SCROLL DOWN FOR THE FOLLOWING DOCUMENTS:
1.) DETAILED LIST OF KEY OBJECTIONS TO CORE STRATEGY.
2.)ANALYSIS OF THORNBURY TOWN COUNCIL SURVEY RESULTS
3.)OPEN LETTER TO TOWN AND SOUTH GLOS COUNCILLORS EXPRESSING KEY CONCERNS.
1.)LIST OF KEY OBJECTIONS TO CORE STRATEGY:
Representations: Core Strategy pre-Submission Publication Draft
Site: Thornbury
HOUSING NUMBERS & LOCATION DO NOT REFLECT THE VIEWS OF LOCAL PEOPLE
ð The consultation process failed to engage with most of Thornbury’s residents. The Response to Issues and Options reported 82 responses (only 45 in favour of some new housing). Thornbury Town Council’s questionnaire had 148 responses, with 41% wanting NO housing, and a further 20% between 0 and 500 houses (roads of approximately 100 houses were given as examples). This site of ‘housing opportunity’ has been selected without taking into account the views of local people. The Town Council questionnaire results, (albeit less than 1% of residents) did NOT identify this site as favoured. The housing development site options were considered at an ‘invitation only’ stakeholders meeting in Oct ’09. Are Thornbury residents not stakeholders? What about a representative from the local area that could be impacted?
The Core Strategy should not be specifying numbers of houses or a ‘Preferred Site’ before proper research, reviews, appraisal, and consultation have taken place.
THE CORE STRATEGY PRE-SUBMISSION PUBLICATION DRAFT & SUSTAINABILITY APPRAISAL REPORTS DO NOT LEND THEMSELVES TO CONSULTATION
ðBetween them, these documents are several hundred pages long and the primary means of responding is online. The representation form itself is long and intimidating. In my opinion the methods of engagement for this consultation are insufficient, and may well discourage the true voice of local people from being heard.INADEQUATE EVIDENCE & CONSULTATION USED FOR JUSTIFYING THIS HOUSING DEVELOPMENT
ðThe Planning Inspector reported on the South Gloucestershire Local Plan 2006 (pg 322-334), having considered several potential development sites for Thornbury, “I have no reason to question that there is a strong local requirement for affordable housing in Thornbury. However, the role of the local plan is not to simply provide housing where there is shown to be demand. The locational spread of housing should reflect national, regional & strategic guidance... I do not consider that sites should be allocated for development in this town. The concerns about the effect of expanding a dormitory town, close to Bristol, are very real and outweigh the desirability of any planned measures aimed at meeting local needs within the town” So, I would question why this is now being ignored? Why is housing development, only 4 years ago considered unsustainable, now suddenly sustainable for Thornbury?
ðOne major justification for this development is the decline in vibrancy of the town centre. I object to this justification, as there is no evidence that the problems associated with the town centre can be rectified by adding a new housing estate to the edge of the town. A key aim sited for any housing development in Thornbury is that future inhabitants are able to comfortably walk or cycle to the town centre - in order to discourage car use, promote healthy lifestyles and encourage town centre shopping (instead of driving to the Mall). We do not believe there is a proven relationship between whether a resident walks or cycles into the town centre for their shopping and the area of Thornbury/distance from centre they live in. In addition many of those who the housing is targeted at will be elderly or families with young children. ðFalling rolls in primary schools should not be cited as justification for a new build in Thornbury. Despite a decline in the birth rate in recent years, the Office of National Statistics reports a new rise from 2008/9. There is an ebb and flow to birth rates and school rolls, and it is reactive and unjustifiable to base housing development policies on this.
ðThe development of the Castle School, and in particular the possible re-build of the whole school should not be dependent on this new housing development.
ð I support the reasonable justification relating to the fact that the average age of the population is increasing; and there is a decrease in household size – suggesting there could be a need for some homes for downsizing and affordable starter homes.
