DRAFT JOINT CORE STRATEGY 2013
CONSULTATION RESPONSE FORM
This form can be used to make a response to the Draft JCS consultation. Please feel free to use
additional paper as necessary.
Completed response forms should be sent to: Joint Core Strategy Team, Municipal Offices,
Promenade, Cheltenham, GL50 9SA and received no later than 5pm on Tuesday 26 November 2013
(extended to 13th December 2013).
Full documentation can be viewed and comments made via the JCS website at www.gct-jcs.org.
CONTACT DETAILS:
Name:
Phil Hardwick
Postal address (including postcode):
Email address:
If you are responding on behalf of an organisation, please give their details below:
Name:
Robert Hitchins Limited
Postal address (including postcode): The Manor, Boddington, Cheltenham, GL51 0TJ
Email address:
plhardwick@robert-hitchins.co.uk
Preamble
Robert Hitchins Limited welcomes the publication of the Councils’ preferred option for the Joint
Core Strategy as an important step in the adoption of a new development plan for the area. It is of
vital importance in terms of securing the most sustainable outcomes that the plan is progressed as
quickly as possible to adoption.
It is noted that comments are specifically sought on four key questions and our responses to each
are set out below. These cross refer to a number of appended documents providing additional
evidence in support of the Company’s comments and form part of these representations.
1. Position Statement: Strategic Allocation Innsworth/Twigworth (Page 15)
2. Position Statement: Strategic Allocation Ashchurch (Page 47)
3. Position Statement: Strategic Allocation land north of former MoD site Ashchurch (Page 86)
4. Position Statement: land at Ashchurch/Fiddington (Page 90)
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We also comment on the other policies contained within the consultation document.
CONSULTATION QUESTIONS
QUESTION 1
Do you think our strategy of focusing on urban extensions (i.e. development sites located around
Gloucester and Cheltenham) is the correct one? If not, where would you propose to locate the new
development?
The strategy is supported where such development can be achieved without unacceptable harm to
the environment and without unacceptably compromising Green Belt purposes.
However in view of the Green Belt and other constraints around Gloucester and Cheltenham and
the need to meet housing and employment needs it is necessary, as the Plan does in part, to
identify other areas where development should take place during the plan period. However it is
considered that additional development should be allocated at Tewkesbury/Ashchurch.
QUESTION 2
Do you think that we have identified the right sites based upon the strategy mentioned in question
Q1? If not, which other sites within the JCS area would you suggest and why?
Support the Strategic Allocation at Innsworth and Twigworth (Policy A1). A comprehensive and
integrated urban extension can be achieved which is in close proximity to Gloucester City Centre
in a location that makes only a limited contribution to Green Belt purposes. Attached at Appendix
1 (page 15) is a Position Statement setting out more detail in respect of the development concept
envisaged, phasing, delivery and a summary of the on-going baseline work.
Support the Strategic Allocation for employment generating uses at Ashchurch. The location is
highly accessible making it attractive to job generating uses and relates well to existing
employment uses to the north of the A46. A Position Statement setting out further information in
support of this proposed Strategic Allocation is at Appendix 2 (page 47).
Support the Strategic Allocation at former MoD site Ashchurch (Policy A8) for a mixed use
development comprising employment and housing.
Have some concerns regarding the
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deliverability of the brownfield element and the proposed phasing arrangements.
Our Policy
specific representation and the Position Statement at Appendix 3 (page 86) set out further
information/evidence in this regard. It is also proposed that this allocation be extended by 3.58ha
at the north eastern end to allow for access.
The sites identified at north Churchdown (Policy A2) south of Churchdown (Policy A3) and Up
Hatherley (Policy A7) are in areas identified in the September 2011 JCS Green Belt Assessment
as making a “significant contribution” to Green Belt purposes. The last site also being located in a
zone identified as having “medium sensitivity” (JCS Landscape Characterisation Assessment and
Sensitivity Analysis). For these reasons we have objected to the Policies allocating these sites.
In view of this and having regard to our comments in respect of the quantum of housing identified
it is considered that additional land should be identified to the south of the Strategic Allocation at
Ashchurch (Policy A9) for residential development. This location is unconstrained, has low
landscape sensitivity and is well located to take advantage of good transport links and proximity to
employment opportunities. A Position Statement setting out more information in respect of this is
included as Appendix 4 (page 90) to these representations.
In the longer term it is also
considered that land further south of this (ie balance of SHLAA Submitted Site 4) would also be
suitable for development meeting longer term needs.
In terms of development for employment generating uses we believe that the location around
Junction 10 of the M5 should be considered for allocation now. We also draw attention to a further
site at Coombe Hill (Junction of the A38 and A4019) outside of the Green Belt and in an
accessible location which will prove attractive to business.
QUESTION 3
Is this the right list of rural service centres and service villages and is this the appropriate amount
of new development for them?
List of settlements identified appears consistent with the evidence base set out in the Rural
Settlement Audit 2013 update.
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We do however have two areas of concern; first the overall quantum of housing directed to these
settlements and secondly the intention that these sites be delivered through the Tewkesbury
Borough Plan and neighbourhood plans.
First the proportion of net additional dwellings directed to rural service centres and service villages
appears high and would question whether this is the most sustainable approach.
Secondly deferring delivery of these sites to plans which might not be in place for many years will
impact on timely delivery.
QUESTION 4
Is there any aspect of the strategy that you wish to question or comment on as a result of additional
or alternative evidence? For example, do you have alternative information or evidence for how
much housing and employment should be provided, or what infrastructure is required to support
the proposed growth?
Would question whether sufficient land is identified in the JCS for housing.
The Councils’ evidence concludes that the objectively assessed need for the JCS area is in the
range of 33,200 – 37,400 dwellings. The lower end is proposed to be adopted with a commitment
to monitoring and early review (Policy SP1).
This does not sit comfortably with Government Policy as set out in the NPPF at paragraph 47
which requires that Councils should use their evidence base to meet the “full, objectively assessed
needs for market and affordable housing”. It is also inconsistent with evidence set out in the
emerging Gloucestershire SHMA 2013 which would point to higher housing needs than are being
planned for in the JCS.
A more robust response to reflect the inherent uncertainties in economic forecasting would be to
adopt at least a mid-range point (and probably the top of the range) now rather than relying on a
commitment to monitoring and early review to justify moving forward on the basis of a housing
requirement at the lower end of the objectively assessed need.
A failure to do otherwise risks the
plan being found unsound.
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It follows therefore that the target for the creation of new jobs should also be based on at least a
mid-point (and probably the high point) figure rather than the lower end. However in this context it
is noted that the JCS has substantially increased the amount of employment land it allocates to
provide “sufficient flexibility for employment needs not anticipated by the evidence base eg
unexpected changes in economic circumstances”. This is to be welcomed. It is worth contrasting
this approach with that taken for housing in the JCS.
Do you have any further comments? If yes, please reference the section/paragraph of the
draft JCS you are referring to.
See below:
Strategic Objective 2 Ensuring Viability of Town Centres
We consider that this objective should also recognise the role that allocated sites in up-to-date
development plans play in meeting identified needs for additional development. We therefore
recommend a slight wording revision to this objective as follows:
Creating the conditions for maintaining and strengthening a balanced hierarchy and network of
city, town and district centres by:

Providing for sufficient retail, employment, social, cultural, tourist and other appropriate
uses within the designated centres and/or on suitably allocated sites to improve their
vitality and viability, supporting accessibility and environmental improvements and town
centre regeneration measures.

….
Policy SP1 (Scale of new Development)
See our response to Q4 above.
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Policy SP2 (Distribution of New Development)
See our response to Q3 and Q4 above.
Policy SP3 (Delivery and Review)
In supporting this policy would point out that the identification of additional land for development
over and above that required would increase flexibility and increase certainty for delivery of the
assessed housing need.
Policy E1 (Employment, and supporting text)
Welcome the recognition in the supporting text to Policy E1 of the wider definition of ‘employment’
and the role of non ‘B’ class uses (e.g. retail, leisure) in generating employment opportunities.
Given that the JCS anticipates the 21,800 jobs needed to 2031 will primarily be created outside
the traditional B class uses, we do however question why it is considered that these other
employment generators may not necessarily have land requirements. This is particularly relevant
as the NPPF requires local plans to be proactive in meeting the needs of business.
Policy E2 (Retail Hierachy Town Centre, and supporting text)
There are a number of references in this policy and supporting text to ‘District Plans’. In the case
of Tewkesbury, this is presumably the Borough Plan for which consultation on the Scoping
Document has recently been completed.
This is therefore at an extremely early stage in the plan-making process.
The draft Tewkesbury Borough Plan is intended to focus on where ‘small scale’ development
should go, with the emerging JCS to identify where the larger sites for housing and employment
development should be located.
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Set against this context, we consider it is not appropriate for the exact town centre boundaries and
allocation of sites to meet the identified floorspace requirements to be defined in the ‘district plans’
as advocated by draft Policy E2. This is both with regard to their intended role and function and
the differing timescales for progressing the plans to adoption.
We consider the draft JCS should identify these key boundaries and sites; clearly over
210,000sqm net of new retail floorspace across the 3 centres of Gloucester, Cheltenham and
Tewkesbury to 2031 is of greater significance than ‘small scale’ development.
Furthermore, by bringing this important stage of the process into the remit of the JCS, rather than
deferred to the subsequent production of the District Plans, will enable provision to be made for
the eventuality that sites cannot be identified in the designated centres to cater for all the identified
floorspace need.
The NPPF makes it clear that it is important that needs for retail and other main town centre uses
are met in full and are not compromised by limited site availability. Local planning authorities
should therefore undertake an assessment of the need to expand town centres to ensure a
sufficient supply of suitable sites, including consideration of edge of centre sites and other
accessible locations that are well connected to the town centre.
We consider the draft JCS needs to make provision for the eventuality that town centre sites
cannot meet all of the identified need, by allocating sustainable sites outside the designated
centres and making clear that the Council will adopt a sequential approach to new retail
development not in an existing centre and not in accordance with an up-to-date development plan.
In terms of the identified convenience and comparison goods capacity, it is firstly not clear how the
floorspace figures have been derived; they do not appear to tally with the capacity tables produced
by the Council’s retail consultants, DPDS, in the 2011 JCS Retail Study which we understand to
form part of the evidence base.
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Whilst DPDS do acknowledge in the 2011 JCS Retail Study that the figures used in their
assessment ‘should not be used with undue precision’ (para 4.56) further understanding of how
these figures have been derived would be welcome.
Assuming they have been formulated on the basis of the JCS Retail Study 2011, we have the
following comments to make on that Study in terms of the comparison goods assessment:

There is a lack of clarity over how the centre turnovers and the turnover of assumed retail
commitments has been derived

The allowance for increases in floorspace efficiency is considered to be unduly high given
the prevailing economic conditions and significantly more modest expenditure growth rates
from 2009

A review needs to be undertaken to establish whether the assumed commitments have
come forward and what are the effects in terms of influencing market shares etc. This is
particularly given a number of the commitments were for increased non-food floorspace in
foodstores; an area which operators have been scaling back during the economic downturn

Only limited and passing consideration has been given to the prospect of enhanced market
shares for the key centres; the DPDS study is based on static market shares

As stated above, the DPDS study acknowledges that the figures cited are subject to some
uncertainty due in part to the use of sample data to estimate turnover and market share,
and around forecasting generally. The volatility of the retail market generally at present
adds to this uncertainty.
Accordingly, we consider the preamble to the floorspace table at Policy E2 B. should be more
circumspect and state:
B.
Over the plan period to 2031 provision will be made to accommodate new floorspace
requirements broadly forecast to arise as follows:
…..
It is the Council’s principal aim to target this floorspace within the existing designated centres
and/or on allocated sites, the extent of which are set out on the Proposals Map. In the event it is
not possible to meet the identified need in full, alternative sites will be promoted and considered in
accordance with the sequential approach.
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….
Finally, we also question the apportionment of the identified comparison goods floorspace capacity
and contend that the centres in greater need of new investment (e.g. Gloucester and Tewkesbury)
should benefit from more significant growth than the pre-eminent centre of Cheltenham. Identified
target floorspace figures should be rebalanced accordingly and following a review of the centres’
capacity to accommodate the new retail floorspace.
Core Policy S3 (Sustainable Design and Construction)
Concerned at the impacts this policy might have on deliverability and it is not clear whether it has
been the subject of viability testing.
The footnote to the policy acknowledges that there may be changes to national standards and in
this context would highlight the following:

Written Ministerial Statement on changes to requirements under Part L of the Building
Regulations (conservation of fuel and power) dated 30th July 2013 ;

DCLG consultation on “Housing Standards Review” launched August 2013 :

