
In addition to this, despite what is written in paragraph 4.42, the reasons for the last National Inspector finding Park Farm the least suitable site for development and Morton Way the more favourable option have not changed since 2006. If anything, there is more evidence for preserving the heritage of the Park Farm site. Surely this far outweighs a claim (in paragraph 4.41a) of two SNCI’s located near to Morton Way, which development could negatively impact upon if not managed appropriately?
5. What can you do at this stage?
When considering the part of the Core Strategy relating to Thornbury, please do not approve the plans for Thornbury. These vital decisions must be backed up by proper fact based evidence to support the correct conclusion, and with full consultation. There are a ridiculous number of changes being made to the Thornbury section (it has practically been rewritten). This will take time to consider properly - it can’t be rushed through.
If you just accept what is put in front of you today, there will be no further opportunity to review/consult, particularly as the Director for Planning is asking for delegated powers to carry out amendments before submission to the Planning Inspector. We request you not to grant this delegated authority, which would allow the planners to make further changes to the detail of the submission without any opportunity for public scrutiny or debate.
The PINS advisory visit (by Planning Inspector Simon Emerson) in 2009 suggested that the Core Strategy could identify broad options for development in Thornbury, rather than define a site allocation. Surely it would be preferable to reappraise the housing need and development options for Thornbury before making such a huge decision based on flimsy evidence. With Oldbury and Shortwood for example, there has been a deferment on the decision as set out in the Strategic Housing Availability Assessment.
You are probably aware that Cllr Clare Fardell, who represents NW Thornbury, questioned the choice of the Park Farm site at the JPSE Committee last Wednesday, expressing concern that the other site options seemed to have been dismissed. Please support this and investigate it further.
The National Planning Inspector will be scrutinising the development of the Core Strategy. We have gathered documents and evidence (many through Freedom of Information requests) that demonstrate the inadequacies of the process and the current conclusion to build at Park Farm. We are happy to discuss these further, but in the meantime we ask that you do not approve the Core Strategy section for Thornbury.
Produced by Steering Group of Save Thornbury’s Green Heritage 12th Dec 2010
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