INADEQUATE/FLAWED SUSTAINABILITY APPRAISAL RESULTING IN THIS AREA OF HOUSING OPPORTUNITY BEING SELECTED
ðMany of the conclusions drawn from the Sustainability Appraisal document and its Appendices are not evidence-based, but rather drawn from subjective, inconsistent or assumptive statements. The site proposed for housing has not been accurately portrayed in this document and its conclusions cannot and should not be upheld. In addition, why has a site been selected before the completion of the Historical, Environmental, and Character Assessments and the technical work to determine flooding implications?ð ECOLOGICAL IMPACT. The use of descriptive language to detail the natural and ecological assets of some of the 6 original sites is noticeably missing when NW Thornbury is described. It has beautiful meadows stretching across the Severn floodplain, meandering streamways and the rich habitats of the woodlands and wetlands surrounding the Medieval fishponds. Although 5.1 of Appendix 10/11 suggests that there are no records of notable or protected species of flora or fauna, there is considerable evidence that there is an abundance of it. Notable/protected species, including bats roosting, badger sets, SongThrush, Plovers, Fieldfares, Kingfishers, Owls, Egrets, Woodpeckers, Shrews, field Mice, as well as protected plant species (records available)
SNCI at Park Mill Covert and the woodland and Medieval Fishponds are particularly ecologically valuable areas that should, without question, be protected from any more housing development. In fact the government has ordered an independent review of Wildlife Networks. Building here will destroy the wildlife network that allows wildlife to move freely.
ð LANDSCAPE IMPACT / HERITAGE This site has a network of well used public footpaths, including the Link path to the Severn Way. Views from these footpaths across the current rural landscape of open fields back across to Thornbury will be fundamentally changed by such a development. The Inspector commenting on South Glos Local Plan p.333 (2006) stated that the NW side of Thornbury had “landscape and heritage issues of some force…the NW edge of Thornbury is an extremely attractive and important one…makes a considerable contribution to the overall character and appearance of Thornbury”. He goes on to say (p334) that development at Park Farm “would detract considerably from the perceived character and appearance of this edge of the town and the wider open setting of the important properties found there.” These include the Listed Buildings of the Castle, the Sheiling School, Morton House and Park Farm. This must not be ignored - this site should not be developed.
ðAGRICULTURAL USE OF LAND. The Inspector described this (mainly Grade 2 agricultural land) area as having “land which is the best and most versatile for agriculture”. This does not seem to merit mention in the Appraisal Report, rather it is given a positive rating under 5.2. Every other site option considered with Grade 2 agricultural land in use was given a negative rating or ?. Yet again, there is serious bias being shown in the report.
ð HISTORICAL / ARCHAEOLOGICAL The green fields area proposed for development is very close to several heritage landmarks, which are very important to Thornbury’s character and value and need to be safeguarded from development. The setting of Thornbury Castle would be affected by development on its rural aspect over all the green fields to the NorthWest of Thornbury.
The Medieval Fishponds is a unique combination of wetlands, woodlands, Nature Reserve and Archaelogical site, one of only a handful in such a fine state of preservation in the country. We believe that Avon Biodiversity Action plan has identified Wet Woodland as a UK BAP priority habitat. The site is important enough for S. Glos Council to try to get it scheduled by English Heritage. Although proposals will be planned in accordance with Policy CS33, CS32, The Vision, CS1 & the Design Checklist, adverse impacts cannot be avoided, and the commitment is only to minimise these impacts. It’s character and appeal is supported by the adjacent rural green field landscape, which also provides a wildlife network in the area. This asset is too valuable to even consider having an impact on. In the Appraisal, it is unjustified that this site gets a positive score for impact on historical assets, whereas other sites get a negative rating for perceived impact.
ð ACCESS TO TOWN CENTRE Appendix 10 (2.4). I disagree with the statement that the proposed housing development site “will promote a stronger, more vibrant community because it has good access to the town centre”, whereas (areas A & B) adjacent to Morton Way “may encourage residents to use their cars to travel to the Mall for shopping rather than Thornbury town centre because of the ease of access to A38 and distance to Thornbury town centre”
The claim of being “very good access to town centre for walking” only applies to the very southern edge of this proposed area. As the crow flies, from the St Mary’s Centre to Park Farm House is 1.4km, whereas St Mary’s Centre to the main Grovesend/Morton Way roundabout is also 1.4km.