DCLG consultation on “Next Steps to Zero Carbon Homes – Allowable Solutions” launched
August 2013.
Policy S5 (Green Belt)
Objection is raised to the removal of land at north Churchdown, south Churchdown and Up
Hatherley from the Green Belt. These are in areas identified in the September 2011 JCS Green
Belt Assessment as making a “significant contribution” to Green Belt purposes.
The proposed Safeguarded Area to the west of the North West Cheltenham Urban Extension is
supported as it is not identified as making a Significant Contribution to Green Belt purposes in the
2011 Green Belt Assessment and is well located to provide for development in the medium/longer
term. Attention is drawn specifically to land in the north east quadrant of J10 M5 (Strategic
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Employment Land Availability Assessment site reference 7E) which lies within this area is well
located to provide now for employment generating uses.
Bearing in mind the need for Green Belts to have long term permanence and the need to plan for
future needs (beyond the plan period) it is considered that land in the vicinity of Boddington
(Strategic Housing Land Availability Assessment site reference SUB26) should also be identified
as Safeguarded land. This would include SELAA site reference 6E which by virtue of its location
would be suitable for allocation for employment generating uses.
SELAA site reference 8E (Land at Coombe Hill) also offers potential for employment generating
uses.
It lies outside the Green Belt in an accessible location, close to existing
business/commercial uses which would be attractive to business. An allocation for this use is
therefore sought.
Policy S9 (Conservation and Improvement of Biodiversity and Geodiversity)
Would question the use of the word ‘integrity’ in the last part of the penultimate paragraph which
applies to local sites (‘integrity’ is associated with the Habitats Regulations and is a strict test for
European Designations – which are clearly of far great value than a local site). Therefore suggest
the wording be amended to read:
“Development adjacent to or within locally designated sites will not be permitted where it would
have an adverse impact on the integrity interest/criteria for which of these sites are designated,
and harm to biodiversity or geodiversity cannot be mitigated.”
Policy S10 (Green Infrastructure)
This policy is supported.
The Position Statement at Appendix 1 of these representations
demonstrates how the Innsworth and Twigworth urban extension can link to and enhance the
Strategic Green Infrastructure identified to the north of Gloucester.
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The Position Statements at Appendices 2 and 4 demonstrate how significant green infrastructure
can be provided in association with development south of the A46 at Ashchurch.
Policy C2 (Housing Mix and Standards) and C3 (Affordable Housing)
It is noted that both these policies will be subject to change based upon the findings of the
Strategic Housing Market Assessment 2013. With that in mind we reserve our position at this
stage other than to point out that site viability is an important component in addressing these
matters. In the meantime we enclose with these representations a copy of our response to the
Gloucestershire Strategic Housing Market Assessment October 2013 (prepared by Pioneer
Property Services Ltd on our behalf and dated 20 th November 2013). This outlines a number of
concerns in respect of the conclusions drawn in the SHMA13 and the validity/soundness of basing
policy on this document.
In respect of Lifetime Homes standards see our response to Core Policy S3.
Policy C4 (Gypsy and Traveller Accommodation)
Whilst a need has been identified (GTTSAA 2013) there seems to be no evidence in support of the
site specific references to the urban extensions and strategic allocations.
It is understood that a county-wide call for traveller sites has been undertaken and this should form
part of the evidence base for site selection and sites identified through that process could be
allocated through the local plans currently under preparation.
Policy C5 (Community Facilities)
The clause “Developers will also be required to demonstrate that their proposals will have no
adverse impact on existing communities in terms of their access to essential services” appears
redundant given that the earlier part of the policy requires that new residential development
provides for and/or mitigates where there are any impacts.
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Policy SA1 (Requirements for Strategic Allocations)
Criterion A:
Not clear how the density is to be calculated. Also query consistency with other policies in the
plan in respect of: urban design (CP4), Residential Development (C1) and Supporting Healthy
Lifestyles and Wellbeing (C6). On the face of it would appear to be an unrealistically high density
moreover there are always pitfalls associated with a “one size fits all” approach.
Criterion F:
Question the need for this given it duplicates last clause of Core Policy S3 (Sustainable Design
and Construction)
Policy A1 (Innsworth and Twigworth)
This proposed urban extension is supported. It is sustainably located just to the north of
Gloucester in a part of the Green Belt that only makes a limited contribution to Green Belt
purposes. A Position Statement is included at Appendix 1 to these representations setting out
details in respect of the development concept envisaged, phasing, delivery and a summary of ongoing baseline work.
2nd Criterion
Not necessary to phase the development of Twigworth behind Innsworth – to do so will
compromise housing delivery. The Position Statement at Appendix 1 sets out further information
in respect of how we envisage this development being phased.
3rd Criterion:
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See Appendix 1 showing proposed location of nature reserve within this allocation and the location
of a central area of green infrastructure providing a focal point and opportunities for recreation and
leisure.
Attention is also drawn to Appendix 1 in respect of the proposed disposition of uses within the
urban extension.
Policy A2 (North Churchdown Urban Urban Extension)
Object to this allocation for the reasons set out above; namely located in a part of the Green Belt
that makes a significant contribution to Green Belt purposes
Policy A3 (South Churchdown Urban Extension)
Object to this policy for the reasons set out above; namely located in a part of the Green Belt that
makes a significant contribution to Green Belt purposes.
Policy A7 (south Cheltenham – Up Hatherley Urban Extension)
Object to this policy for the reasons set out above; namely located in a part of the Green Belt that
makes a significant contribution to Green Belt purposes moreover this land is located in a zone
identified as having “medium sensitivity” (JCS Landscape Characterisation Assessment and
Sensitivity Analysis).
Policy A8 (MOD Site at Ashchurch Strategic Allocation)
Allocation is supported however objection is raised to fourth criterion in that the phasing proposed
will at best very significantly delay delivery of houses during the plan period and at worst mean no
completions from this site during the plan period. There are a number of uncertainties associated
with the delivery of this land: including the timing and certainty of the closure process, site
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remediation and preparation timescales and there has to be a question mark over the viability of
redeveloping this site.
To address this it is suggested that development of the greenfield parts of the site are not
restricted until the whole of the MoD site has been redeveloped – it may never be and parts might
remain as existing. Appendix 3 to these representations demonstrates how land to the north and
north east of this site could come forward in parallel or if necessary in advance of the brownfield
elements.
This would have advantages not just in terms of delivery but would ensure the
necessary connections/links to the existing built up area to the west of the railway and attendant
social and community facilities thereby achieving sustainability at an early stage.
Policy A9
This allocation for employment generating uses is supported. The location is highly accessible
making it attractive to job generating uses and relates well to existing employment uses to the
north of the A46. Further information in support of this allocation including a summary of
environmental baseline information demonstrating the suitability of this land for development is set
out at Appendix 2 to these representations.
Policy D1 (Infrastructure)
The first two paragraphs of this policy appear contradictory insofar as the reference to ‘cumulative
impact’ in the first paragraph of this policy is at odds with the second paragraph which correctly
refers to planning permission being granted when the infrastructure and services to meet the
needs of the new development are in place. In other words does not require that infrastructure
and services for other developments are in place. Therefore suggest the final paragraph of this
policy is all that is needed
Policy D2 (Planning Assessments)
Not all of these assessments will be required for every major application and to require all would
place an unnecessary burden on development contrary to Government Policy.
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Appendix 1
Position Statement: Strategic Allocation “Innsworth Twigworth”
1
Introduction
1.1
This statement sets out further information in respect of the proposed urban extension to
the north of Gloucester at Innsworth/Twigworth and summarises the baseline work that has
been undertaken. It presents details of the emerging concept plan including land uses and
phasing thereof and sets out an expected delivery programme.
1.2
The objective is to deliver a sustainable, comprehensive urban extension to the north of
Gloucester which links with and complements the existing settlement pattern and provides
for housing, employment, social and recreational needs with access to extensive green
infrastructure that provides a focus for the urban extension.
2
Baseline Survey Work
2.1
Baseline survey work as detailed in Section 7 has been undertaken and has looked in detail
at all aspects of the environment in order to further inform the emerging concept plan.
3
Emerging Concept Plan
3.1
Having regard to the baseline survey work undertaken the plan below shows the key
components and how about 2,125 dwellings, employment land, local centres primary
schools, landscaping and open space could be accommodated without compromising
additional phases at Twigworth.
3.2
The employment is located so as to form an extension of Innsworth Technology Park,
additional employment land opportunities will be provided for within the local and
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neighbourhood centres proposed. The latter is located so as to integrate with existing
development at Innsworth.
3.3
The central green infrastructure provides a focal point for the development and is intended
to offer opportunities for leisure and informal recreation uses as well as areas managed for
nature conservation purposes. Footpath connections will link both parts of the development
both to each other and to the Gloucestershire Way.
Concept Plan: Key Components
Local
Centre
Future
Phase
Residential
Sch
Future
Phase
Central Green Infrastructure
Leisure and informal
recreation uses
Residential
SSSI
Residential
Nature
Reserve
Sch
Neighbourhood
Centre and
employment
Emp
Consented
Longford Site
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3.4
The area of ponds at the western end of the development offer further opportunities for
management for recreational uses but with more emphasis on nature conservation and
therefore it is proposed as a “nature reserve”.
4
Land Use Budget
South
Land use
Residential
Area (Ha) Amount
38.28 (net 35.97) up to 1,400 dwellings
Employment
2.64
Neighbourhood Centre (incl. emp.)
4.24
Primary School
2.05
Public open space (inc suds)
24.82
Total
72.03
North
Land use
Residential
Area in Ha Amount
19.62 (Net 18.45 ha)Up to 725 homes
Employment
0
Local Centre
0.32
Primary School
1.54
Public Open space (inc SuDs)
10.4
Total
31.88
Central Green Infrastructure
Land use
Informal leisure uses
Area (Ha) Amount
15.46
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5
Phasing
5.1
The plan below shows the phasing envisaged for the development. One of the advantages
of this urban extension is that an early start can be readily achieved using existing
infrastructure as demonstrated below.
2
1
3
2
3
2
2
3
3
1
2
1
6
Delivery Programme
6.1
The Tables below set out a proposed delivery programme.
1
1
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Pre-Commencement
Date
Event
March 2014
Application for outline planning permission submitted
September 2015
Outline planning permission granted
March 2017
Commence house building
September 2017
First financial completion
Delivery: accesses from A38, A40, Innsworth Lane and Frogfurlong Lane
Year ending March
Housing
Employment
Other
2016
2017
2018
65
2019
200
Neighbourhood
centre
and
employment and local centre
2020
200
Primary School (south)
2021
200
2022
200
1.00 Primary School (north)
2023
200
1.00
2024
200
0.64
2025
200
2026
200
2027
190
2028
180
2029
90
2030
2031
Total
2125
2.64
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7
Summary of baseline Survey Work
North
7.1
The following paragraphs summarise the environmental baseline studies which have been
undertaken to date in order to inform the concept of development of land north of Hatherely
Brook.
Landscape and Visual Context
7.2
The site consists of very gently sloping agricultural land predominantly under arable
production and adjoining the Orchard Park residential caravan park at Twigworth.
7.3
The site is made up of a number of fields divided by existing hedgerows in variable
condition. This existing vegetation has value for visual screening.
7.4
The site lies within the Severn and Avon Vales National Landscape Character Area (NCA
106). The landscape character of the site and its immediate surroundings is considered to
be fairly typical for the national character area.
7.5
At the county level the site is within the Settled Unwooded Vale landscape character type,
located within the Vale of Gloucester character area. The site and surrounding area are
fairly typical for the character area, described as “soft, gently undulating to flat
landscape… Mixed arable and pastoral land use enclosed by hedgerow network, in
places forming a strong landscape pattern; limited woodland cover with mature
hedgerow trees… Rural areas bordered by large urban and suburban areas and
interspersed with commercial and industrial premises…
Widespread network of
pylons and transmission wires.”
7.6
The site lies close to the boundary of the Rea, Maisemore Ham and Longford character
area, within the Floodplain Farmland landscape character type.
7.7
The Evidence Base for the Joint Core Strategy being developed by Gloucester City Council,
Cheltenham Borough Council and Tewkesbury Borough Council includes two studies which
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are relevant to landscape and visual issues: the Landscape Characterisation Assessment
and Sensitivity Analysis and the Landscape and Visual Sensitivity and Urban Design
Report.
7.8
The first of these reports identifies the site as being within the G6 Longford to Innsworth
Compartment which is assessed as being of medium-low sensitivity, where the level of
sensitivity is considered in terms of “a combination of the sensitivity of the landscape
resource, including landscape as a physical resource, its historical features and
elements and the visual sensitivity of the landscape itself such as views and
visibility. Importantly it is also a function of landscape value.” The reasons for this
assessment are given as:

Visually related to the city due to flat topography and peripheral housing areas;

Agricultural intensification has resulted in a degraded landscape character (particularly
south of the Hatherley Brook).

Some
landscape
features
have
endured
including
Innsworth
Meadow
SSSI
(unfavourable recovering condition), mature willows (some once traditionally pollarded),
some intact and dense hedgerows, meandering Brooks, ridge and furrow, and buildings
of historical importance.
7.9

Loss of tranquillity.

Good amenity access and value.
The JCS Landscape and Visual Sensitivity and Urban Design Report assess the site as
being of medium landscape and high visual sensitivity. However, the JCS Broad Location
as a whole is assessed as being of low landscape and visual sensitivity as “the area is
predominantly a flat, agricultural landscape with very little ecological and character
qualities which could be easily replaced or substituted except for one small area of
higher value around the designated SSSI”. The Draft JCS identifies that the main visual
receptor would be Tinkers Hill/Churchdown Hill to the south east of the site which carries
views across the vale.
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7.10 The proposals will retain the SSSI and opportunities for the green infrastructure
enhancement have been identified and will be designed so as to maximise landscape and
other benefits. It is therefore considered that the site is capable of accommodating
development.
Ecology
7.11
Extended Phase 1 Habitat Surveys have been undertaken at the site in 2012 and most
recently during the 2013 survey season.
7.12
A series of protected species surveys (Great Crested Newts, bats, Water Voles, Otters,
Badgers and reptiles) have also been undertaken at the site in 2012 and 2013 as well as
within the wider area periodically between 2004 and 2013.
7.13
The site is mainly intensively managed agricultural land divided by hedgerows, some of
which are considered likely to qualify as important under the Hedgerow Regulations 1997,
but with many being species-poor and of poor structure. Hatherley Brook runs along the
southern boundary of the site and there is evidence of the invasive Himalayan Balsam
along its banks.
7.14
No ponds are located within the site, although a small population of Great Crested Newts
have been recorded within a pond located approximately 197m to the north and within
ponds over 600m to the south. Optimal terrestrial habitat for Great Crested Newts is largely
absent within the site, being predominantly arable and grazed grassland, although the
hedgerows and areas of longer grassland have some limited opportunities. Therefore,
specific mitigation measures will be incorporated into the proposal to ensure that no
adverse impacts occur to Great Crested Newts.
7.15
A series of bat activity surveys have been undertaken within the wider area in 2004, 2006
and 2011 and within the site in 2013. Some of the habitats present within the site, such as
hedgerows, trees and the brook corridor present foraging and commuting opportunities for
this faunal group. The buildings located in the west of the site have been surveyed for bats
and no evidence of any roosts or potential for roosting bats was recorded. Trees exhibiting
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potential to support roosting bats have been identified in the site and are primarily Willows
located along the brook.
7.16
The majority of the habitats present do not comprise suitable reptile habitat, although the
longer grassland areas along the brook have some limited potential. Specific reptile surveys
were undertaken within the areas of suitable habitat in 2013, but no reptile species were
recorded.
7.17
No evidence of Water Vole has been recorded along Hatherley Brook during any of the
survey work undertaken.
7.18
Some potential Otter slides were recorded along Hatherley brook in 2012, although no
actual evidence in the form of spraint, footprints or hairs have been recorded during any of
the survey work.
7.19
Badger surveys have identified two disused outlier setts and one active potential annex /
subsidiary sett within the site. Furthermore a number of latrines and run-throughs have also
been identified within the site.
7.20
Opportunities for ecological enhancements within the proposed development will be
identified and these will be used to promote a net gain in biodiversity across the
development. In particular these will aim to incorporate the goals of the local Biodiversity
Action Plan.
Noise and Vibration
7.21
An assessment of the existing noise levels across the site has been undertaken through
unattended noise monitoring supplemented by attended sample noise measurements.
7.22
The exercise indicated noise levels within the site are influenced by a mix of sources.
Aircraft movements flying out of Gloucester Airport were observed frequently throughout the
day, influencing noise levels across the site. Road traffic travelling along the A38 to the
north of the site also influenced the noise environment within the northern area of the site.
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7.23
In order to inform a planning application, noise levels within the proposed development
areas will be assessed against the guidance contained within the NPPF and BS 8233, to
demonstrate that a satisfactory noise environment can be achieved within the proposed
residential areas of the proposed development.
7.24
Consideration would be given to providing appropriate mitigation, particularly within the
northern part of the site to ensure noise levels were reduced to a satisfactory standard.
7.25
With appropriate mitigation and design measures incorporated it is anticipated that an
acceptable noise environment for future residents across the site would be successfully
achieved.
Hydrology, Drainage & Flood Risk
Assessment of Flood Risk
7.26
A preliminary assessment of flood risk has been undertaken for the development of the land
at Twigworth.
Level 2 Strategic Flood Risk Assessment (L2SFRA)
7.27
The land at Twigworth is considered in the Level 2 Strategic Flood Risk Assessment
(SFRA) as part of its evidence base for the Gloucester, Cheltenham & Tewkesbury Joint
Core Strategy. The land forms part of L2SFRA ‘Site T9’ together with land at Innsworth and
consented land at Longford.
L2SFRA Exception Test:
7.28
The L2SFRA Exception Test (ET) concludes that “Given the size of the Site T9 it is shown
that the required housing (3,995 dwellings) can be delivered within the available area of the
site within Flood Zone 1. Development within Flood Zones 2, 3a and 3b should therefore be
avoided. Provided development is located within Flood Zone 1, the ET should not apply.”
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L2SFRA Comments & Recommendations:
7.29
The L2SFRA shows that parts of Site T9 are affected by Flood Zones 2, 3a and 3b with
historic flood outlines showing that areas of the site have been affected by fluvial flooding.
In addition, there is a risk of flooding from surface water and a residual risk from culvert
blockage.
7.30
The L2SFRA strongly recommends that any development within Site T9 is located fully in
Flood Zone 1 and the higher flood risk areas are kept as open space.
7.31
The L2SFRA recommends that for all development, it must be ensured that the vulnerability
of flooding from other sources is considered as well as the effect of the new development
on surface water runoff. A FRA will be required to demonstrate runoff from the proposed
development is reduced through the use of SUDs techniques. Where important surface
water flow paths are identified, it is recommended that these flow paths are taken into
consideration in the design layout of the development sites and are maintained to prevent
an increase in flood risk at downstream locations.
7.32
In general, existing access routes to Site T9 are unaffected by flood risk. Modelling has
shown that Tewkesbury Road is at risk from fluvial flooding during the 100 year event
adjacent to the western boundary of Site T9, associated with the Hatherley & Horsbere
Brooks. To the north of the flood risk area adjacent to the Twigworth land, the A38 is not
affected and access can be maintained.
7.33
Where a residual risk from a culvert blockage is identified, it is recommended these areas
are kept as open space and development is located towards lower risk areas. A culvert
maintenance schedule should be developed to periodically clear culverts of debris, which
will reduce the risk of blockage during a flood event.
7.34
Areas susceptible to surface water flood risk have been identified. It is recommended that
areas of high and moderate hazard are kept as open space and appropriate management
of surface water is employed, keeping flow risk paths clear, particularly where access
routes are affected.
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Flood Modelling & Flood Zones:
7.35
Site specific flood modelling for Site T9 has been carried out (Capita model for the
Horsbere and Hatherley Brooks), and details of the extents of the flood zones for the land at
Twigworth have been agreed with the Environment Agency (EA). The EA has confirmed
that the agreed 1 in 100 year flood extent (including an allowance for climate change)
should be used when bringing forward potential development in the Twigworth area.
NPPF Sequential Test:
7.36
In accordance with the National Planning Policy Framework (NPPF) Sequential Test
approach to development and flood risk, and in accordance with the recommendations of
the L2SFRA, development will be located in Flood Zone 1 which has the lowest risk (less
than 0.1% or 1:1,000 annual probability).
Site Specific Flood Risk Assessment (FRA):
7.37
In accordance with the requirements of the NPPF and the L2SFRA recommendations a Site
Specific FRA will be produced to demonstrate that the site can be safely developed without
flood risk, from any source, and without increasing flood risk elsewhere.
Sustainable Drainage System (SuDS):
7.38
Surface Water will be managed through the use of an appropriate sustainable drainage
system incorporating the surface water management train principles and including green
infrastructure such as basins, ponds and swales. The FRA will include details of a surface
water drainage strategy incorporating SuDS.
Water Quality:
7.39
The FRA will consider water quality and demonstrate that the development of the site will
not adversely affect the water environment and will identify ways in which the development
can contribute towards the enhancement of it, helping to improve the ecological status of
downstream watercourses.
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Development Levels:
7.40
To ensure that the proposed dwellings are not at risk from flooding floor levels will be a
minimum of 600mm above the 100 year flood level, including allowance for climate change.
Flood Routes:
7.41
The FRA will identify existing and proposed flood routes and ensure that existing paths are
maintained or enhanced and that new routes are provided to direct any surface water flows
safely through the development without causing flood risk to existing or new properties.
Safe Access:
7.42
Safe dry access is available from the A38 to the north.
Foul Sewerage Infrastructure:
7.43
Severn Trent Water has confirmed that there will be capacity within their foul sewerage
infrastructure to accommodate flows from the proposed development without any increase
in the risk of flooding.
Conclusion:
7.44
The preliminary assessment concludes that there is no significant flooding or drainage
issues that would prevent the development of the site. Therefore in terms of flooding or
drainage the land at Twigworth is considered to be a sustainable location for development.
Ground Conditions
7.45
A Phase 1 Desk Study of land adjacent to the A38 in Twigworth, Gloucester has been
undertaken in order to identify and evaluate the former/current site usage, environmental
setting and its likely contamination status. This has enabled formulation of a preliminary risk
assessment to determine any plausible pollutant linkages with regard to potential impacts to
human health and/or controlled waters, the results of which were used to define the scope
of Phase 2 intrusive works.
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7.46
A review of historical Ordnance Survey mapping confirmed little significant change to the
agricultural land use of the site from the earliest available mapping of 1883 until the present
day. The site possesses no buildings and there was no expectation of significant made
ground and/or contamination, although low-level contamination associated with the
former/current agricultural land use should not be discounted.
7.47
There are no recorded former or active landfills within the site or within potential influencing
distance. Historic mapping does however record a small number of infilled ponds outside
the west and northwest site boundaries, thus the installation and subsequent monitoring of
gas wells was recommended as part of the Phase 2 intrusive works.
7.48
In view of the above, the following potential sources and principal contaminants of concern
were considered relevant:

Toxic and phytotoxic metals, as well as polyaromatic hydrocarbon compounds within
general near surface made ground and/or topsoil

Insecticide/pesticide residues within topsoil

Gypsum crystals within natural Rugby Limestone Member clays/mudstones
representing a potential source of elevated sulphates/sulphides

7.49
Landfill-type gases generated off-site within potentially infilled ponds
A detailed contamination risk assessment including the above potential contaminants of
concern indicates that the site is effectively uncontaminated where there is no perceived
risk to human health and similarly no significant risk to controlled waters in light of the
proposed residential development. On the basis of the foregoing there are no areas
identified within the site where contamination may pose a constraint to future development
and thus there are no specific recommendations for remediation and/or supplementary
investigation.
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Cultural Heritage and Archaeology
7.50
An initial archaeological desk based assessment has been undertaken. This assessment
has established that there are no archaeological heritage assets of the highest significance
(designated or nationally important) identified within the site or its immediate proximity.
7.51
A number of built heritage assets, comprising nine grade II listed buildings, are identified to
lie within a 500m radius of the site. It is considered unlikely that development within the site
would result in any harm to these designated assets or their setting.
7.52
Non-designated heritage assets are identified within the site itself, represented by former
Medieval/Post-Medieval cultivation remains and a trackway, and an enclosure cropmark of
uncertain, but possibly Prehistoric/Roman date. Beyond these assets and based on current
evidence, a moderate to high potential was recognised by this study for the presence of
buried heritage assets of archaeological interest on the site dating to the Prehistoric,
Roman and Medieval/Post Medieval periods.
7.53
A number of historic hedgerow boundaries are identified to be present within the site which
may be considered important under the 1997 Hedgerow Regulations.
7.54
On the basis of the known non-designated archaeological assets identified on the site and
the potential recognised for further previously unrecorded archaeological remains to be
present, a programme of further field studies, initially comprising detailed geophysical
survey followed by trial trenching, was agreed with the local planning authority’s
archaeological advisor at Gloucestershire County Council.
7.55
Initial geophysical survey produced positive results, identifying a distinct group of
enclosures and settlement features, probably including hut circles, within the central area of
the site. Beyond these features, indistinct cultivation effects from remnant Medieval/Post
medieval ridge and furrow cultivation and later land drainage were identified, along with a
number of further discrete and widely scattered anomalies of possible archaeological origin.
7.56
On the basis of the results produced by the geophysical survey, further trial trenching was
implemented both to target the anomalies identified and to provide for an appropriate
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spatial sample of the site area. The majority of trenches excavated across the site produced
negative results for the presence of any significant archaeological remains beyond
remnants of former Medieval cultivation or later agricultural land use. Trenches targeted on
the previously identified enclosures recorded by geophysical survey at the centre of the site
have recorded corresponding below ground features to be present. Finds recovered from
excavated features in this area suggest the presence of a Middle to Late Iron Age to Early
Roman farmstead settlement, with recorded outlying features beyond suggesting the
presence of associated field systems. A number of further undated features were also
recorded, these potentially being contemporaneous with the settlement activity identified, as
well as evidence relating to a former trackway illustrated to have once been present on the
site on the 1799 Twigworth Inclosure map. The evidence from the evaluation indicates a
correlation between the recorded main foci of archaeological activity and the elevated and
level ground present across its central area overlooking the Hatherley Brook to the south.
The remains recorded are considered to be of no more than local to regional importance
and as such would not be of sufficient significance to preclude development.
7.57
The results produced by the field investigations undertaken on the site will be used to
inform the further development of a concept masterplan.
Agricultural Circumstances
7.58
An assessment of the agricultural circumstances arising at Twigworth has been undertaken
and it has been determined that the site is virtually equally split between best and most
versatile agricultural land in Subgrade 3a and a small area of Grade 2 and lower quality
subgrade 3b.
Land by agricultural land classification grade
Grade
Description
Area (ha)
Area (% of
agric. land)
2
Very good quality
1.3
4
3a
Good quality
14.5
45
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3b
Moderate quality
Total
16.2
51
32
100
Agricultural
7.59
The agricultural land is farmed as part of the Boddington Estate. The Estate farms some
490ha in the locality and is mainly concerned with arable crop production, though it also
rears pedigree Simmental cattle.
Summary
7.60
A number of environmental studies have been undertaken to date to establish the
parameters relating to the environment which are present at the site, namely landscape,
visual amenity, ecology, archaeology and cultural heritage, agricultural circumstances, flood
risk, drainage, noise and ground conditions. It is recognised that all of these environmental
aspects require careful attention in developing a design for development at the site.
7.61
The baseline evidence obtained to date demonstrates that land north of Hatherely Brook
(Twigworth) can successfully be allocated as part of a strategic location for growth.
7.62
In addition the following work is being undertaken to further inform the development
proposals including: a socio-economic assessment, transport assessment, air quality
assessment, sustainability assessment, waste minimisation report, affordable housing
provision, and utilities statement.
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South
Introduction
7.63
The following paragraphs summarise the environmental baseline studies which have been
undertaken to date in order to inform the concept of development of land south of Hatherely
Brook.
Landscape and Visual Context
7.64
The site consists of gently sloping agricultural land under grass and arable production on
the edge of the existing built development of Innsworth, a suburb of Gloucester.
7.65
The site is made up of a number of fields divided by existing hedgerows in variable
condition and a small area of woodland.
This existing vegetation has value for visual
screening.
7.66
The site lies within the Severn and Avon Vales National Landscape Character Area (NCA
106). The landscape character of the site and its immediate surroundings is considered to
be fairly typical for the national character area.
7.67
At the county level the site lies within the Floodplain Farmland landscape character type
and within the Rea, Maisemore Ham and Longford character area.
The site and
surrounding area are typical of the character area, described as “an open and expansive
area as a result of the flat landform and very limited tree cover… A predominantly
pastoral landscape with unimproved and improved grassland, with some areas of
arable farming…” The area to the north of Gloucester is noted as being an exception to
the otherwise generally limited extent of settlement.
7.68
The site is also close to the boundary of the Vale of Gloucester character area, within the
Settled Unwooded Vale landscape character type.
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7.69
The Evidence Base for the Joint Core Strategy being developed by Gloucester City
Council, Cheltenham Borough Council and Tewkesbury Borough Council includes two
studies which are relevant to landscape and visual issues: the Landscape Characterisation
Assessment and Sensitivity Analysis and the Landscape and Visual Sensitivity and Urban
Design Report.
7.70
The first of these reports identifies site as being within the G6 Longford to Innsworth
Compartment which is assessed as being of medium-low sensitivity, where the level of
sensitivity is considered in terms of “a combination of the sensitivity of the landscape
resource, including landscape as a physical resource, its historical features and
elements and the visual sensitivity of the landscape itself such as views and
visibility. Importantly it is also a function of landscape value.” The reasons for this
assessment are given as:

Visually related to the city due to flat topography and peripheral housing areas;

Agricultural intensification has resulted in a degraded landscape character (particularly
south of the Hatherley Brook).

Some
landscape
features
have
endured
including
Innsworth
Meadow
SSSI
(unfavourable recovering condition), mature willows (some once traditionally pollarded),
some intact and dense hedgerows, meandering Brooks, ridge and furrow, and buildings
of historical importance.
7.71

Loss of tranquillity.

Good amenity access and value.
Potential visual receptors are identified as residents of Longford, Twigworth, Innsworth and
Drymeadow Farm; users of the Gloucestershire Way and other public rights of way; and
staff at the Innsworth Technology Park and RAF Innsworth.
7.72
The JCS Landscape and Visual Sensitivity and Urban Design Report assesses the site as
being of overall low landscape and visual sensitivity as “the area is predominantly a flat,
agricultural landscape with very little ecological and character qualities which could be
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easily replaced or substituted except for one small area of higher value around the
designated SSSI.
The report identifies the main key receptor would be from Tinkers
Hill/Churchdown Hill to the south east of the site which carries views across the vale. The
report does assess part of the western end of the site around Drymeadow Farm as being of
medium landscape sensitivity and the northern and western parts of the site being of
medium visual sensitivity.
7.73
Opportunities for green infrastructure enhancement will be identified within the
development, and these will be designed so as to maximise ecological and other benefits at
the same time.
Ecology
7.74
Extended Phase 1 Habitat Surveys have been undertaken at the site periodically since
March 2004 continuing in 2005, 2006, 2011 and most recently during the 2013 survey
season.
7.75
A series of protected species surveys (Great Crested Newts, bats, Water Voles, Otters,
Badgers and reptiles) have also been undertaken periodically between 2004 and 2013.
7.76
The site is mainly agricultural land with grassland habitats divided by hedgerows, some of
which are considered likely to qualify as important under the Hedgerow Regulations 1997
but with many being species-poor and of poor structure. A network of field ponds of varying
size and type are present throughout the site and there is evidence of the invasive
Himalayan Balsam along the banks of the Hatherley and Horsbere Brooks along the north
and south-west edges of the site respectively.
7.77
The site includes the Innsworth Meadows Site of Special Scientific Interest (SSSI), which is
one of the few remaining unimproved lowland neutral meadows in the Vale of Gloucester.
Hydrological monitoring surveys have been conducted in conjunction with discussions with
Natural England to ensure this statutory designation is not adversely affected as part of any
development proposals.
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7.78
A declining population of Great Crested Newts (recorded as ‘small’ in 2006, 2011 and 2013
and ‘medium’ in 2004) was identified utilising a cluster of ponds in the south of the site.
Optimal terrestrial habitat for this population is largely absent within the site in proximity to
the ponds (being predominantly arable and grazed grassland but with hedgerows and some
areas of longer grassland). Discussions have been carried out with Natural England as to
provision of an appropriate receptor area together with necessary precautions and
mitigation/enhancement as an intrinsic part of the proposed development where necessary.
7.79
A series of bat activity surveys have been undertaken in 2004, 2006, 2011 and 2013 as
habitats (hedgerows, trees and brook corridors) present foraging and commuting
opportunities for this faunal group. The buildings at Drymeadow Farm have been surveyed
for bats and no evidence of any roosts was recorded. Trees exhibiting potential to support
roosting bats have been identified in the site and are primarily Willows located along the
two Brooks.
7.80
There are a couple of fields within the site that present apparent opportunities for common
reptiles. Surveys in 2004 did not identify this group as present but a very small number of
reptiles (individual Grass Snake and Common Lizard) have been identified during surveys
in 2013 around the derelict barracks buildings south of Drymeadow Farm.
7.81
No evidence of Water Vole or Otter was noted along the Hatherley Brook during the 2013
surveys. Past evidence of Water Voles, in the form of burrows, has been found along
Horsbere Brook, although in 2004 the only signs of any recent activity were some minimal
feeding signs recorded where Horsbere Brook meets the A40 main road. No activity was
recorded along Horsbere Brook in 2006 or 2013.
7.82
Badger surveys have identified two main setts and a number of other lower status setts
within the site and activity has been monitored periodically between 2004 and 2013. Baitmarking studies in 2004 provided a good indication of the territories of the social groups
using the main setts within the site.
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7.83
Opportunities for ecological enhancements within the development will be identified and
these will be used to promote a net gain in biodiversity across the development. In
particular these will aim to incorporate the goals of the local Biodiversity Action Plan.
Noise and Vibration
7.84
An assessment of the existing noise levels across the site has been undertaken through
unattended noise monitoring supplemented by attended sample noise measurements.
7.85
The exercise indicated noise levels within the site are influenced by a mix of sources.
Aircraft movements flying out of Gloucester Airport were observed frequently throughout the
day, influencing noise levels across the site. Road traffic travelling along the local roads
influenced noise levels along the southern and eastern boundaries, with the operation of
the Innsworth Technology Park having the potential to influence noise levels within the
south western area of the site.
7.86
In order to inform a planning application, noise levels within the proposed development
areas will be assessed against the guidance contained within the NPPF, BS 8233 and BS
4142 where appropriate, to demonstrate that a satisfactory noise environment can be
achieved within proposed residential areas.
7.87
Consideration would be given to providing appropriate mitigation or buffer zones within a
masterplan to ensure that noise from the industrial areas and roads were reduced to a
satisfactory standard.
7.88
With appropriate mitigation and design measures incorporated into a masterplan, it is
anticipated that an acceptable noise environment for future residents across the site would
be successfully achieved.
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Hydrology, Drainage & Flood Risk
Assessment of Flood Risk:
7.89
A preliminary assessment of flood risk has been undertaken for the development of the land
at Innsworth.
Level 2 Strategic Flood Risk Assessment (L2SFRA):
7.90
The land at Innsworth is considered in the Level 2 Strategic Flood Risk Assessment (SFRA)
as part of its evidence base for the Gloucester, Cheltenham & Tewkesbury Joint Core
Strategy. The land forms part of the L2SFRA ‘Site T9’ together with land at Twigworth and
consented land at Longford.
L2SFRA Exception Test:
7.91
The L2SFRA Exception Test concludes that “Given the size of the Site T9 it is shown that
the required housing (3,995 dwellings) can be delivered within the available area of the site
within Flood Zone 1. Development within Flood Zones 2, 3a and 3b should therefore be
avoided. Provided development is located within Flood Zone 1, the ET should not apply.”
L2SFRA Comments & Recommendations:
7.92
The L2SFRA shows that parts of Site T9 are affected by Flood Zones 2, 3a and 3b with
historic flood outlines showing that areas of the site have been affected by fluvial flooding.
In addition, there is a risk of flooding from surface water and a residual risk from culvert
blockage.
7.93
The L2SFRA strongly recommends that any development within Site T9 is located fully in
Flood Zone 1 and the higher flood risk areas are kept as open space.
7.94
The L2 SFRA recommends that for all development, it must be ensured that the
vulnerability of flooding from other sources is considered as well as the effect of the new
development on surface water runoff. A FRA will be required to demonstrate runoff from the
proposed development is reduced through the use of SUDs techniques. Where important
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surface water flow paths are identified, it is recommended that these flow paths are taken
into consideration in the design layout of the development sites and are maintained to
prevent an increase in flood risk at downstream locations.
7.95
In general, existing access routes to Site T9 are unaffected by flood risk. Modelling has
shown a small part of Frog Furlong Road is at risk from fluvial flooding immediately
adjacent to the Hatherley Brook for the range of modelled events. Here the flood hazard is
significant. To the south of the risk area, the remainder of the Road is not affected and safe
access can be maintained for the Innsworth part of the site for the range of modelled
events.
7.96
Where a residual risk from a culvert blockage is identified, it is recommended these areas
are kept as open space and development is located towards lower risk areas. A culvert
maintenance schedule should be developed to periodically clear culverts of debris, which
will reduce the risk of blockage during a flood event.
7.97
Areas susceptible to surface water flood risk have been identified. It is recommended that
areas of high and moderate hazard are kept as open space and appropriate management
of surface water is employed, keeping flow risk paths clear, particularly where access
routes are affected.
Flood Modelling & Flood Zones:
7.98
Site specific flood modelling for Site T9 has been carried out (Capita model for the
Horsbere and Hatherley Brooks), and details of the extents of the flood zones for the land at
Innsworth have been agreed with the Environment Agency (EA). The EA has confirmed that
the agreed 1 in 100 year flood extent (including an allowance for climate change) should be
used when bringing forward potential development in the Innsworth area.
NPPF Sequential Test:
7.99
In accordance with the National Planning Policy Framework (NPPF) Sequential Test
approach to development and flood risk, and in accordance with the recommendations of
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the L2SFRA, development will be located in Flood Zone 1 which has the lowest risk (less
than 0.1% or 1:1,000 annual probability).
Site Specific Flood Risk Assessment (FRA):
7.100 In accordance with the requirements of the NPPF and the L2SFRA recommendations a Site
Specific FRA will be produced to demonstrate that the site can be safely developed without
flood risk, from any source, and without increasing flood risk elsewhere.
Sustainable Drainage System (SuDS):
7.101 Surface Water will be managed through the use of an appropriate sustainable drainage
system incorporating the surface water management train principles and including green
infrastructure such as basins, ponds and swales. The FRA will include details of a surface
water drainage strategy incorporating SuDS.
Water Quality:
7.102 The FRA will consider water quality and demonstrate that the development of the site will
not adversely affect the water environment and will identify ways in which the development
can contribute towards the enhancement of it, helping to improve the ecological status of
downstream watercourses.
Innsworth SSSI:
7.103 SUDs will be used to ensure that the sensitive water environment within the SSSI is not
adversely effected by the development. A system of monitoring will be implemented to
ensure that the SuDS is effective.
Development Levels:
7.104 To ensure that the proposed dwellings are not at risk from flooding floor levels will be a
minimum of 600mm above the 100 year flood level, including allowance for climate change.
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Flood Routes:
7.105 The FRA will identify existing and proposed flood routes and ensure that existing paths are
maintained or enhanced and that new routes are provided to direct any surface water flows
safely through the development without causing flood risk to existing or new properties.
Safe Access:
7.106 Safe dry access is available from Innsworth Lane and Frog Furlong Lane. The proposed
link to the A40 will be raised above the 100 year flood level (including allowance for climate
change), it does however cross flood zones 2 and 3 and will therefore be subject to the
NPPF Exception test. In accordance with the requirements of the Exception test the FRA
will demonstrate that the road link will not impede flows or increase flood risk elsewhere
through the provision of flood compensation areas and flood culverts under the road.
Foul Sewerage Infrastructure:
7.107 Severn Trent Water has confirmed that there will be capacity within their foul sewerage
infrastructure to accommodate flows from the proposed development without any increase
in the risk of flooding.
Conclusion:
7.108 The assessment concludes that there is no significant flooding or drainage issues that
would prevent the development of the site. Therefore in terms of flooding or drainage the
land at Innsworth is considered to be a sustainable location for development.
Ground Conditions
7.109 A Phase 1 Desk Study of land situated between the A40, Innsworth Lane, Frog Furlong
Lane and the Hatherley Brook, some 3km north of Gloucester City Centre has been
undertaken in order to identify and evaluate the former/current site usage, environmental
setting and its likely contamination status. This included a review of existing ground
investigation reports prepared by others, and enabled formulation of a preliminary risk
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assessment to determine any plausible pollutant linkages with regard to potential impacts to
human health and/or controlled waters, the results of which were used to define the scope
of Phase 2 intrusive works.
7.110 A review of historical Ordnance Survey mapping indicates that the site has been mainly
agricultural since the earliest available mapping of 1887. Circa 1980’s a large “borrow pit”
was excavated in the southwest of the site to provide clay materials to facilitate the
construction of the A40, and since 1987 this void has been in use as an inert waste landfill
facility (Drymeadow Landfill), although since c2003 it has reportedly continued mostly as an
inert waste recycling and transfer station. The area surrounding the site is predominantly
residential to the south/southeast and commercial to the east. A former water reclamation
(sewage) works was located beyond the site boundary to the southwest, whilst a smaller
sewage works is located in the northeast corner of the site (does not actually constitute part
of
the
proposed development
layout; the
works was reportedly proposed for
decommissioning although it is unclear if this is yet complete).
7.111 Whilst Drymeadow Landfill occupies land in the southwest of the site, there is no proposal
`for “built development” within the landfill area, although plans do include the establishment
of a primary infrastructure road (specific route to be confirmed), likely crossing the
southeast corner of the licensed area though falling outside the area of actual historic
tipping. In addition to the landfill, other notable potential contaminative land-uses in / within
influencing distances of the site include:

Former Water Reclamation Works (sewage works) beyond the southwest site
boundary

The small sewage works in the northeast of the site (although not actually forming
part of the proposed development area)

Innsworth Technology Park to the immediate south/east comprising a variety of small
businesses of potentially contaminative use including car repair garages

RAF Innsworth located beyond the eastern site boundary
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7.112 Phase 2 intrusive investigations including a detailed contamination risk assessment did not
identify any significant potential “abnormals” to site development. The majority of the site is
of “greenfield” status and effectively uncontaminated from a human health perspective,
although
localised
areas/sources
have
been
identified
as
requiring
further
consideration/investigation prior to site development. Leachate analysis indicates that the
site does not pose a risk to controlled waters, although analysis of groundwater suggests
that localised contamination may already be present, leading to the possibility that it could
be associated with either an off-site source of elevated background concentrations in the
area of the site. Landfill gas monitoring across land to the southeast of Drymeadow Landfill
and the wider site area recorded nil methane and low level carbon dioxide, although it was
noted that precautionary measures may need to be considered unless further monitoring
continues to demonstrate no risk.
7.113 On the basis of the foregoing and investigative findings to date, supplementary investigation
has been proposed within the following areas:

Southwest corner of the site immediately adjacent former sewage works

Land immediately adjacent Drymeadow Landfill

Land adjacent small sewage works in the northeast of the site

Land adjacent Innsworth Technology Park in the south/southwest of the site
7.114 It is intended that investigative work will comprise targeted borehole drilling at all
aforementioned positions with sampling of made ground, natural ground and groundwater
at all positions as considered appropriate. Results will be used to expand the existing dataset which will be incorporated into an appropriate risk assessment to determine risk levels
to the receptors, such that any necessary remedial measures can be identified and
recommended to ensure that the proposed development site is “fit for use”.
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Cultural Heritage and Archaeology
7.115 An initial archaeological desk based assessment of a wider area incorporating the site has
been undertaken. This assessment has established that there are no archaeological
heritage assets of the highest significance (designated or nationally important) identified
within the site or its immediate proximity.
7.116 A number of built heritage assets, comprising five grade II listed buildings, are identified to
lie within a 500m radius of the site. These assets have been considered as part of a
subsequent heritage statement produced for the site. This study concludes that proposed
development within the site would result in no harm to these designated assets or their
setting.
7.117 Non-designated heritage assets were identified by the desk based study to be present
within the site itself, represented by undated cropmark features, with a moderate potential
identified for remains dating to the Medieval period, relating to a possible moated site, and
the Modern period, relating to former World War II structures. Beyond these assets, a low
potential was recognised for the presence of any further important previously unrecorded
buried heritage assets of archaeological interest dating to all periods
7.118 A number of historic hedgerow boundaries are identified to be present within the site which
may be considered important under the 1997 Hedgerow Regulations.
7.119 On the basis of the known non-designated archaeological assets identified on the site and
the potential recognised by the desk based study, a programme of further field studies,
initially comprising detailed geophysical survey followed by trial trenching, was agreed with
the local planning authority’s archaeological advisor at Gloucestershire County Council.
7.120 Detailed geophysical survey within the site was implemented in two phases. The Phase 1
survey recorded three notable foci of features relating to past settlement, representing
multi-phase occupation and land-use. These comprised ring ditches, curvilinear and
rectilinear enclosures and trackways detected within the south-eastern extents of the site; a
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eastern central area of the site, and a double ditched enclosure with possible associated
features detected within the north-eastern central area of the site. Elsewhere, traces of
former ridge and furrow cultivation were recorded across the site area indicating agricultural
exploitation in the Medieval period.
7.121 The Phase II survey incorporated an area within the northern limits of the site up to its
bounds with the Hatherley Brook. The survey recorded further anomalies of potential
archaeological interest comprising the remains of possible palaeo-channels associated with
the course of the brook, two possible ditches, one of which may represent a ring ditch
enclosure, and alterations in magnetic responses suggesting either changes in cultivation
practices or alluviation.
7.122 On the basis of the results produced by the geophysical survey, further trial trenching was
implemented both to target the anomalies identified and to provide for an appropriate
spatial sample of the site area, although not all areas of the site could be accessed due to a
lack of access permission, the presence of active landfill operations and existing ecological
constraints. The results produced by the evaluation broadly corresponded with the pattern
of settlement/occupation foci identified as being present on the site by the previous Phase I
geophysical survey. A double ditched enclosure of Late Iron Age/early Roman date was
recorded within the north-eastern central area of the site, a series of ditched enclosures and
trackway of late Iron Age/early Roman date, with occupation activity suggested to continue
into the mid to late Roman period, within the south-eastern area of the site, and a series of
intercutting ditches and pits and postholes indicative of settlement activity dating to the late
Iron Age and extending into the Roman period within the south-eastern extents of the site.
The overall character of the activity recorded on the site suggests agrarian settlement and
utilisation of the landscape in the late Iron Age and Roman periods. Evidence of later
activity was limited to the use of the site as agricultural land in the Medieval period.
7.123 The recorded buried archaeological remains of interest identified on the site are not
considered to be of sufficient importance to merit in situ preservation, or to preclude
development. However, suitable measures to secure their further investigation and record
would be required, such an approach having been previously identified as appropriate in
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the Planning Inspectors Appeal Report (November 2009) relating to an earlier planning
application for development on the site (App. Ref. 07/00680/OUT).
Agricultural Circumstances
7.124 An assessment of the agricultural circumstances arising at Innsworth and it has been
determined that the majority of the site is lower quality agricultural land in Subgrade 3b,
Grade 4 and Grade 5, with the remainder split between Subgrade 3a and Grade 2.
Land by agricultural land classification grade
Grade
Description
Area (ha)
Area (% of
agric. land)
2
Very good quality
14.2
13
3a
Good quality
29.3
26
3b
Moderate quality
64.0
58
4
Poor quality
2.1
2
5
Very poor quality
1.6
1
Total
111.2
Agricultural
7.125 The majority of the agricultural land is understood to be owner-occupied and farmed in
conjunction with other owned land to the east of Cheltenham. Between these two units a
herd of 140 dairy cows is kept along with approximately 70 dairy herd replacements and 60
beef cattle. Some 80ha of cereal crops are grown (mainly at Hawling) and 40ha of forage
maize (within the study area) which is used for winter feed for the dairy cows which are kept
at Longford.
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7.126 The balance of the land, with the exception of approximately 6.5ha in the far south-east, is
owned and managed by Robert Hitchins Ltd and farmed by them as part of the Boddington
Estate. The Estate farms some 490ha in the locality and is mainly concerned with arable
crop production, though it also rears pedigree Simmental cattle.
7.127 The small parcel in the south-east has been in the present ownership since 1976 and the
land is split into two parcels with that adjacent to the farmhouse being used for horse and
donkey grazing; the remainder is rented to dairy farm (referred to above) for forage maize
production.
Summary
1.128 A number of environmental studies have been undertaken to date to establish the
parameters relating to the environment which are present at the site, namely landscape,
visual amenity, ecology, archaeology and cultural heritage, agricultural circumstances, flood
risk, drainage, noise and ground conditions. It is recognised that all of these environmental
aspects require careful attention in developing a design for development at the site.
7.129 The baseline evidence obtained for the site to date demonstrates that land south of the
Hatherely Brook (Innsworth) can successfully be allocated as part of a strategic location for
growth.
7.130 In addition the following work is being undertaken to further inform the development
proposals including: a socio-economic assessment, transport assessment, air quality
assessment, sustainability assessment, waste minimisation report, affordable housing
provision, and utilities statement.
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Appendix 2
Position Statement: Strategic Allocation Ashchurch
1
Introduction
1.1
This statement sets out further information in support of the proposed strategic allocation at
Ashchurch which is the subject of a current planning application for a proposed retail outlet
centre and garden centre (LPA reference: 13/1003/OUT).
1.2
The objective is to provide a sustainable employment generating development that will
provide for future economic growth within an attractive setting.
2
Baseline Survey Work
2.1
Work undertaken in connection with the application (and attention is drawn to the
supporting documents submitted with the application including the environmental
statement) demonstrates the suitability of the site to be allocated for employment
generating uses and indeed for the development proposed. Summary information is set out
in section 4 below.
3
Master Plan
3.1
The plan below has been informed by the baseline work undertaken and shows the outline
proposals for the development of the Strategic Allocation. In summary the design concept
is to provide for an attractive frontage alongside the A46, complementing development to
the north and providing for a modern retail environment within a ‘parkland’ setting to the
south.
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Not to Scale
4.0
Summary of Baseline Survey Work
4.1
The following section summarises the baseline and other work undertaken in connection
with the proposed development of this site.
Further information can be found in the
supporting documentation submitted with the recent planning application.
Flood Risk
4.2
The site specific FRA examines the evidence provided by the various sources of fluvial
flood mapping, including the level 2 SFRA site T3 assessment and the site specific flood
modelling carried out by the applicant. It identifies that the site is in predominantly flood
zone 1 (< 0.1 % Annual Exceedance Probability (AEP) of flooding, 1:1,000) and that the
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southern area adjacent to the Tirle Brook is flood zone 2 (0.1% to 1% AEP, 1:1,000 to
1:100) and flood zone 3 (< 1% aep, 1:100). The flood zones are shown in the figure below.
4.3
Other potential sources of flooding that have been identified in the site Specific FRA are:
surface water (pluvial), sewers and groundwater.
Geology
4.4
Geological Survey of Great Britain mapping indicates the site to be underlain in its entirety
by solid strata of the Charmouth Mudstone Formation (CMF) usually comprising firm to stiff
grey brown plastic clay, which grades at depth into dark blue grey friable shaly mudstones.
Mapping also shows a broad band of overlying superficial alluvial deposits along the south
of the site adjacent to the Tirle Brook; plus sands and gravels to the north of the site, the
southern extent of which is coincident with the A46 (northern site boundary); these deposits
may slightly encroach onto the northern extremities of the site. Mapping indicates no
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apparent geological faulting within influencing distance of the site; there is also no made
ground on/within the site.
4.5
Intrusive investigations were carried out by Wilson Associates in January 2013 using a
combination of borehole (BH) drilling and trial pit (TP) excavations. Four windowless sample
BHʼs (WS1 – WS4) were drilled to depths of up to 4.45m. The BHʼs were supplemented
with seven TPʼs and a further three shallow pits (SA1 – SA3) within which falling head tests
were carried out at depths of up to 1m in order to determine the infiltration characteristics of
the ground. Infiltration calculations were carried out in general accordance with BRE365
guidance. Full details are included in chapter 7 of the ES.
4.6
The boreholes and trial pits have shown natural ground conditions to be broadly
commensurate
with
geological
mapping,
with
all
investigation
positions
proving
clay/mudstone representing the upper weathered mantle of the CMF, overlain by topsoil
and subsoil deposits and locally by a superficial covering of River Terrace Deposits. Ground
conditions are summarised as:
TOPSOIL: 0-0.4m depth: generally encountered as mid to light brown and locally greyishbrown, silty clay topsoil with grass rootlets and occasional gravel.
SUBSOIL: 0.4-0.85m depth: generally firm greyish-brown, locally mottled orange-brown silty
clay subsoil with grass rootlets and occasional gravel.
CLAY and SAND and GRAVEL: to 2.45m depth: horizons of clay containing occasional
limestone gravel, and very sandy limestone gravel (River Terrace Deposits).
CLAY / MUDSTONE: >1 to >4.45m depth: generally recovered as firm becoming stiff bluegrey clay with occasional limestone gravel, sandy nodules and gypsum crystals; grading to
extremely weak to very weak, dark blue-grey, fissured, thinly laminated mudstone (C MF).
Hydrogeology
4.7
The EA website groundwater mapping classifies the CMF as a ʻSecondary Undifferentiated’
aquifer, which means the EA has not been able to characterise the material due to the
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variable characteristics of the rock type. Experience of the CMF is that it mostly classifies as
a non-aquifer. The overlying superficial alluvial deposits are classified as a Secondary ʻAʼ
(minor) aquifer, which comprises predominantly lower permeability layers which may store
and yield limited amounts of groundwater due to localised features such as fissures, thin
permeable horizons and weathering.
4.8
The EA mapping shows that the site is not located in a groundwater Source Protection
Zone (SPZ).
4.9
The recorded geology indicates that nearby private water abstractions are unlikely;
Envirocheck data records in the Ground Investigation report show that there are no water
abstractions within a 1km radius.
4.10 The closest active discharge consent relates to trade discharge of process water at Dowty
Seals Ltd some 34m to the north into the Northway Brook.
4.11 To help identify the suitability of the soils for infiltration three hand-dug pits were excavated
to a consistent depth of 1m. Falling head tests proved either very poor or negligible soil
infiltration within the CMF (water levels fell less than 100mm in over one hour). The test
methodology and limited test duration do not strictly comply with minimum BRE 365
requirements, the results suggest that water would not drain to 50% storage capacity within
24hrs, thus the natural deposits are considered to be generally impermeable and unsuitable
for soakaway drainage. Test results are included in Wilson Associates Report dated March
2013.
4.12 Upon completion of drilling, WS1 – WS3 were installed with water monitoring wells, with
response zones between 1.0m and 4.0m depth. There was a very slight seepage at base of
hand-dug starter pit (1.2m) in WS1; all boreholes and trial pits are identified as dry upon
completion of drilling/excavation.
4.13 Only one minor groundwater seepage within the clay was recorded in WS1 at 1.2m depth
during the drilling process, although monitoring wells installed in WS1 – WS3 subsequently
recorded levels as presented in Figure 1.3 below.
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4.14 The initial monitoring results show groundwater levels slowly increasing over time, most
likely attributable to prolonged wet weather in February and March 2013 leading to
groundwater infiltration by way of minor seepages via fissures in the clay.
4.15 Based upon the above information the site is considered to be within an area of generally
low sensitivity with regards to groundwater resources.
Hydrology
4.16 The Tirle Brook (Main River) forms the southern boundary of the site. It enters the site in the
east under a bridge where Fiddington Lane crosses over the Brook and exits the site in the
west through a culvert under the M5. A second watercourse, the Northway Brook (Ordinary
Watercourse) divides the site; it is culverted through the Ashchurch Industrial Estate to the
north of the A46 and enters the site from a 900mm diameter pipe to the east of the BP
Services.
4.17 The Tirle Brook is approximately 1,200m in length (within the site) and has a meandering
channel approximately 1-2m in width and 2m in depth with steep banks. The upstream bed
level is approximately 12.9m and the downstream bed level approximately 10.3m giving an
average gradient of approximately 1:460. The Fiddington Lane Bridge at the upstream end
has a span of approximately 10m and a soffit of approximately 14.6m. The culvert under the
M5 at the downstream end is approximately 4.5m wide and 4m high with a raised concrete
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walkway along the southern side. There is a small concrete field access bridge
approximately one third of the way along the Brook; the clearance under the bridge is
approximately 2m. The catchment area for the Brook at the downstream end is
approximately 25.2 km2 (taken from FEH CD-ROM 3). The catchment is predominantly
rural with an urban extent of approximately 5%.
4.18 The Northway Brook is approximately 425m in length (within the site) and has a less
meandering channel generally less than 1m in width and 1-1.5m in depth with steep banks.
The upstream bed level adjacent to the A46 is approximately 14.4m and the downstream
bed level where it meets the Tirle Brook is approximately 11.3m giving an average gradient
of approximately 1:140. To provide farming access the Brook is culverted at two locations,
with a 450mm diameter pipe and 600mm diameter pipe. The catchment area for the Brook
at the downstream end is approximately 0.6 km2 (taken from FEH CD-ROM 3). The
catchment is more urban with an urban extent of approximately 35% providing drainage for
a large part of the Ashchurch Industrial Estate.
4.19 There are two significant surface water sewers within the site. There is a 450mm diameter
sewer that runs along the northern boundary of the site from Northway Lane discharging to
the Northway Brook, and a 600mm diameter sewer crossing the west part of the site from
the Ashchurch Industrial Estate to the North. The 600mm diameter sewer forms the outfall
to a pond located to the north of the A46 adjacent to the MOOG building. The 600mm
diameter sewer crosses the west part of the site and discharges to the Tirle Brook. The
FRA identifies flooding from the sewers to be a potential flood risk to the development.
4.20 In addition to the watercourses and sewers there are a number of drainage ditches around
the perimeter of the site. These are minor in nature and are localised land drainage ditches
to drain surface water from the adjacent areas.
Green-field Run-off (Pluvial Flows)
4.21 Green-field run-off resulting from rainfall on the site discharges overland to the Northway
Brook and Tirle Brook. Due to the impermeable nature of the underlying soils run-off is
relatively high. The SPR (Standard Percentage Run-off) for the impermeable clay soils
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encountered on the site is 45% (i.e. 45% of rainfall results in run-off; the remaining 55%
infiltrates, lies on the surface, evaporates, or is taken up by crops and vegetation.
4.22 Peak green-field run-off rates for the site have been calculated using Micro drainage and
are summarised below (taken from FRA):
Qbar (Mean Annual Flood Flow, 2.3 Year)
4.0 l/s/ha
Q1 (1 Year)
3.3 l/s/ha
Q30 (30 Year)
7.8 l/s/ha
Q100 (100 Year)
10.2 l/s/ha
For the 19.3 ha site (excluding existing highways) the peak green-field run-off rates are:
Qbar (Mean Annual Flood Flow, 2.3 Year)
77.2 l/s
Q1 (1 Year)
63.6 l/s
Q30 (30 Year)
150.5 l/s
Q100 (100 Year)
196.8 l/s
4.23 The southern part of the site adjacent to the Tirle Brook (floodplain) will not be developed
and will be retained as open space, approximately 5.3ha. The area of the site proposed for
development is 14ha; the existing green-field rates for the 14ha are:
Qbar (Mean Annual Flood Flow, 2.3 Year)
56.0 l/s
Q1 (1 Year)
46.2 l/s
Q30 (30 Year)
109.2 l/s
Q100 (100 Year)
142.8 l/s
4.24 To compare run-off from existing green-field sites and developed sites guidance
recommends that the 100 year 6 hour rainfall event is used.
Existing 100 Year 6 Hour Run-off Volume (from FRA) = 3,675 m3
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Water Quality
4.25
The WFD focuses on the protection, improvement and sustainable use of the water
environment. Its priorities include:

To prevent deterioration in the status of aquatic ecosystems, protect them and improve the
ecological condition of waters.

To achieve at least good status for all waters by 2015. Where this is not possible, and
subject to the criteria set out in the Directive, aim to achieve good status by 2021 or 2027.

To conserve habitats and species that depends directly on water.

To reduce or phase out the release of individual pollutants, or groups of pollutants, that
presents a significant threat to the aquatic environment.

To reduce the pollution of groundwater and prevent or limit the entry of pollutants.

To help reduce the effects of floods and droughts.
4.26
The WFD and RBMP - Severn River Basin District identifies the Tirle Brook (Water Body
109054039810 – source to confluence with River Swilgate) as currently being of Poor
Ecological and Poor Biological quality. The WFD and RBMP objective is to achieve Good
Ecological and Biological status for the Tirle Brook by 2027. Development should not serve
to hinder this objective and should explore betterment wherever possible.
4.27
The catchment of the Tirle Brook is approximately 25.2 km2 (taken from FEH CD-ROM 3); it
is predominantly rural with an urban extent of approximately 5% (126 ha). The catchment
area for the Northway Brook (tributary of the Tirle Brook) at the confluence with the Tirle
Brook is approximately 0.6 km2 (taken from FEH CD-ROM 3). The catchment for the
Northway Brook is more urban with an urban extent of approximately 35% (21 ha) providing
drainage for a large part of the Ashchurch Industrial Estate.
4.28
The Enviocheck Report for the site does not identify any significant risks to water quality
from the site or surrounding areas.
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4.29
The ground investigation carried out by Wilson Associates included contamination testing
for soils and water and also leachate analysis to identify potential risk to groundwater
resources. The testing included three water samples from the Tirle Brook. The report
concludes that the site is effectively uncontaminated and there is no significant risk to
controlled waters.
4.30
Because of the current RBMP poor status for the Tirle Brook, and the WFD objective of
achieving good status by 2027, the site is considered to be within an area of moderate
sensitivity in terms of controlled surface waters. Any benefits that the Proposed
Development can provide to help improve the ecological and biological quality of the
downstream watercourses would therefore be a significant benefit.
Landscape
Landscape Character (National Level)
4.31 The site is located within the Severn and Avon Vales area (106), as shown on the Natural
England National Character Area Map. The key characteristics of this character area are as
follows:
- Diverse range of flat and gently undulating landscapes, united by broad river valley
character.
- Riverside landscapes with little woodland, often very open.
- Variety of land uses from small pasture fields and commons in the west to intensive
agriculture in the east.
- Distinct and contrasting vales: Evesham, Berkeley, Gloucester, Leadon, Avon.
- Many ancient market towns and large villages along the rivers
- Nucleated villages with timber frame and brick buildings.
(Source: National Character Area Profile, Natural England)
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Landscape Character (District Level)
4.32 At district level the site is located within the County Landscape Character Type: Settled
Unwooded Vale area 18 (SV6B Vale of Gloucester), and the County Landscape Character
Area: Tewkesbury Urban. The key characteristics of this character area are as follows:
- Prominent views of hills – such as the Cotswolds, Bredon and the Malverns – at the edges
of the character area.
- Soft rolling or gently undulating landform, with the Cotswolds Escarpment defining the
eastern limit of the Vale and providing a dramatic backdrop to vale settlements and
landscapes.
- Mixed arable and pasture land use with occasional orchards.
- Well maintained hedgerows forming a strong landscape pattern.
- Limited woodland and ancient woodland cover indicative of widespread clearance for
agriculture
- Major transport corridors through vale with effects of noise, traffic movement, and light
pollution at night
- Rural areas bordered by large urban and suburban areas and interspersed with
commercial and industrial uses
- Varied and complicated mix of building materials, with use of brick, timber and stone, and
stone, Welsh slate, tile and thatch roofing, with Oolitic Limestone still prevalent within the
vale villages in closer proximity to the Cotswolds escarpment.
(Source: Gloucestershire District Landscape Character Assessment, LDA 2002)
Landscape Character (Local Level)
4.33
The local landscape character is created by the abrupt convergence of three distinct
landscape types which bring strong contrasts in scale, texture and openness. The open and
exposed rural vale landscape abruptly joins the large scale structures of the Ashchurch
commercial area and active highway and motorway junction adjoining. The motorway
corridor dissects the rural landscape into segments that fall between major routes of
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communication including the railway and the trunk road. This convergence of contrasting
landscape types is exaggerated by the raised location of the areas of built form which are
seen to contain the agricultural vale landscape in the same way that the high ground of the
Cotswold Hills and Malvern Hills are seen to contain the broader vale landscape.
4.34
The landscape character is strongly influenced by urban and rural elements both of large
and small scale. The open agricultural landscape abruptly adjoins the large scale
contemporary commercial buildings which forms the prominent southern urban edge at
Ashchurch. The A46 highway is an active element in the landscape which is broad and
urban as it extends east to west at Ashchurch. Fiddington Lane in contrast remains rural
and small in scale, providing direct local access from the urban area to the more isolated
settlement. Lanes and highways are generally contained by hedges in contrast to the open
farmland beyond. An exception is the M5 corridor which cuts through the rural landscape
south of junction 9 where it creates a significant barrier between the open farmland
adjoining. The built form is seen to extend along the entire A46 trunk road corridor both east
and west of the motorway junction. This alignment reflects the underlying ridged topography
which extends from the eastern fringe of Tewkesbury to the west of Junction 9.
4.35
Despite the physical containment of the rural field pattern by communication corridors and
built form, the agricultural landscape retains a sense of openness and isolation. Noise from
commercial centres and traffic along with the visible movements of vehicles make this an
active landscape with low sense of tranquillity or time depth.
4.36
A characteristic of the landscape character type SV6 Vale of Gloucester is confirmed as:
‘In the wider vale landscape, low hedgerows with scattered trees form the common
boundary treatment. While these hedgerows are generally well maintained, some are
becoming either gappy or overgrown, and in other areas the hedgerow network is
beginning to break down, with evidence of field amalgamation and hedgerow trees and
scrubby vegetation marking the lines of former field boundaries’.
This characteristic is seen within and adjoining the site.
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4.37
Settlement pattern is broadly linear being influenced by the A46 and adjoining minor lanes.
The main settlement area of Ashchurch has developed away from the highway but retains a
generally linear pattern.
4.38
Enclosure: The field pattern and pattern of settlement is locally distinctive although it does
not create a strong sense of enclosure within the landscape. The local field pattern and
condition broadly reflects the adopted district landscape character type.
4.39
Time depth: The simple but active agricultural landscape with low hedges and few mature
trees does not create a strong sense of time depth. Modern structures both of isolated
settlement and communications routes further distance the sense of long establishment and
time depth.
4.40
Scale: The scale of the existing commercial development, highways infrastructure and
agricultural landscape is large. This contrasts with small scale settlement within the
adjoining countryside.
4.41
Movement and noise: The background sounds of highway, railway and commercial activity
are significant and ever present. Vehicle movements are identifiable over some distance
both on the M5 motorway and A46 highway. These movements are particularly notable
during hours of darkness of low light.
4.42
Pattern, texture and diversity: The landscape is diverse with its contrast between the varied
forms of the built environment and the simple untextured adjoining agricultural landscape.
Landscape Value
4.43
The site landscape is of local value when considered in a regional context. This is in terms
of being absent from any landscape designations or containing elements of great quality or
rarity.
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Site description
4.44
The site consists of two agricultural fields in active arable production. The fields slope
gently from the northern boundary with the A46 highway to the meandering southern
boundary formed by the Tirle Brook. The land is open and without existing structures within
the site.
4.45
Site vegetation is limited to a number of trees located along Tirle Brook and low hedges to
the eastern and northern boundaries. More substantial hedge and mixed native planting is
located along the western site boundary with the motorway junction and its south bound slip
road although stands of taller hedge are present along the northern boundary also.
4.46
The soils are representative of the local area being heavy over vale clays. Drainage varies
according to gradient of the land but lower lying areas of the site are damp and poor
draining. Ditches are frequent throughout particularly in association with hedges.
Key site features identified are as follows:
Arable agricultural land
4.47
The two fields which comprise the site were both in arable production during 2012. Fields to
the south of the site were also in arable crop production. The site fields are open in
character and partly defined by low hedges. These hedges are gappy and missing in some
areas within the site. There are no hedges along the boundary with Tirle Brook. The
landform falls from a local ridge approximately located along the line of the A46, to Tirle
Brook creating a sense of low lying land along the southern margin of the site. Beyond the
watercourse the land rises gently returning to generally level ground. At the time of the
survey the fields appeared wet and were holding surface water in dips and depressions.
The arable fields are considered to be in a moderate condition and to be low sensitivity to
change.
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Tirle Brook and other riparian features
4.48
Tirle Brook is a simple watercourse with strong meandering pattern which flows east to
west along the southern boundary of the present arable land which forms the site. It should
be noted that the brook and its margins falls outside of the site red line boundary but is so
visually associated with the site that it is included as a site feature in this instance. The
watercourse is predominately narrow and without substantial riparian vegetation due to the
active agricultural land use which extends up to the top of the watercourse channel. A
number of well-established willow trees are present along the edge of the water channel.
The watercourse is generally shallow and set within a well-defined channel. At the time of
the survey the channel was fast flowing and showed signs of recent level fluctuation. The
watercourse (Tirle Brook) is considered to be in a moderate condition but associated
riparian vegetation is limited and poor condition. The watercourse is considered to be
medium sensitivity with significant potential for enhancement.
A46 highway corridor
4.49
The highway and its infrastructure is a distinctive feature that dissects the site from the
commercial centre at Ashchurch. Lighting columns, signage and other functional highway
structures are dominant features at the approach to the M5 junction 9 interchange. This is
an active and audible feature which has considerable influence on its surrounding areas
including the site. The highway is aligned with a naturally occurring local ridge which has
encouraged a pattern of linear settlement along the road and which creates a visually
prominent urban edge at present when seen south of the A46. The highway corridor is
considered to be low sensitivity to change.
M5 motorway corridor vegetation
4.50
The main M5 motorway carriageway is set below the levels of the site but the vegetation
adjoining the southbound slip road lies immediately along the western boundary. The
vegetation is established but indistinctive although it does limit views of vehicle movements
on the slip road and on the roundabout when seen from the east. For this reason the
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motorway vegetation is considered to be moderate condition with medium to high
sensitivity to change.
Site vegetation: hedges, hedgerows and field trees
4.51
Site vegetation is limited with low agricultural hedges and occasional hedgerow tree or
mature trees in close proximity to an existing field boundary. Hedges have been well
clipped to maintain practical agricultural fields, creating on open and exposed landscape.
To the south west of the site a distinct copse (Milne’s Covert) is visible adjoining the
motorway margin. The limited woodland/copse within the landscape as a whole creates a
distinct local feature in the landscape. Taller areas of vegetation are located adjoining the
junction 9 highway infrastructure and these partly extend along the A46 highway boundary
with the site. There are few mature trees within the site or immediately adjoining. Field trees
are considered to be in a moderate to good condition. Field hedges are considered to be
in moderate to poor condition with sections of dense hedge but areas where vegetation is
missing or in significant design. Field hedges contribute to an established field pattern
which is considered to be medium sensitivity. Field hedges, hedgerow and field trees are
considered to be high sensitivity to change.
Site context description
4.52
The site is located immediately south of the Ashchurch Industrial Estate, separated only by
the A46 highway and an associated service station. To the east the site adjoins Fiddington
Lane, a minor lane which provides access to the small rural settlement areas of
Homedowns and Natton. To the east of the lane a narrow band of mixed agricultural land is
located adjoining the mainline railway between Birmingham and Gloucester. Several
isolated residential properties are located to the south east of the site. Newton Farm is
located to the immediate east of the site. Open agricultural land extends south from Tirle
Brook. To the west is located the M5 motorway corridor including the junction 9
interchange. Contextual site features which inform local character include the following:
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Ashchurch Industrial Estate and Northway railway station
4.53
Ashchurch Industrial Estate is located to the immediate north of the site and comprises of a
modern commercial structures of medium to large scale, located within an estate formed
between the M5 corridor and the mainline railway. The industrial estate extends north
beyond the frontage with the A46 highway but the scale of the frontage buildings
predominately obscures the mass of the estate. Structures are of mixed materials with
simple form, accessed by broad formal road network which also provides access to the
Northway railway station. A pedestrian only ramp provides an access from the station to the
A46 to the immediate north east of the site. Where, commercial properties front onto the
main A46 highway, there are a variety of boundary finishes and areas of ornamental
landscaping. Access to these properties is from secondary access roads rather than from
the main highway.
A46 highway and service station
4.54
The A46 highway lies immediately north of the site and comprises of a single broad
carriageway with pedestrian footpath on the northern side of the highway only. Highway
infrastructure including lighting, traffic lights and signage are frequent features. The
highway provides a major access link to junction 9 of the M5 motorway and as such is
subject to large volumes of traffic movements. Pedestrian crossing is difficult and limited to
a narrow island to the immediate west of the railway bridge. Road margins are
predominately rough and untidy with litter frequent throughout the margins of the highway
and on the access roads into the industrial estate.
4.55
An existing service station is located to the south of the A46 and borders the northern edge
of the site. The service station comprises an extensive covered forecourt with shop. A
former café forms a separate single storey building on the site which is presently boarded
and unused.
4.56
It has been noted in this assessment that an application by Sainsbury’s for the development
of a new supermarket and service station is proposed for land immediately north of the A46,
