Bredon & Bredon’s Norton
Parish Council
Bredon Village Hall
Main Road
Bredon
Tewkesbury
GL20 7QN
01684 773 984
bredonpc@btconnect.com
Chairman: Mr A Woodward
Clerk: Ms J Shields
The Planning Inspectorate
3/18 Eagle Wing
Temple Quay House
2 The Square
Bristol
BS1 6PN
12 June 2014
Dear sir or madam
REF. APP/H1840/A/14/2217607 [APPEAL BY KNARSBORO HOMES LTD, SITE AT
LAND OFF CHELTENHAM ROAD, BREDON, TEWKESBURY, GL20 7ND]
Bredon Parish Council submitted comments to Wychavon District Council on 12 July 2013, 25 July
2013 and 7 October 2013. This correspondence should have been forwarded to the Planning
Inspectorate. This letter seeks to add to these comments, while avoiding repetition of points that
have already been made.
Bredon is a community that thinks carefully about its future development. The parish achieved
some of the highest participation rates in the West Midlands Regional Spatial Strategy and South
Worcestershire Development Plan (SWDP) consultations. The Parish Council has undertaken
studies of the amount of affordable housing it requires, and the level of housing that is sustainable
when set against local employment provision and key services. With the community’s assistance, it
produced a detailed Village Design Statement (VDS) which was adopted as a Local Information
Source by Wychavon District Council in September 2011. This is attached for your reference.
Preferred sites
The Parish Council believes that if the principles of sequential test planning are applied, there are
better locations for development within Bredon. The Parish Council’s response to the South
Worcestershire Joint Site Allocation & Policies Development Plan identified two preferred sites for
development which together could accommodate 49 houses. These sites are centrally located
within easy walking distance of the key village services clustered around Church Street. One of
these sites (Oak Lane) has recently been granted outline planning permission for 24 dwellings and
full planning permission is now awaited.
It is important that new development does not contribute unnecessarily to increases in road traffic.
Bredon suffers from the fact that the school, nursery school, shop / Post Office, pub and church are
all located in the historic heart of the village in narrow, medieval lanes. There is already acute
congestion in Church Street at peak times, blocking access to homes and businesses. Because the
Appeal site is located at the extremity of the village, with poor pedestrian links, it will lead to a
significant increase in car journeys within the village exacerbating these problems.
Employment opportunities are limited in Bredon and the overwhelming majority of working
residents commute by car to local towns. The proposed addition of 33 dwellings will not be
matched by any new employment provision within the village. The development would therefore
be less sustainable than alternative sites located near the towns and cities of the sub-region.
In these respects the proposed development is contrary to NPPF 34, which states that “decisions
should ensure developments that generate significant movement are located where the need to
travel will be minimised and the use of sustainable transport modes can be maximised”.
Figure 16. Morning congestion in Church Street, near the junction with Main Road and Back Lane.
Over-development in Bredon
Since the beginning of the SWDP plan period (2006), 86 houses have either been built or granted
planning permission. Planning applications and appeals are pending for a further 141 dwellings
across four different sites (including the Appeal site). In 2006, there were approximately 790
dwellings in Bredon village. Development of all the extant permissions would lead to growth of
29%, with the majority of this growth falling within a five year period. In the Parish Council’s
view, this would be extremely detrimental to the community’s cohesiveness and sense of its own
identity. It would also make the settlement less sustainable, as the schools, shops, amenities and
services would become increasingly unavailable to residents, forcing people to travel elsewhere.
For these reasons, the proposed development does not satisfy NPPF 54, which states that “in rural
areas local planning authorities should be responsive to local circumstances and plan housing
development to reflect local needs”.
Biodiversity
The Parish Council notes the comments of Kemerton Conservation Trust, Worcestershire Wildlife
Trust and Wychavon District Council relating to the importance as the Appeal site as an area of
Green Infrastructure between two nature reserves. The Parish Council takes its duty seriously under
the Natural Environment and Rural Communities Act 2006 in having regard to the purpose of
conserving biodiversity. It is strongly opposed to development which is likely to have damaging
environmental consequences, when likely harms can be avoided through the development more
sustainable alternative sites.
Traditional orchard
The Parish Council has secured funding for the restoration of traditional orchard around the village
of Bredon. If the Appeal is dismissed, the Parish Council will seek to use its funds to expand and
enhance the traditional orchard at this key gateway site, as has happened on the opposite side of the
road at Upstones Orchard under the aegis of Kemerton Conservation Trust.