Likewise in 3.4, 4.1, 4.2 & 4.3 the conclusion that walking to the town centre has more potential in the proposed site, than site 1,2 or 3 for example, cannot be justified. Some parts of the proposed site are much further from the town centre than other sites that were considered too far and scored negatively. In addition, it is conveniently not mentioned that the proposed site is furthest from Tesco, the most frequented supermarket in Thornbury. The Inspector (South Glos Local Plan 2006 page 332), claimed that Park Farm “is above the desired maximum walking distance set out in table 1 of RPG10”
ðHEALTHY LIFESTYLES. There seems to be a lot of speculative suggestion that the imaginary people who will inhabit the proposed new build, will be more likely to walk everywhere, or cycle, or take public transport, will do their shopping locally in Thornbury, and wont travel to the Mall. They will leave their 500+ cars at home and wont impact on parking or contribute to traffic congestion. And, as a result, Thornbury town centre will spring to life….. I object to these claims , that are not evidenced, and should not be allowed to stand. Currently, the paths in this beautiful area are used extensively by many individuals and families, dogwalkers and birdwatchers for recreation, health & wellbeing. Building here could reduce healthy lifestyles for many in Thornbury.
In addition, will Thornbury’s Leisure Centre cope with an extra 500 households using it? Perhaps this would also have a negative impact on health?
ð TRAFFIC A major new housing development of 500+ houses with the only vehicle access onto Butt Lane will put excessive pressure on Thornbury’s roads, particularly during peak hours, with numerous negative impacts. I object to our local roads having to cope with an extra 500+ commuter journeys per day, A38 and M5 junctions even more clogged with traffic and Town Centre parking problems exacerbated. The Inspector (SGLP 2006) also claimed that development on Park Farm would “generate increased commuting along the A38, primarily to Bristol & the North Fringe”
ðTHE NUCLEAR POWER STATION. In my opinion, it is presumptuous to use any arguments pertaining to a new Nuclear Power Station as justification for more housing in Thornbury, when the outcome of that debate is still undecided. In addition, if Oldbury site was approved for a new nuclear power station, Butt Lane will need to cope with unmanageable increases in traffic.
ð FLOODING/SEWAGE. Despite the fact that there has been concern expressed regarding surface water run-oo and rhine levels, no negative score was allocated to this area in the Appraisal. Residents living near to the area by Park Farm have experienced considerable problems with flooding over the years. I object to housing development which is concretising significant parts of Thornbury’s natural floodplain & drainage system.
THE WAY FORWARD
ð TRY OTHER OPTIONS FIRST I support ‘some’ growth for Thornbury, but starting with a review of all potential Brownfill sites. Quite possibly, this could result in at least another 100 homes being built. Eg. If The Castle School was to give up its current Sixth-Form site, this would release a brown-field site that could be suitable for a small housing-development close to the Town Centre.If it is determined that yet more housing development in Thornbury is needed, there could be consideration of other accurately appraised options.
ð APPRAISE THE 6 SITES AGAIN, ACCURATELY. Re-examine some of the arguments you have used. For example, Why should Morton Way be a boundary for development? When this town was previously developed, the intention had been to develop beyond Morton Way, hence the size of the road and the underpass ‘path to nowhere’. Housing could be developed across this road and another ‘boundary’ set up. Remember that the Inspector (SGLP 2006 p333) concluded that “Park Farm is much less suitable for development than Morton Way”
The Green Belt, extending around the north side of Bristol, right up to the South and Western edges of Thornbury was never created to protect Thornbury from expansion, but is often quoted as a reason for protecting Thornbury from expansion in those directions. Sites 4 & 5 in the South & West are closest to the town centre and provide balance around the High St. Development here could be more sustainable in terms of benefitting the elderly and young families with easy access to the town centre etc.
ð PROTECT GREEN SPACES: USE GREEN BUFFERS/WEDGES TO PROTECT ALL OF THORNBURY
The new Government’s Green Paper on Planning highlights the need to protect Green Field sites from development. I support the setting up of green buffer and wedge policies to protect the whole of the town from unlimited Greenfield expansion.
ðFollowing the General Election, the new coalition government has announced that it will rapidly abolish Regional Strategies. Local Planning Authorities have been urged to have regard for this in any decisions they are currently taking. Be mindful of the fact that the planning system is to be reformed to give people and communities more power over their lives.
2. Analysis of Thornbury Town Council’s Residents Questionnaire
Total responses to questionnaire 148 (approx 1.2% of Thornbury residents).