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opposite the site and the potential development has been considered with regards potential
cumulative landscape and visual effects.
M5 motorway
4.57
The M5 motorway lies immediately west of the site, where it forms a strong north south
linear corridor. This corridor separates Ashchurch from the main Tewkesbury urban area.
The raised structure of the junction 9 interchange with the motorway creates a significant
feature to the west of the site. The slip road providing access to the southbound motorway
descends immediately adjoining the western boundary of the site. Vegetation planted as
part of the highway structure has established and formed a screen between the site and the
junction infrastructure. The motorway generates significant traffic noise although vehicle
movements on the main motorway corridor are screened by the southbound slip road.
Mainline railway
4.58
The mainline railway between Birmingham and Bristol is located to the east of the site. The
railway is within a cutting and obscured by local landcover located between the site and the
railway. The railway is aligned north south and runs parallel with the M5 corridor creating a
distinctive communications corridor which dissects the settlement areas. Northway station
is located to the immediate north east of the site with access gained through Ashchurch
Industrial Estate. The A46 highway bridge over the railway is a major engineered structure
which rises above general levels to create a significant ridge which separates the original
Ashchurch settlement area from west of the railway line.
Tewkesbury
4.59
The main urban area of Tewkesbury is located to the west of the motorway corridor. The
main historic centre is a distance of approximately 1.5 kilometres from the site but linear
pattern settlement extends from the historic centre to and beyond the motorway junction.
The settlement area of Newtown is located to the west of junction 9 where it presently forms
the eastern most edge of the Tewkesbury settlement area. This is generally seen to follow a
ridge of higher land which continues east of motorway junction 9 and on which the
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Ashchurch commercial development area is located. Vegetation associated with the
settlement area is identifiable along this ridge and is locally distinctive because of
evergreens and poplar trees.
4.60
Tewkesbury Abbey is a central historic feature of the town the tower of which is frequently
seen from adjoining rural areas. These views of the Abbey are an important element of the
local character, seen above local land cover.
Ashchurch settlement area
4.61
Ashchurch is a rural parish comprising a church, primary school and a number of rural
dwellings. The parish is approximately 1.5 miles from Tewkesbury Borough Council town
centre. The main village area is located to the east of the main line railway which in turn
lies to the east of the site.
4.62
The settlement area of Ashchurch is dominated by the long established MOD Ashchurch
site. In the recent period new housing has been introduced in response to the changes to
the former military depot. The original settlement area is very small but a key feature is the
church (St Nicholas) which is seen with open rural paddock in its foreground adjoining the
highway. Materials and ages of buildings are varied along with scale and land use.
Established vegetation in the vicinity of the church contributes to the setting and time depth
of the old centre of the settlement. The main A46 highway to the south of the church rises
above traditional ground levels as it crosses the railway line immediately west of the church.
A steep engineered embankment creates a strong sense of separation of the church and its
setting from the settlement area south of the road. Overall the Ashchurch settlement area is
fragmented and significantly dissected by recent developments of the A46 highway.
Agricultural land and rural settlements
4.63
The rural land adjoining the site and within the general locality is primarily located to the
south of the A46 and its bordering settlement. The general field pattern is medium to large
scale with fields contained by well kept, low hedges. Hedgerow trees are infrequent and
woodland/copse limited but localised groups of taller hedge vegetation have been left to
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establish in more recent years. Fields are frequently regular in shape and interspersed with
small farms, small holdings and isolated settlement. Non domestic areas of land which are
impractical to farm are seen scrubby and rough within an otherwise smooth, active
agricultural landscape. The land is predominately gently undulating over poor draining
heavy vale soils. Large arable fields are common south of the site but small, contained
parcels of permanent pasture are common particularly in close proximity to isolated
settlement.
4.64
To the west of the site are the small dispersed hamlets of Natton and to the south
Homedowns.
Both settlements consist of isolated and dispersed properties contained
within the agricultural landscape but connected by minor roads and lanes which extend to
the main settlement areas. The settlement area of Walton Cardiff is located to the west of
the motorway corridor and more closely associated with the urban margin of Tewkesbury.
Hedges and garden vegetation contain the properties generally but several properties have
limited garden vegetation and are more exposed within the landscape. Structures are of
mixed ages and material with render finished dwellings more visually apparent than red
brick. Houses are small in scale but frequently with outhouses or other outbuildings.
Settlement frequently fronts onto the main access lanes or minor tracks which spur off the
main access roads.
Public Rights of Way
4.65
There are no public rights of way designated on the site. There is a public right of way
(AAS/8/1 & AAS/8/2) located to the south west of the site which utilises an underpass under
the motorway which incorporates the brook. The path extends along existing field
boundaries south of the watercourse, linking with the local lanes at Natton.
4.66
To the south of the area the Gloucestershire Way county trail (AWC/6/1) passes east/west
at Homedowns.
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Enhancement Potential
4.67
The site character assessment has identified a number of existing landscape features of
value including hedges and watercourse. Hedges are considered to be of only moderate
condition some of which are in declining condition due to intensive agricultural production.
These features have potential to benefit from enlarging and enhancing with long term
management focused on the development of ecological habitat. In addition the introduction
of hedgerow tree planting would introduce additional potential wildlife habitat and screening.
4.68
The introduction of new riparian vegetation along the course of the Tirle Brook has potential
to provide significant new wildlife habitat and to provide a new belt of vegetation which
would provide a screen between the existing commercial urban area and the rural
landscape to the south.
Landscape Baseline Summary
4.69
The site and immediate study area reflect characteristics representative of the district
Settled Unwooded Vale landscape character type. In particular the influence of major
transport corridors and rural areas bordered by large urban and suburban area interspersed
with commercial and industrial uses are less desirable characteristics notable of the site
and immediate study area.
4.70
Overall the local landscape character is considered to be of low landscape sensitivity due
to the adjoining commercial land use and a significant presence of major routes of
communication. The large scale and diverse structures associated with the commercial
area and communication routes breaks the local field pattern and introduces strong urban
character elements. The simple agricultural landscape is in contrast to the diverse
structures, styles and finishes seen in the built environment but the natural features are
predominately in poor condition.
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Visual
Area of Study
4.71
The area of study for the identification and assessment of the visual baseline was
established through desktop studies, production of a digital visibility map (ZTV) and
consultation with the local authority Landscape Officer.
4.72
A ZTV was produced based on a 14.5m and 15.5m height parameter to represent the
current proposals for development. The ZTV used a 1:25000 Ordnance survey (OS) map
base showing an area up to 10km radius of the site boundary. The ZTV illustrates the zone
of theoretical visibility based on landform without obstructing landcover such as woodlands,
hedges and built form. The digital exercise assisted with identifying potential areas with
views of the site within 10km radius of the site boundary.
Desk Study; identification of receptors
4.73 Review of topographical survey information, aerial photographs, ZTV, Ordnance Survey
maps and contours identified the following potential visual receptors:
- Settlement at Ashchurch including Newton Farm
- Settlement at Natton
- Settlement at Homedowns
- Settlement at Walton Cardiff
- Listed Buildings – Walton House, Walton Cardiff and St Nicholas Church, Ashchurch
- Users of Public Rights of Way immediately south of the site
- Users of public rights of way including the Gloucestershire Way on Cotswold Hills outliers
including Bredon Hill, Oxenton Hill and Cleeve Hill
- Motorists and pedestrians using the A46 highway and Fiddington Lane
- Motorists using the M5 motorway
- Users of commercial buildings facing onto the site at Ashchurch Industrial Estate.
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Site Survey; identification of receptors
4.74 Following the desk study identification of potential visual receptors, the list was further
refined during a site walkover by two Chartered landscape architects. Consideration to the
effects of land cover on the ZTV was made to identify areas where clear views were
identifiable. The following visual receptors were confirmed:
- Motorway junction 9 and associated south bound slip road
- The north bound carriageway of the M5 motorway on embankment south of junction 9
- Ashchurch Industrial Estate and linear urban area immediately adjoining the A46 where
views exist to the south
- Existing service station adjoining the northern site boundary
- Settlement at Newton Farm
- Settlement to the west of Natton
- Settlement at Homedowns
- Users of Public Rights of Way immediately south of the site
- Users of public rights of way including the Gloucestershire Way on Cotswold Hills outliers
including Bredon Hill, Oxenton Hill and Cleeve Hill
- Motorists and pedestrians using the A46 highway
- Motorists and pedestrians using Fiddington Lane
4.75 Confirmed visual receptors with views of the site were then assessed for viewpoints which
provide a good representation of those views from that area; sometimes encompassing
several receptors. The locations of these views were identified as viewpoints; from where
the visual assessment, notes and photographs of the view were recorded.
4.76 On completion of the initial assessment the Local Authority Landscape Officer was
consulted to seek identification of additional potentially sensitive visual receptors. The
Landscape Officer confirmed one further potential receptor (PROW at Oxenton).
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Visual Baseline Analysis
Summary of Visual Baseline Analysis
4.77 From short distance views, the site is of high visibility due to the close proximity of visual
receptors and limited height of local landcover i.e. low agricultural hedges. Views are
generally limited to motorists and pedestrians on or approaching the A46 and to occupants
of commercial buildings with south facing views across the A46. Views are experienced as
transient and sequential from vehicles but static from adjoining commercial premises.
These views are seen above low cut sections of the boundary hedge and are extensive and
distant where not obscured by foreground landcover. To the east views are seen from the
Fiddington Lane and from Newton Farm. Deeper views into the site from settlement in
Ashchurch are prevented by built form and established vegetation. From southern aspects
views into the site are limited to residential properties immediately adjoining or footpaths
which cross in close proximity to Tirle Brook. This visibility being due to the low height of
local field hedges and limited number of established trees. From the west views are
restricted by the motorway corridor and junction 9 interchange. Passengers and drivers in
vehicles driving north will have transient views across open farmland to the site for a short
period approaching junction 9. The visibility of the site is increased when seen from local
southern viewpoints due to the ridged landform. The form, elevation and associated
structural vegetation of the south bound slip road increasingly obscure the site when
travelling north bound. Travelling south bound the focus is to the south and south east
where views of the Cotswold Hills are prevalent.
4.78 From long distance viewpoints the site is identifiable from elevated locations which allow
panoramic views over the vale landscape. These views are distant but large scale
landscape features including commercial structures, railway and motorway corridors can be
identified assisting orientation of the view to the site. In all long distance views, the
panoramic nature of the view is expansive, extending to the Malvern Hills in the west and
Cotswold Hills to the east and south east. The site contributes a very small element of the
overall panoramic view and as such is negligible.
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Ecology
Introduction
4.79
The objectives of establishing the ecological baseline are twofold:

to describe aspects of the natural environment and to identify important and
protected habitats and species that could be adversely affected by the proposed
development; and

to characterise features that could be positively enhanced, created, restored or
managed, by establishing the occurrence, distribution and extent of ecological
features on site and in the surrounding area; and/or those species that could be
positively managed to enhance their conservation status, distribution and
abundance.
Context
4.80
Unlike the intensive agricultural habitats which dominate the site, natural and semi-natural
habitats usually support the greatest diversity of wildlife. Important species are those
protected by international or national legislation; those that have been identified in the UK
Biodiversity Steering Group Volumes I to VI as priority species, and those identified as
locally distinctive in a local BAP (e.g. ‘local keystone’, ‘flagship’ and ‘umbrella species’1).
4.81
Natural Areas are sub-divisions of England, each with a characteristic association of wildlife
and natural features defined by Natural England. Each Natural Area has a unique identity
resulting from the interaction of wildlife, landforms, geology, land use and human impact.
4.82
The site is located within the Severn and Avon Vales Natural Area. This Natural Area is
approximately 2,000km2 in size and is situated across Worcestershire and Gloucestershire,
with a small area within Warwickshire. The area is concentrated on the broad floodplains of
the Severn and Warwickshire Avon rivers and their tributaries, with much of the adjacent
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land flooding regularly in winter. The area has a number of relict wetland site, including old
pollards, wet pastures, ditches and tall hedgerows. The area is not heavily wooded and
there are only small areas of woodland that are scattered, although there are
concentrations of woodland in the north of the area. The area is generally fertile and is
intensively farmed with arable and livestock land as well as horticultural and fruit growing
land.
Designated Sites
Statutory
4.83
The nearest statutory site is Severn Ham Site of Special Scientific Interest (SSSI) which is
located approximately 2.7km west of the site (see Figure 4.1). This SSSI is designated for
its rare Ham Meadow habitat. This SSSI is separated from the site by open countryside, the
settlement of Tewkesbury and the M5 motorway.
4.84
The nearest European designation is Dixton Wood Special Area of Conservation (SAC) that
lies just within 5km of the east of the site. This SAC is one of only three known locations in
the UK for the Violet Click Beetle (Limoniscus violaceus) and is an area of broad-leaved
woodland surrounded by permanent pasture.
Non-statutory
4.85
The nearest non-statutory designated site of nature conservation importance is Walton
Cardiff Newt Ponds Key Wildlife Site (KWS), which is located approximately 200m southwest of the site on the opposite side of the M5 motorway. This KWS is designated for its
population of Great Crested Newt, and is separated from the site by the M5 motorway,
which is considered to be a considerable dispersal barrier to Great Crested Newts. Whilst
the Tirle Brook links this KWS with the site, the brook in itself is again considered to be a
dispersal barrier to Great Crested Newts.
.Habitats
4.86
The following main habitat / vegetation types were identified within the site:
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
Arable;

