Cleve Park Appeal will take place in March or April 2018. Comments to be submitted by 30th November 2017. Watch this space for further information
Cleve Park objection from TRAPPD by Colin Gardner: Speaker Notes
Slide 2 – context; Map of Thornbury Above all in this planning discussion we need some context, so we start with a map. We should not just look at Cleve Park in isolation. It comes amid a string of applications that have been approved, only one of which (Park Farm) was consented by Thornbury Town Council. The impact is not only in the quantum of new houses, but the shape of the town is being stretched to the north and east – in a mirror image to what is happening to Bristol. Slide 3 – cumulative impact turns Thornbury into a dormitory town Slide 3 shows that starting from 5,000 houses in 2015 we have a rash of greenfield development so that if you approve Cleve Park today we will have seen almost a 30% increase in the size of the town. Add to that the next two in the pipeline and we’re up to 40%. Compare that to Employment - Since adoption of the Core Strategy in December 2013 South Glos has recorded in its employment land survey a net loss of 348 jobs. This does not include the Council Offices where some 300 people used to be employed. With falling employment and rising housing you are creating a dormitory town, with all the implications on things like traffic congestion that go with it. We think you have to look at the cumulative impact which is currently threatening the community and character of this town, and leaving us with an unsustainable impact on the capacity of our services. We are in the ludicrous position that the Core Plan, that was supposed to take us up to 2027, has now been completely overtaken in terms of housing development. Now it looks like the Joint Spatial Plan (JSP), which is supposed to take us to 2036, will suffer the same fate. In TRAPP’D we worked hard to make sure the people of Thornbury understood the threat that the JSP posed, and to that end in November we managed to fill the Armstrong Hall to capacity to hear about controversial developments which included Cleve Park. So, having got a lot of people involved in the democratic process to comment on the JSP, how on earth can we be in this room today, before the JSP consultation has been considered, and potentially be about to approve a key element of that plan?
Slide 4 – Stress on town infrastructure is unsustainable, but fudged in Cleve Park report On slide 4 I want to show you a deep dive on one aspect of infrastructure, GP capacity, to illustrate both the increasingly desperate situation in Thornbury, and the deceptive, shoddy, unprofessional way this has been assessed in the Cleve Park report. In your Infrastructure Delivery Plan, published in March 2014, you correctly reported that the 3 surgeries in Thornbury had 11.95 Full Time Equivalent GPs, giving and average 1,796 patients per GP. The Full Time Equivalent bit is important here because we have a number of doctors working part time, and the definition is given at the bottom of the slide. This compared poorly with the NHS Gloucestershire standard of 1,700, and also versus the average in England of 1,520. You identified that to satisfy your Core Strategy you would need two more GPs, and you observed that there was insufficient space, but that extension was possible. Now we come to the Carney Green report, commissioned by the Developer. They correctly identified and reported updated information, produced by the Health & Social Care Information Centre, based on 2014 data, and also using the Full Time Equivalent methodology. By now you see that Thornbury has gone up to 2,069 patients per GP, and the gap is opening up with England overall, and also with South Glos and West of England. But Carney Green didn’t use this data to draw their conclusion, presumably because it didn’t fit the story their client wanted to tell. So they created their own statistic by obtaining information from HSCIC on patient numbers, then divided it by a headcount of the number of GPs mentioned in the Surgery websites – i.e. regardless of whether they were full time or not. This gave a misleading figure of 1,510 patients per GP, which they then declared was below the capacity. This is not simply inaccurate information, it is false information. The idea that you think you can get objective, reliable research from consultants bought and paid for by the Developer I find stunningly naïve. Now, you might think that your Planning Officer would ask about this glaring anomaly, or the fact that the picture looks entirely different from the one painted by your own report in 2014. But no, he simply quotes the numbers and concludes, in para 5.174 that the extra demand “can be absorbed by the existing practices”. In fact, the latest available data from NHS England (January 2017) shows the number of GP FTEs has actually decreased by almost two from the level reported in your infrastructure report, and the number of patients per GP is now at a critical 2,090. Taking into account houses that have been approved but not yet built, up to and including Cleve Park, we would be adding more than 300 patients for each FTE GP, taking us to over 2,400 patients per GP if we followed the recommendation in this report. Our view is that the Planning Report has been written to support a pre-judged conclusion that this application should proceed. To do so a world of “alternative facts” has been created. I’ve shown you one major flaw in it. There are others, and these will prove fertile grounds for a judicial review should you decide to agree with the conclusion that “the social and environmental harms of this development are not significant”. Slide 5 – Cleve Park proposal will tower over other developments In slide 5 I want to draw your attention to some specific features of this proposal which we think make it completely inappropriate. Firstly, although the applicant has made some very minor adjustment to heights, the proposal includes 3 storey blocks of flats with Building Height Parameters at 12m. This is way taller than anything else that’s been approved so far. It will tower over the existing housing along Morton Way, being 50% taller, as well as sitting on a hill. This means that the ridge line will be a huge 9-13m above the houses opposite. 3 storey 12m tall blocks of flats are quite frankly totally inappropriate to anywhere along the rural edge of Thornbury let alone on land lying significantly higher than the adjacent houses. We see no justification in ever going above a Building Height of 9m, and these proposals will be completely out of character with their surroundings, having a highly overbearing impact on the adjacent houses and a significantly harmful impact on the views both for existing residents and from the popular public paths and cycleway above. Please also bear in mind that the proposed 12m build height would set a record for the rural edge of Thornbury and a precedent for future applications to follow.
Slide 6 – inappropriate location and design We think that the site location is also completely unsuitable for this proposal. It is outside of the 1,200m circle from the town centre, and therefore beyond South Glos’s recommended limits of distances to health services, shops etc. Also, the location on Grovesend Road will greatly increase congestion on that road approaching the traffic lights. We have serious concerns about the inevitable impact of the traffic calming measures which will restrict the traffic flow along Morton Way – this is a designated distribution route and was built to assist the flow of traffic around Thornbury. Previous development along Morton Way has introduced underpasses to prevent impeding this route – it does not make any sense to approve an application that needs calming measures along this significant distribution route. We also point out that it’s proposed to be built on land that drains into a level 3 flood zone, and that is the reason why there are no less than 17 attenuation ponds! The applicant has no partner for the end use of the care home or other non-residential buildings and these will not be built until they have. This should be of serious concern – this land could be left derelict for years unless the council allows yet more housing here instead.
Slide 7– Summary – our view in TRAPPD In summary, we believe that it is unsustainable to carry on adding more and more greenfield development to the north and east of Thornbury. At some point you have to draw the line, and we believe we’ve already reached that point. We believe we have demonstrated the conclusionsin the Planning Report are unsound. Moreover, we think we have shown that this particular proposal is inappropriate in both Location and Design. At this moment, the Core Strategy still applies, and we believe it gives ample valid planning reasons to reject this application. The Core Strategy says about Thornbury that it will be “a thriving and socially cohesive market town …. supported by an appropriate amount of high quality housing growth”. At the time of its adoption the Core Strategy did not include this development. Please start to follow your own Core Strategy and reject this application.
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