Need more Yes 87 58.8%
Housing ? No 61 41.2% i.e. only 3:2 in favour
--- -----
148 == 100%
How much 0 61 41.2%
Housing ? 1 – 500 29 19.6%
(given examples 501-1000 19 12.8%
of roads with 1001-1500 21 14.2%
90 and 118 over 1,500 16 10.8%
Houses) Don’t know 2 1.4%
--- ------
148 == 100%
Where should Nowhere/No housing 61 41.2%
Housing go ? East (Morton Way
North (Butt Lane) 20 13.5%
West (Kingston Way
South (Leisure Centre) 4 2.7%
Infilling 1 0.7%
Nil response 6 4.0%
--- -------
148 == 100%
From these results, the Town Council concluded in their ‘South Glos Core Strategy Vision for Thornbury’ (Minutes 2009) that “local people saw a need for between 500 and 1000 new housing units”. This is not accurate.
If South Gloucestershire can be said to have a mandate for development by this survey (and this is debatable given the low sample and mere 3:2 support,) then this would only apply to building along Morton Way, since twice as many respondents indicated this area for any housing, compared to Butt Lane. Not that we are suggesting this course of action, merely that this is all the data supports.
Any other option simply cannot be validated by the data and so any such proposal would properly need to be put back to all residents for ratification in some new survey. Unilaterally deciding to switch from Morton Way Butts Lane
Observations on the Thornbury Stakeholder Workshop 20th October 2009
This document asserts itself to be a “factual report summarising the exercise results and opinions expressed by the participants …(which) … will be used to inform the drafting of the South Gloucestershire Core Strategy.”
However, the opening paragraph clearly also states that this workshop was in fact to launch Thornbury Town Council’s Town Centre Strategy. We therefore question how this can be a proper SGlos Core Strategy “stakeholder” workshop.
There is no representation from groups of residents across Thornbury at this workshop and selection of a day time for this event may well have excluded many interested parties from attending, particularly in a dormitory town from which most workers commute.
No community consultation was carried out in relation to appraisal of sites, despite the Statement of Community Involvement stating the Council “will seek input from the community on the issues that the Core Strategy needs to address and the options available to deal with the issues”. This to include ” ‘widespread public consultation”.
Analysis of Attendance List
10 x SGC facilitators
31 x “stakeholders”
10 x Developers and associated professionals.
7 x School based (six from schools receiving children from any Park Farm Devlpt.)
3 x Councillors (2 joint & 1 TTC.)
5 x Local community organisations
3 x Local businesses
3 x SGC Officers ( One planner and two education officers.)
Stakeholders were given a background to South Gloucestershire ’s Core Strategy process. They were accurately told that 60% of survey respondents were in favour of more housing developments, though there is no evidence in the report that they were told anything of respondents’ site preferences for development (i.e. twice as many voted for Morton Way as for Park Farm - in fact more votes for Morton Way than for all the other sites put together!)
Discussion of Education/Schools
The issue of falling rolls was discussed, but no evidence that 4 crucial issues were made plain:-
- Most benefit would go to the nearest schools and not be spread over all local schools, i.e. the nearest school would be saved and the remainder still be in crisis. (Six of the seven attendees represented the schools closest to Park Farm.)
- You cannot predict the age range of families moving into a new estate, i.e nursery & reception may be overwhelmed and the remainder unaffected by any new arrivals.
- Families grow up and fly the nest, parents stay much longer; after 10 years you are back where you started with a falling rolls crisis.
- The situation in Thornbury is no different to many other schools - it is a national problem and can only be resolved by downsizing capacity. This is best done before deciding where such small scale housing developments are sited.
- The birth rate has started to rise again and The Depart. for Children, Schools & Families (Mar 2010) project a large national increase in primary school children in next 8 years.
- Current government proposals to fast track applications for ‘Free School’ status to any parents or teachers wishing to set up their own school could at any time alter numbers entering the current primary schools.
Discussion of Employment
There were valid points made in relation to employment.
However, there is no evidence of where the necessary employment opportunities concomitant with a sustainable development would be sited. The future of Oldbury Nuclear Power was mentioned but, whilst possibly crucial to Thornbury Town Centre Strategy, this project is specifically excluded from the scope of South Gloucestershire ’s Core Strategy.
In a sustainable development project, the issue therefore remains; a 500 home development would require the support of c750 full time equivalent local jobs. There is no indication in the Workshop Report nor in the Core Strategy proposals where these would be sited in Thornbury. The Core Strategy proposals for Thornbury are therefore not “sustainable.”