Removal of Inclosure Act Hedge
The Parish Council notes the comments submitted to the Planning Inspectorate by Mr Duncan
Priest’s solicitors and barrister, to which the Parish Council has also been party. It strongly agrees
with Mr Priest’s case that the hedge should be retained in its entirety, and would be prepared to
bring its own locus standi to bear in support.
Mineral Safeguarding Area
The Parish Council believes that safeguarding mineral deposits ought properly to have been
included among Wychavon District Council’s refusal reasons. On this subject, Wychavon’s
planning officer stated,
“One of the primary constraints is that there should be a 200m buffer strip from a
potential working area to a settlement group of 6 or more dwellings. If this approach
was applied with respect to the application site, clearly none of the area identified as
having the potential for minerals deposits would be extracted from since the whole site
lies within 200m of the edge of the village.”
However, it appears the officer had not fully taken account of the requirement under the NPPF to
protect Mineral Safeguarding Areas from unnecessary sterilisation by non-mineral development. In
particular, he did not recognise that the effect of the proposed development would be to move the
200 metre buffer strip approximately 100 metres further south, resulting in the sterilisation of a
large additional area.
The attached plans (1:14000 scale and 1:2500 scale) illustrate that the proposal would sterilise
approximately 8 acres (3.2 ha) of potentially realisable sand and gravel deposit (these plans have
been prepared electronically in AutoCAD and is accurately dimensioned). It should be noted that
the factors which according to the officer would constrain gravel extraction on the Appeal site itself
(the proximity of housing and an 11kV electricity line) would not apply to land lying south of the
200 metre buffer zone.
The sterilised area forms part of the Kinsham deposit identified on the Hereford & Worcester
Mineral Resource Map 1999. The deposit covers approximately 50 acres, and is bounded by the
railway to the west, Bredon to the north, the B4079 to the east and Kinsham village to the south.
An 8 acre reduction in this area could potentially jeopardise the economic viability of the entire
deposit, depending on the depth of gravel across the site.
The Parish Council notes that the emerging Minerals Local Plan proposes a restoration led
approach. The Kinsham deposit lies near to (and directly between) two former gravel workings of a
similar scale – Kemerton Lake Nature Reserve and Croft Farm Waterpark. Both sites are now
important wildlife habitats, with Kemerton Lake being designated a Local Wildlife Site. In
addition, the former gravel working at Croft Farm lies at the heart of a successful water park and
outdoor recreation business, which is one of the parish’s principal employers.
In response to the original planning application, Worcestershire County Council (Ms Lucy Botterill)
commented as follows:
“Part of the application site is located within an area of identified Sand and Gravel
Deposit in the adopted Hereford and Worcester Minerals Local Plan. The County
Council is currently developing a new Minerals Local Plan and preliminary
investigations undertaken as part of its development indicate that this area is an
important mineral resource and, therefore, it is recommended that this area be
recognised as a potential extraction area. This does not mean that planning permission
for mineral working would be given, only that an assessment of the nature of the deposit
should be made to inform decisions about the use of the land… Given that part of the
proposed site is located within an area of identified Sand and Gravel Deposit and only
preliminary investigations have been carried out as part of the development of the
Minerals Local Plan, the Minerals Planning Authority would recommend that further
investigations into the nature of the mineral deposit is carried out before the above
planning application is determined. Once this information has been obtained it is
recommended that the Mineral Planning Authority is consulted on this information.”
The Appellant’s agent responded by ruling out undertaking the investigations recommended by Ms
Botterill.
Mr Nick Dean, Minerals and Waste Planning Policy manager at Worcestershire County Council,
recently reinforced the County Council’s earlier view in correspondence with the Parish Council
(attached herewith). He states,
“I wish to re-iterate this [Lucy Botterill’s comments above]; the NPPF and NPPG,
supplemented by the BGS report "Mineral Safeguarding in England good practice
advice" (2011) are clear that minerals are a scarce and limited resource that should be
safeguarded for future generations and that proper assessments of the value of
particular resources are a fundamental part of this policy. Any applicant`s refusal to
provide appropriate information would not be in accordance with the NPPF and would,
I consider, be a material consideration which counted against their proposal.”
Given that given the proposed development would have the result of sterilising a significant area of
sand and gravel deposit in perpetuity, the Parish Council believes that a proper assessment must be
undertaken of the potential economic and environmental benefits that the deposit could provide
over the long term.
For the above reasons in addition to those given previously, we request that the Appeal is
dismissed.
Yours sincerely
Andrew Rhodes
Chairman of Planning Working Party
Bredon Parish Council