There is also a myth at the heart of the “sustainability” philosophy that homes and employment opportunities arrive together and ‘travelling to work’ is thus reduced. However this can only happen in a “control/command” economy. If homes come to market first, people with jobs move in and travel to work elsewhere. If jobs are created first people commute from their existing homes. All you create is a bigger commuting nightmare.
However, town centre strategies are concerned with “footfall” not employment. Whether employed or on “benefit” the objective is to create a vibrant town centre where residents can purchase their weekly needs.
Discussion of Housing
The introductions stated
- “Any housing must respect the historic character & setting of Thornbury.”
- “Need to ensure that drainage & flooding issues are addressed and that any new housing development does not make existing issues worse”
Negative comments in respect of the loss of views of farmland or “green setting” were made for
- Option 1 (Upper Morton),
- Option 2 (
- Option
but were seemingly not recorded for Option 6 (Park Farm.)
However there was considerable interest recorded in the possible advantages for Castle School
The only negatives listed for Park Farm were the impact on the setting of Thornbury Castle (a major leisure service industry focus for the town!), the mediaeval fishponds & conservation area and also water run off towards Oldbury.
3. Letter written to Town and South Glos Councillors expressing key concerns.....
To:-
Thornbury Town Councillors
South Gloucestershire Councillors
Head of South Gloucestershire Spatial Planning
21st May 2010
Dear
Re: South Gloucestershire’s Core Strategy and proposed housing development in Thornbury
I am writing this initial letter on behalf of a significant number of Thornbury residents, who have very recently discovered that the Core Strategy proposes a housing development on the fields adjacent to the Park Farm/Parklands estate. This was only brought to the residents attention by the presence of surveyors in the fields at the beginning of this month.
Our intention is that this letter will raise some of our concerns and questions in relation to the development of the Core Strategy document and will open up the opportunity for some valuable dialogue between all parties, which will enable some true representation of the opinions of residents in Thornbury.
There has obviously been a process going on in the last 2-3 years that has resulted in Thornbury being identified as a town which will benefit from housing development, and this process has concluded with the identification of Park Farm/Parklands estate, from The Castle school all the way round to Butt Lane, as the favoured site for development.
From researching South Gloucestershire’s Core Strategy documents online and other documents/reports of relevant meetings, the consultation process appears to have engaged with less than 1% of Thornbury’s residents (less than 100 people) both in relation to whether Thornbury should be considered for additional housing development, and if so, which site is prefered.
Therefore in this letter we include:-
1. A summary of the issues and questions we wish to raise regarding the process of development of the draft Core Strategy and the consultation in relation to housing development in Thornbury.
2. Some initial comments and objections to the selection of the Park Farm estate as being suitable for development.
Firstly, going back to the 2008 Core Strategy Development Plan – Issues and options for Consultation,
the document claims to “provide opportunity to involve stakeholders & local communities in the development of issues & alternative options for meeting the future development needs of the area” (p.5).
From our understanding, the engagement with Thornbury residents has included a written questionnaire, a meeting/drop in at Turnberries/Armstrong Hall, and comments invited on the document. Other workshops/meetings have been arranged for key organisations/stakeholders.
With regard to Thornbury, this document states that “The key issue to discuss is whether Thornbury should be considered to take some additional development” (p.111)
The conclusion of the engagement was that there IS a role for further development in Thornbury, particularly due to shops declining, Primary school rolls falling and need for affordable housing.
THE ISSUES WE WISH TO RAISE REGARDING THE CONCLUSION THAT THORNBURY SHOULD HAVE ADDITIONAL 500 HOUSING DEVELOPMENT. (questions in green):-
· QUESTION 73 of the questionnaire asked residents whether more housing should be allowed in and around the edge of Thornbury (YES/NO) “in the light of primary school rolls falling/shops declining”
According to the Summary of Responses to this Issues & Options Document, only 82 members of the public answered this question, with only 45 saying ‘Yes’. The Turnberries consultation was attended by 30-40.
Do you believe this response rate can accurately reflect the opinion of Thornbury residents, bearing in mind there are 12,000 inhabitants?
Have serious questions been asked about the appropriateness of the community engagement methods, especially as the conclusions have a very serious impact on the health & wellbeing of Thornbury people?
Not one of us has any recollection of a public consultation meeting being brought to our attention during 2008 (although it appears it was put in the Thornbury magazine/library), yet just in the last couple of weeks, more than 100 residents reactions to the housing development proposal have ranged from “unbelievable” and “outrageous” through to “devastating” for Thornbury.
· The Summary of Responses also shows that 7 out of 9 Town Council/Political groups/Councillors answered YES to this question 73. Should these groups not be reflecting the views of Thornbury residents?
· Feedback on this same question was only gained from 3 Environmental/Community/Other groups, but from 11 Developers/Landowners/Consultants. Is this really getting a balance of views from the whole community?
· In this Summary of Responses Document, a further question asked from those who wanted more housing was “how much & where should it go?” This gave a range of ideas/preferences for potential sites around Thornbury. Development of the area around Park Farm is not mentioned here - the nearest is “West of Town behind Castle School
· One of the comments quoted in the Summary Of Responses document following a ‘Yes’ to Question 73 was “there is no certainty that more houses will help local businesses”. Has this issue really been analysed and explored? Have real questions been asked of local businesses as to why they find it difficult to set up business in Thornbury town centre? (We are willing to provide statements from local people who have wanted to set up business in Thornbury centre but have been prevented from doing so due to lack of affordable premises). How much evidence do you have that a new housing development will ensure the Town’s vibrancy? Did you witness the carnival in 2009 or the Food Fairs and see the vibrant Thornbury community overflowing the town centre?!
· We are interested to know whether there is real evidence of a demand for 500 more houses in Thornbury (apart from developers/other business interested parties)?
· The falling rolls of Primary Schools has been quoted in the Draft Core Strategy as a justification for requiring housing development in Thornbury. The falling roles are demographic - since 1999 there have been fewer pupils in maintained nursery and primary schools owing to the decline in births since 1990, according to statistics from the DCSF. There are many issues and perspectives that need to be considered in relation to falling rolls and although this is obviously an issue for Thornbury, as it is for many towns & villages across the country, has it been fair to use this to justify this proposed housing development? (500 houses doesn’t even solve the problem).
· The Governments Planning Policy Statement 7 In relation to the reluctance to build on Greenbelt (which only partially surrounds Thornbury), Has consideration been made of the use of ‘Rural Buffers’ and ’Green Wedge’ Policies to restrict development on our green fields, thus ensuring that Thornbury has protected green space all the way round?
Although the Core Strategy is now about to be produced as a glossy hard copy (rather than just an online pdf) and distributed across South Gloucestershire, we are asking that you reconsider the conclusions regarding whether there should be additional housing development in Thornbury.
We strongly believe that you have NOT carried out meaningful consultation with the people of Thornbury on the proposal and the subsequent identification of a favourable site.
We are therefore asking that this is addressed by engaging with the community in a meaningful way and seeking the views of residents, particularly those who will be most affected by the proposals.
South Gloucestershire’s website states that we are now invited to make comment on the Core Strategy. Not negating the above comments and questions, I move on to detail our initial response to the selection of Park Farm estate for the development of approx 500 houses. We will build on this information during the consultation period and provide you with more detail as to our objections in due course.
THE INITIAL ISSUES AND QUESTIONS WE WISH TO RAISE REGARDING SELECTION OF PARK FARM ESTATE FOR THE DEVELOPMENT OF UP TO 500 HOUSES:-
· Lack of consultation with the community regarding selection of this site
To reiterate some of the above, there was no consultation with Thornbury residents who would be most affected by this proposed development before this site was recommended. Therefore it was literally ‘a bolt out of the blue’ to discover surveyors in the Park Farm fields adjacent to Butt Lane and phone up S.Glos Planning (on 6th May ’10 )to find out this area was included in the proposed for development even though it isn’t marked on the Core Strategy online document (p.169 Fig 13). Is this satisfactory conduct?
In addition to this, we have discovered that the questions regarding housing development that were put in the Thornbury Magazine back in June 2008 came with a map showing 3 different areas of Thornbury with around 100 houses in each so that people were aware what 100 houses looked like on the ground. Now it is 500 houses – so was there any consultation at all on this number?
· Impact on historical heritage landmarks of Thornbury.
The green fields area proposed for development is very close to several heritage landmarks, which are very important to Thornbury’s character and value and need to be safeguarded from development.
1. The setting of Thornbury Castle would be affected by development on its rural aspect over all the green fields to the NorthWest of Thornbury. We contacted the General Manager recently, who had not been made aware of this proposed development.
2. The Medieval Fishponds. This area is a unique combination of wetlands, woodlands, Nature Reserve and Archaelogical site. One of only a handful of medieval fishpond sites in such a fine state of preservation in the country. We believe that Avon Biodiversity Action plan has identified Wet Woodland as a UK BAP priority habitat. Isn’t that what we have here? The site is important enough that we understand S. Glos Council is trying to get it scheduled by English Heritage. Although proposals will need to be planned in accordance with Policy CS33, CS32, The Vision, CS1 & the S.Glos Design Checklist, adverse impacts cannot be avoided, and the commitment is only to minimise these impacts. It’s character and appeal is supported by the adjacent rural green field landscape, which also provides a wildlife network in the area. Our view is that this asset is too valuable to even consider having an impact on. How can development in this area therefore be justified?
· Conservation & wildlife interest
Although 5.1. suggests that there are no records of notable or protected species of flora or fauna, the community living on the doorstep of this area can provide evidence that the area F has many sightings of notable/protected species, including bats roosting, badger sets, hedgehogs, SongThrush, Plovers, Fieldfares, Kingfishers, Owls, Egrets, Woodpeckers, Shrews, field Mice, as well as protected plant species.
SNCI at Park Mill Covert and the woodland and Medieval Fishponds are ecologically valuable areas that should, without question, be protected from any more housing development. In fact the government has ordered an independent review of Wildlife Networks. Are you proposing to build on an existing wildlife network when it seems the current consensus is to restore these networks that allow wildlife to move freely?
· Transport/commuter traffic issues. Vehicular access is proposed on to Butt Lane. The addition of 500 more households with cars needing access onto Butt Lane and A38 will have a major impact on the town. It has already been recognised (in the Core Strategy) that about 40% of Thornbury commutes out of the town to work. Have you considered the impact of the additional traffic on to Butt lane at key commuter times?
With all the uncertainty of nuclear power development affecting this area, and with it the considerable issues/implications re transport and other factors, why compound the problem with proposing housing in the area most affected?.
· Access to Town Centre. Appendix 10 (Thornbury Broad Area Appraisal Matrices) Re 2.4. Please can you justify your conclusion that the proposed housing development site (area F) “will promote a stronger, more vibrant community because it has good access to the town centre”, whereas area A & B adjacent to Morton way “may encourage residents to use their cars to travel to the Mall for shopping rather than Thornbury town centre because of the ease of access to A38 and distance to Thornbury town centre?
(As the crow flies, from the St Mary’s Centre to Park Farm House is 1.4km, whereas St Mary’s Centre to the main Grovesend/Morton Way roundabout is also 1.4km).
Likewise, 3.4, 4.1, 4.2 & 4.3 conclude that walking to the town centre has more potential in site F than Site A & B for example, despite the not dissimilar distances involved (as above). Please can you justify the conclusion that car travel is significantly more likely for accessing the town centre from site A & B, compared to site F?
· Floodplain issues. (Residents living near to the area by Park Farm have experienced considerable problems with flooding over the years (statements available if required). We understand however that Policy CS33 states that technical work will be carried out to demonstrate that development wouldn’t increase the likelihood/severity of flooding at Thornbury or Oldbury).
· Right to views from public footpaths
This part of Thornbury has a network of paths and public rights of way that are regularly used by numerous walkers (including dogwalkers, runners and families) and birdwatchers for recreation. Views from these footpaths across the current rural landscape of open fields back across to Thornbury will disappear. Some of Thornbury’s heritage will be lost. What about the rights to a view from public rights of way?
· Change in the Government policy on ‘Communities & Local Government’
The new Government Programme includes abolishing Regional Spatial Strategies and returning decision-making on housing/planning to local councils and communities. The Government also promises to ‘protect green areas of particular importance to local communities’. David Cameron, speaking in the last few days has said “ we know that when you give people and communities more power over their lives, more power to come together to make life better – great things happen”. Why not use this in support of abandoning a planning proposal that we would argue is compromising the heart of the community’s wishes and quality of life?
Thank you for your time in considering these issues and questions. We look forward to receiving a response.
Representatives from the Park Farm/Parklands Way estate and ‘Save Thornbury’s Green Heritage’ would also be happy to meet and discuss these issues further with representatives from any of the parties involved in making these key decisions on behalf of Thornbury.
Yours sincerely,
Grace Davies
“Save Thornbury’s Green Heritage” (Chair)
Cc:
Steve Webb MP
Liza Gillespe – Thornbury Gazette