Hedgerows and Trees;

Copse;

Scrub;

Watercourse;

Ditch;

Grass Verge; and

Hardstanding.
Arable
4.87
The vast majority of the site comprises two large arable fields which had grassy margins
during the surveys undertaken in April 2012 but which were subsequently recorded as
having been ploughed (i.e. no margins) by November 2012. During the 2013 surveys, the
arable fields were seen to contain Barley crops.
4.88
Species present at the field margins included Cock’s-foot, Yorkshire Fog, False Oat-grass
and Fescues within the sward. Herbaceous species present included Dove’s-foot Crane’sbill, Hogweed, Broad-leaved Dock, Common Field Speedwell, Red Dead-nettle, Cow
Parsley, Hemlock, Cleavers, Creeping Thistle, Bristly Ox-tongue, Ground-ivy, White Deadnettle, Brassica species, Bramble, Lesser Burdock, Common Nettle, Dandelion, Groundsel,
Shepherds Purse, Teasel, Colt’s-foot, Daisy, Ribwort Plantain, Creeping Cinquefoil, Soft
Rush, Greater Plantain, Ivy, Yarrow, Sweet Violet, Scentless Mayweed, Prickly Sow-thistle,
Lords and Ladies, Common Mouse-ear, Fat Hen, Salad Burnet, Hedge Parsley, vetch sp.,
Primrose, White Clover and Common Ragwort.
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Hedgerows and trees
4.89
There is a generally continuous hedgerow along the northern western and eastern
boundary of the site that has been split into five sections corresponding with its structure
and management. There are also segments of hedgerow along the northern boundary of
Tirle Brook in the south of the site.
4.90
A number of trees are present within the site, largely associated with the hedgerows.
Species present include Field Maple, Elm, Sycamore, Ash, Elder and Willow.
Copse
4.91
There is a small copse present in the southeast of the site, adjacent to Tirle Brook and
Fiddington Lane. This copse is scrubby in nature and is species-poor, comprising only
Hawthorn and Blackthorn with Willow trees, and Common Nettle and Garlic Mustard
present in the ground flora.
Scrub
4.92
Scattered scrub is present running along S1, Tirle Brook (see below), with species present
including Dog-rose, Hawthorn, Blackthorn, Bramble, Elder and Wild Privet with Common
Nettle, Cleavers, Burdock and Hemlock associated with the scrub.
Watercourses
4.93
A single brook, Tirle Brook, is at the southern boundary of the site and runs from the east to
west of the site. Species present associated with the banks of the stream include Lesser
Celandine, Common Nettle, Creeping Thistle, Hemlock, Cleavers, Hogweed, Broad-leaved
Dock, Garlic Mustard, Wavy Bitter-cress, Lords and Ladies, Teasel, Prickly Lettuce and
Forget-me-not. Emergent and aquatic vegetation include Fools Water-cress, Typha, Great
Willowherb, Common Water Plantain, Water Crowfoot, Branched Bur-reed, Common Reed
and Flag Iris.
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Ditch
4.94
A drainage ditch is present running north-south. Species present associated with this ditch
are largely similar to those found within Tirle Brook.
4.95
Other smaller ditches are present associated with the hedgerows.
Grass Verge
4.96
There is a grass verge present along Fiddington Lane. Species present within the sward
include Cock’s-foot, Yorkshire Fog, False Oat-grass and Red Fescue. Herbaceous species
present include Hogweed, Broad-leaved Dock, Cow Parsley, Cleavers, Creeping Thistle,
Bramble, Lesser Burdock, Common Nettle, Dandelion, Ribwort Plantain, Creeping
Cinquefoil, Greater Plantain, Common Ragwort, Common Mouse-ear and White Clover.
Hardstanding
4.97
There are hardstanding roads present along the north (A46) and east (Fiddington Lane) of
the site.
Desk Study
4.98
Information received from the GCER returned no records of any notable plants form within
the site itself, although a record of Bluebell, a Schedule 8 species (protected from sale
only), was recorded from the same grid square as the site in 1998.
Wildlife Use of the Site
4.99
General observations were made during Ecology Solutions’ surveys, between April and July
2013, of any faunal use of the site with attention paid to the potential presence of protected
species. Specific surveys have been undertaken with regard Badgers, bats, wintering birds
and Great Crested Newts and further information can be found in the documentation
supporting the recent planning application.
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Ground Conditions
Geology
4.100 Geologically the site is underlain in its entirety by solid strata of the Charmouth Mudstone
Formation (CMF) with a broad swathe of overlying superficial alluvial deposits along the
south of the site (associated with the Tirle Brook). Mapping also records superficial sands
and gravels (Wasperton Sand and Gravel Member) to the north of the site, the southern
extent of which is coincident with the A46.
Mapping indicates no apparent geological
faulting within influencing distance of the site; there is also no made ground mapped
on/within the site.
Hydrogeology
4.101 The EA classifies the CMF as a ‘Secondary Undifferentiated’ aquifer, which means that the
EA has not been able to characterise the material due to the variable characteristics of the
rock type. This Practice’s experience of the CMF is that it mostly classifies as a nonaquifer. The overlying superficial alluvial deposits are classified as a Secondary ‘A’ (minor)
aquifer. Envirocheck data records no water abstractors within a 1km radius of the site and
confirms that the site is not located in a groundwater Source Protection Zone (SPZ).
Hydrology
4.102 The closest surface water feature is the Tirle Brook coincident with the southern site
boundary including the tributary which runs through the site. As a result a moderate swathe
of ground (broadly comparable to the extent of mapped alluvium) is deemed to lie within the
zone of influence of extreme flooding from rivers or seas without defences (zone 2). The
site is entirely of hardstand and therefore water infiltration at the site can currently be
regarded as high, subject to natural permeability.
Site History
4.103 Historical mapping confirms little significant change to the agricultural land use of the site
from the earliest available mapping of 1884 until the present day, although the adjacent
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village/suburb of Ashchurch shows continued residential and commercial/industrial
development.
Site Sensitivity
4.104 Based upon the available information contained within the Envirocheck Report service
offered by Landmark Information Group the site does not lie either inside or within potential
influencing distance of any environmentally sensitive areas.
Land use
4.105 Based upon the available information provided within the Envirocheck Report service
offered by Landmark, the current site of interest and its immediate surrounding area has not
previously contained and does not currently contain, or has not previously been affected by
any of the following:
a. Historical landfill or licensed waste management facility
b. Local Authority pollution prevention and control sites
c. Contaminated land register entries
d. Notifications of installations handling hazardous substances (NIHHS)
e. The use, storage and handling or radioactive or explosive substances
f. Groundwater or surface water abstraction points
g. Source Protection Zones
h. Coal mining or shallow mining
i.
Ground stability hazards relating to collapsible ground, ground dissolution, landslide,
running sand and shrinking and swelling clay.
The potential stability hazards
associated with compressible ground are locally considered to be moderate, although
this is likely associated with localised alluvial deposits proximal to the Tirle Brook.
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Potentially Contaminative Uses
4.107 Based upon the review of historical Ordnance Survey mapping the site would appear to
have been entirely agricultural usage, and although this suggests “greenfield” status,
potential contaminants relating to this land use may have resulted in localised impaction to
the subsoil from toxic and phytotoxic metals, hydrocarbon compounds (fuel/oil associated
with the BP service station coincident with the northern site boundary), PAH compounds
within ash/charcoal based topsoil/made ground, and pesticide residues from crop spraying.
4.108 The closest active discharge consent relates to trade discharge of process water at Dowty
Seals Ltd some 34m to the north into the Northway Brook. This is unlikely to influence the
site in any way.
4.109 There have been sixteen recorded Category 3 (Minor) pollution incidents to controlled
waters within the local area but none on the site itself, with the closest occurring to the
immediate northeast of the site in April 1996 when a septic tank released tank effluent into
an unidentified watercourse, presumably the Tirle Brook. Given the time elapsed since the
incident, there is highly unlikely to be any lasting detrimental effect upon the site.
Summary of Ground Conditions Encountered
4.110 Based upon information available at the time (preceding Phase 1 researches), intrusive
investigation was undertaken, targeted to reflect the former/existing site usage though also
to provide overall site coverage. Intrusive investigation identified a consistent ground profile
beneath the site concordant with geological mapping comprising clay/mudstone
representing the upper weathered mantle of the Charmouth Mudstone Formation, overlain
by topsoil and subsoil deposits and locally by a superficial covering of River Terrace
Deposits. Whilst the topsoil and subsoil horizons represent ‘disturbed’ deposits resulting
from agricultural activity on the site, there was no evidence of made ground or
contamination in any site arisings. Only one minor groundwater seepage was recorded
during the drilling process, although monitoring wells in boreholes subsequently showed
groundwater levels slowly rising over time, most likely attributable to the recent prolonged
wet weather leading to groundwater infiltration by way of minor seepages via fissures in the
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clay. For a detailed description of ground conditions including borehole and trial pit logs,
reference should be made to WA Geotechnical Design Report, ref: 3553.
Summary of Contamination Risk Assessment
4.111 A detailed contamination risk assessment including toxic and phytotoxic metals, TPH, PAH,
pesticide and acidity analysis indicates that the site is effectively uncontaminated where
there is no perceived risk to human health and similarly no significant risk to controlled
waters.
On the basis of the foregoing there are no specific recommendations for
remediation and/or supplementary investigation.
For a detailed review of laboratory
contamination analysis and the ensuing risk assessment, reference should be made to WA
Geotechnical Design Report, ref: 3553, included in Appendix 7.1.
Heritage and Archaeology
4.112 The results of previous field studies conducted within the site have served to investigate
and identify its potential to contain heritage assets of interest, and the detailed results of
these surveys are presented at Appendices 8.1. to 8.4 of this ES. Accordingly, this section
of the ES summarises those resources identified.
4.113 Previous field evaluation conducted within the site in 1992 comprised an assessment of its
historic background, preliminary non-invasive fieldwalking and the excavation of a total of
26 trial trenches. Fieldwalking within the site recovered only a small number of pottery
sherds as residual surface material, the presence of which were concluded to be as a result
of Medieval and/or Post Medieval agricultural manuring practices. Subsequent trenched
evaluation within the site identified a focus of late Iron Age/Romano-British settlement
activity to be present within its north-western extent, comprising several ditch features and
two inhumation burials. These remains were interpreted as probably representing outlying
enclosures and a small cemetery belonging to a focus of Romano-British settlement
previously recorded to the west of the site during the construction of the M5 carriageway.
Elsewhere, further recorded evidence across the rest of the site comprised only former
Medieval cultivation remains (plough furrows) and a small number of north to south aligned
ditches reflecting the remains of former Post-Medieval field boundaries, evidence for which
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broadly accorded with the historical analysis of the site that concluded that it lay within open
agricultural fields associated with likely Medieval settlement foci in the immediate area.
4.114 In view of the limitations on the scope of the field studies conducted in 1992 on the site, and
to accord with current sampling procedures and best practice in the county, a detailed
magnetometer (geophysical) survey, incorporating the site, was undertaken by Stratascan
in. The results of this survey has provided an enhanced understanding as to the extent,
form and focus of the previous Late Iron Age/Romano-British occupation activity identified
in 1992 to be present within its north-western extent, that is represented by a complex of
positive linear anomalies reflecting a series of enclosures and an adjacent trackway,
indicative of a farmstead settlement. Two further curvilinear anomalies of uncertain, but
possible archaeological origin, were also identified at the far north-eastern extent of the site.
North to south aligned ridge and furrow cultivation remains, as previously identified from
evaluation in 1992, were also noted as being present across the site.
4.115 Following the survey, an archaeological watching brief was maintained within the site, by
Cotswold Archaeology between late 2012 and early 2013, during the course of geotechnical
trial pit and borehole investigations. A total of 12 test pits and boreholes were monitored,
but no archaeological features or deposits were observed or recorded.
4.116 In order to examine the results and conclusions drawn by the 1992 field evaluation
conducted within the site and to corroborate the results of the geophysical survey, the
excavation of a further 24 trial trenches was undertaken by Oxford Archaeology in 2013.
4.117 The results of this additional evaluation broadly accord with those of the evaluation
conducted within the site in 1992 in that it has confirmed the presence of anomalies
recorded by the geophysical survey within its north-western extent and provided additional
dating evidence to confirm this as an area of probable 1st to 3rd century Roman occupation
activity, with possible late Iron Age origins, likely reflecting a possible agricultural farmstead
settlement. Examination of further identified anomalies at the north-eastern extent of the
site produced no corresponding below ground archaeological remains, and the results
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produced by the geophysical survey in this area are considered likely to have been as a
result of later activity associated with the entrance to the field and a modern service trench.
4.118 Elsewhere across the site and beyond the focus of the identified Roman occupation activity,
the evaluation confirmed an absence of any further archaeological remains other than for
later cultivation activity, reflecting both the result produced by the 1992 evaluation exercise
and recent geophysical survey. This absence of any associated activity to the Roman
settlement identified is considered likely to relate to the proposed development sites
situation within the floodplain of the Tirle Brook, it being notable from the evaluation results
that areas of identified occupation activity are focused on apparent topographical high
points within the landscape, a similarly discrete area of occupation activity being noted by
evaluation to the south of the Tirle Brook and site.
Designated Assets
4.119 There are no designated heritage assets identified to lie within the site itself, and as such
Proposed Development would have no direct impact on any such asset.
4.120 A number of designated heritage assets are identified to lie within a c.500m radius (study
area) surrounding the site and further consideration of the potential effects of Proposed
Development within the site on the significance of their associated settings is necessary.
These assets are illustrated on Figure 8.1 and comprise:
 Church of St Nicholas, Grade II* listed building;
 Yeend Monument and John Rowles Monument, Grade II listed chest tombs within
churchyard of Church of St Nicholas;
 The Rectory, Grade II listed building;
 Church Farmhouse, Grade II listed building; and
 Milestone, Grade II listed structure.
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4.121 Of the designated assets identified above, those of St Nicholas’s Church, the Yeend and
John Rowles Monuments, The Rectory and Church Farmhouse, form a coherent group of
buildings situated at the northern extent of Ashchurch, c.280m to the north-east of the site.
The designated milestone, lies in isolation, being situated along the current A46
carriageway, c.480m to the west of the site.
Building group north of Ashchurch
4.122 These built heritage assets were variously designated in 1960 and 1987. The Church of St
Nicholas dates from the 12th century although has been much restored in the late 19 th and
early 20th centuries, with later 20th century extension. The Yeend and John Rowles chest
tomb monuments lie within its associated churchyard and date from the 17th century.
Church Farmhouse, a timber frame building with brick infills, dating from the late 16 th to
early 17th century, and extended in the 19th century, lies adjacent, and may have once
served as the church rectory. The Rectory, that again lies adjacent to the church, dates
from the mid-19th century and is a red brick building with later extension.
4.123 The primary settings of this group of listed buildings relates to there existing curtilages and
their inter-relationship with the church as a focal point. In their wider setting, they can be
seen to form a coherent group forming the historic core of the village of Ashchurch, the
modern focus of which now lies to the south. Whilst the former setting beyond the identified
assets and village would have once been predominantly rural in character, this has been
subject to considerable alteration and encroachment by subsequent previous development.
4.124 As such, all of the identified assets, and including the current modern core of settlement at
Ashchurch, can be seen to be dislocated from the site by the line of the Worcester to
Gloucester railway that runs north to south between them. The development of the railway
line and later adjacent industrial units to the north has caused severance to any former
setting relationship that may have once existed between the site and Ashchurch, these
assets having no intervisibility with the site.
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Milestone on the A46 carriageway
4.125 The milestone situated along the current A46 was designated in 1987 and dates from the
19th century. Its setting can be seen to relate directly to its function as a visual marker along
a former and existing carriageway. The carriageway along which the milestone lies (now
the A46) has been subject to significant later alteration and modification, such as by the
development of the M5 carriageway that runs north to south between the milestone and the
site and its associated roundabout junction forming Junction 9 with the M5. There is no
visual connection between the site and this asset and no setting relationship can be seen to
exist between them.
Agricultural Circumstances
Agricultural land
4.126 Consideration of the Agricultural Land Classification of England and Wales indicates that
the 19.3 ha of agricultural land which will be permanently taken for the proposed
development is mapped as Grade 3 on the Provisional Land Classification maps.
4.127 Details obtained from Natural England regarding a pre 1988 survey of the area mapped the
site as subgrade 3b.
4.128 Detailed fieldwork has been undertaken in February 2013 using the revised ALC guidelines
and indicates that the Provisional classification was correct with the land mapped
predominantly as subgrade 3b with smaller areas of subgrade 3a.
4.129 Therefore the development site includes, in part, land of significant quality, i.e. ‘best and
most versatile agricultural land’ (BMV) (as defined in Annex 2 of the NPPF) and authorities
should take into account the economic and other benefit of this type of land (NPPF para
112).
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4.130 The policy does not prohibit the development of BMV land; rather, it applies to losses of
significant areas of BMV land. It details that where significant development of agricultural
land is demonstrated to be necessary, local planning authorities should seek to ensure that
the possibility of locating development elsewhere, or on lesser quality or previously
developed land has been investigated.
4.131 There is no practical alternative to taking the BMV land for the scheme as it lies
predominantly in the centre of the proposed development site. The overall importance of
this on a national scale is considered to be Low. By reference to the criteria set out in
Tables 10.1 - 10.4, the impact of the loss of 8.31 ha of BMV land is considered to be Low or
Moderate. The Moderate Adverse impact on a Low sensitivity factor indicates this loss may
be considered to be of Low/Moderate Adverse overall significance of effect.
Farm Businesses
4.132 This subsection considers the impacts of land take and/or severance on each farming
business affected by the proposed development.
4.133 One farm business will be affected by permanent land-take for the proposed development.
This business is operated by Boddington Estates (the farming subsidiary of Robert Hitchins
Limited) and although no formal tenancy is in place, a rent is paid for the use of the land.
The farm business extends to approximately 630 hectares which includes grassland, arable
and woodland. The land is generally in three main blocks, with the land at Fiddington being
one of those land parcels.
4.134 The loss of the land at Fiddington amounting to approximately 20 hectares will represent
approximately 3% of the overall land area farmed by Boddington Estates.
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4.135 The scheme will not result in the loss of any buildings or fixed equipment utilised by the
farm and will not leave isolated small pockets of land severed from the remaining land
block. Access will still be possible to all land remaining in agricultural production.
Summary
4.136 The assessment work undertaken in connection with the current application for outline
planning demonstrates the site’s suitability for development for employment generating
uses as proposed in the emerging JCS.
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Appendix 3
Position Statement: Strategic Allocation Former MoD site Ashchurch
1
Introduction
1.1
This statement sets out further information in respect of those parts of the proposed Policy
A8 allocation that lie to the north of the MOD site and are allocated for residential
development. It presents details of the emerging concept plan for this part of the allocation
1.2
As mentioned in our representations RHL has doubts as to the timely delivery of the MOD
parts of this allocation due to its current land use, need for site clearance and land
remediation before development can be commenced. With that in mind and to ensure a
satisfactory independent access it is proposed that this allocation be extended northwards
so that access can be achieved at an early stage from the B4079. This would link via
improvements to the railway crossing with Grange Road and thence Hardwick Bank Road.
This connection will provide sustainable links to the existing community and associated
facilities without traffic going via the A46.
2
Baseline Information
2.1
The majority of this area is identified as being of low landscape sensitivity, the proposed
extension as being of medium sensitivity.
The site is not identified as being at risk of
flooding and there are no environmental designations precluding the development of this
land.
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3
Emerging Concept Plan
3.1
Having regard to the evidence base the plan below shows how up to 1,200 dwellings, a
centrally located primary school, public open space and playing fields could be
accommodated in this area with strategic landscaping along the northern margins of the
site.
Concept Plan Key Components
Proposed extension to
allocation (3.58ha)
Residential
Residential
Residential
MOD Depot
N
Links to existing community and
associated facilities
Not to Scale
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4
Land Use Budget
Land use
Area (Ha) Amount/Comments
Residential
35.00 (31.1 ha net) Up to 1,200 units
Primary School
1.75 Two form entry
Public open space/Recreation (inc
12.11 Including pitches
suds)
Strategic landscaping
5.05 Northern buffer and existing tree
belt
Total
5
53.91
Phasing
2
2
1
2
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6
Delivery programme
Pre-Commencement
Date
Event
September 2014
Application for outline planning permission submitted
September 2015
Outline planning permission granted
March 2017
Commence House building
September 2017
First Financial Completion
Delivery: Accesses from Grange Road and B4079
Year ending March
Housing
Other
2016
2017
2018
30
2019
95
2020
95 Primary school
2021
95
2022
95
2023
95
2024
95
2025
95
2026
95
2027
95
2028
95
2029
95
2030
95
2031
30
Total
1200
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Appendix 4
Position Statement: Ashchurch/Fiddington
1
Introduction
1.1
This statement outlines details of a proposed urban extension to the south of the Ashchurch
Strategic Allocation (Policy A9) and summarises the baseline work undertaken. It presents
details of the emerging concept plan including land uses and phasing thereof and sets out
an expected delivery programme.
1.2
The objective for the scheme is to deliver up to 900 homes, school, local centre together
with community facilities and leisure and recreation opportunities all set within an extensive
area of green infrastructure linking with the proposed strategic allocation immediately to the
north.
2
Baseline Survey Work
2.1
Baseline survey work as summarised in section 7 has been undertaken and has looked at
all aspects of the environment in order to further inform the emerging concept plan.
3
Emerging Concept Plan
3.1
Having regard to the baseline survey work undertaken the plan below shows how about
900 dwellings, a local centre, primary school, social and community facilities, landscaping
and public open space could be accommodated.
3.2
The primary school is located centrally within the proposed development as is the local
centre and playing fields.
The latter is located within an extensive area of green
infrastructure providing links to the north.
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Concept Plan: Key Components
Not to Scale
Strategic Allocation Policy A9
Link to Newtown,
Walton Cardiff
and Tewkesbury
Green
Infrastructure
Residential
Link to Walton
Cardiff and
Tewkesbury
4
Local
Centre
Residential
School
Land Use Budget
Land use
Residential
Local Centre
Area (Ha)
Amount
25.00 (23.5 ha net) up to 900 units
0.6
Primary School
1.75 One form entry expandable to two
Green Infrastructure including formal,
20.4
informal areas and SuDS
Total
47.75
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5
Phasing
5.1
The plan below shows the phasing envisaged for the development.
Not to Scale
Strategic Allocation Policy A9
1
1
3
2
6
Delivery Programme
Pre-Commencement (Fiddington)
Date
Event
June 2014
Application for outline planning permission submitted
June 2015
Outline planning permission granted
December 2016
Commence house building
June 2017
First Financial Completion
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Delivery Fiddington
Year ending March
Housing
Employment
Other
2016
2017
2018
50
2019
75
2020
75
2021
75
2022
75
2023
75
2024
75
2025
75
2026
75
2027
75
2028
75
2029
75
2030
25
Local Centre
School
2031
Total
900
7
Summary of baseline Survey Work
7.1
The following section summarise the environmental baseline studies which have been
undertaken in order to inform the emerging concept plan for the proposed development.
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Ecology
7.1
Extended Phase 1 Habitat Surveys have been undertaken between April 2012 and July
2013.
7.2
A series of protected species surveys (Great Crested Newts, bats, Water Voles, Otters,
Badgers and wintering Birds) have also been undertaken between April 2012 and July
2013.
7.3
The site is mainly agricultural land of low ecology value (primarily arable with occasional
grassland/pasture) divided by hedgerows. The Tirle Brook forms the northern boundary and
there are a network of field ponds (some of which are dry).
7.4
The site does not include any statutory nature conservation designations. The nearest nonstatutory designated site of nature conservation importance is Walton Cardiff Newt Ponds
Key Wildlife Site (KWS), which is located on the opposite side of the M5 motorway. This
KWS is designated for its population of Great Crested Newt, and is separated from the
Application Site by the M5 motorway, which is considered to be a considerable dispersal
barrier to Great Crested Newts. Whilst the Tirle Brook links this KWS with the Application
Site, the brook in itself is again considered to be a dispersal barrier to Great Crested Newts.
7.5
A low population of Great Crested Newts was identified utilising two ponds in the centre of
the site. Optimal terrestrial habitat for this population is largely absent within the site in
proximity to the ponds (being predominantly arable but with hedgerows). Necessary
precautions and mitigation/enhancement will form an intrinsic part of the Proposed
Development as appropriate.
7.6
A series of bat activity surveys have been undertaken as habitats (hedgerows, trees and
brook corridor) present foraging and commuting opportunities for this faunal group. There
are no buildings within the site that would be lost to any development proposals although
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trees exhibiting potential to support roosting bats have been identified in the site; all of
these can be retained in areas of open space.
7.7
Wintering bird surveys were conducted in November 2012 to assess if the site was likely to
be important in this regard. Given the small numbers of wintering birds and lack of any large
flocks within the context of the large size of the Application Site, it was not deemed
necessary to carry out further wintering bird surveys as the Site is clearly of low value in this
regard.
7.8
Evidence of Otter footprints were recorded at the very eastern end of the Tirle Brook but no
evidence of Otter holts or spraints were recorded during the survey. No evidence of Water
Vole was recorded during the specific surveys for this species.
7.9
A number of badger latrines were recorded along the Tirle brook and a disused badger sett
has been recorded. The sett has been subject to periodic monitoring in 2012 and 2103.
7.10
Opportunities for ecological enhancements within the Proposed Development will be
identified and these will be used to promote a net gain in biodiversity across the
development. In particular these will aim to incorporate the goals of the local Biodiversity
Action Plan.
Ground Conditions
7.11
A Phase 1 Geo-Environmental Desk Study of land to the south of the Tirle Brook in
Fiddington, Tewkesbury has been undertaken in order to identify and evaluate the
former/current site usage, environmental setting and its likely contamination status. This
has enabled formulation of a preliminary risk assessment to determine any plausible
pollutant linkages with regard to potential impacts to human health and/or controlled waters,
the results of which were used to define the scope of Phase 2 intrusive works.
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7.12
A review of historical Ordnance Survey mapping confirmed little significant change to the
agricultural land use of the site from the earliest available mapping of 1884 until the present
day. The site possesses no buildings and there was no expectation of significant made
ground and/or contamination, although possible low-level contamination associated with the
former/current agricultural site usage should not be discounted.
7.13
In view of the above, the following potential sources and principal contaminants of concern
were considered relevant:

Toxic and phytotoxic metals, as well as polyaromatic hydrocarbon compounds within
general near-surface made ground and/or topsoil;

Insecticide / fertilizer residues within topsoil;

Gypsum crystals within natural Charmouth Mudstone Formation clays/mudstones
representing a potential source of elevated sulphates/sulphides.
7.14 There are no recorded former or active landfills within the site or within potential influencing
distance. There are similarly no recorded features such as potentially infilled ponds, quarries
or gravel pits etc, therefore landfill gas monitoring was considered unnecessary.
7.15 A detailed contamination risk assessment including the above potential contaminants of
concern indicates that the site is effectively uncontaminated where there is no perceived risk
to human health and similarly no significant risk to controlled waters in light of the proposed
residential development. On the basis of the foregoing there are no areas identified within
the site where contamination may pose a constraint to future development and thus there
are no specific recommendations for remediation and/or supplementary investigation.
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Noise
7.16 An assessment of the existing noise levels across the Proposed Development area has
been undertaken through unattended noise monitoring supplemented by attended sample
noise measurements. The exercise indicated noise levels are principally influenced by road
traffic using the M5, which runs along the western boundary and, to a lesser extent, rail
traffic travelling along the railway line to the east.
7.17 In order to inform a planning application, noise levels within the proposed development
areas will be assessed against the guidance contained within the NPPF and BS 8233, to
demonstrate that a satisfactory noise environment can be achieved within the proposed
residential areas.
7.18 Appropriate noise mitigation measures are likely to be required along the western boundary
adjacent to the M5, which is likely to comprise bunding / noise barriers together with the use
of an appropriate buffer between the road and dwellings. Consideration would also be given
to ensuring appropriate glazing and ventilation were adopted within dwellings close to the
M5.
7.19 With appropriate mitigation and design measures incorporated into the final Masterplan, it is
anticipated that an acceptable noise environment for future residents across the site would
be successfully achieved.
Archaeology and Cultural Heritage
7.20 The proposed development site has been the subject of a previous desk-based assessment
and field evaluation (comprising field-walking and trenched evaluation) undertaken by
Oxford Archaeology in 1992.
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7.21 The desk based study and subsequent recent site inspection has confirmed that there are
no statutory protected heritage assets identified to lie within the proposed development site
or its immediate vicinity, such that proposed development would result in harm to any such
asset or their setting.
7.22 Previous field studies on the site, comprising field walking and trial trench evaluation, have
indicated the presence of activity dating to the late Prehistoric, Roman, Medieval and Post
Medieval periods, the evidence for which recorded in 1992, was not considered to be of
sufficient quality, rarity or importance to warrant in situ preservation.
7.23 In view of the time that had elapsed since these earlier studies were conducted, the local
planning authorities archaeological advisor at Gloucestershire County Council was
consulted and it was advised that the field studies conducted in 1992 no longer accorded
with current sampling standards or approaches. On this basis, they may not therefore be
considered to provide sufficient information to inform as to the likely extent of any
archaeology, the periods represented, or the significance of the assemblage of remains that
may be present to support the development proposals, as required by the NPPF and Local
Plan policy.
7.24 A programme of further on-site investigations were therefore agreed with the local planning
authorities archaeological advisors, these comprising initial detailed geophysical survey
followed by additional trial trenching.
7.25 Initial geophysical survey across the site produced results that broadly corresponded with
the interpretations of activity identified by evaluation conducted in 1992, in that a focus of
probable enclosures and discrete geophysical anomalies were recorded within the central
north-eastern area of the site wherein earlier evidence of Iron Age activity had been
previously identified. A number of further potential and possible anomalies were however
also recorded by the geophysical survey that did not correspond with previous trench
locations and where adjacent trenching had produced negative results for archaeological
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remains. The survey also highlighted the remnant pattern of Medieval/early Post-Medieval
ridge and furrow cultivation that formerly existed on the site.
7.26 On the basis of the results produced by the geophysical survey, further trial trenching was
implemented both to target the anomalies identified and to provide for an appropriate spatial
sample of the site area. The evaluation confirmed three small foci of activity to be present
within the north-eastern area of the site. These comprised two foci of late Prehistoric (Iron
Age) settlement activity represented by enclosures containing evidence of oven structures,
both of which correspond with evidence recorded from previous evaluation, and a foci of
later Early Roman occupation represented by a further enclosure with associated evidence
of an oven structure where no previous evidence had been recorded. No further activity
beyond former ridge and furrow cultivation of Medieval/early Post-Medieval date was
recorded across the majority and remaining area of the study site. The evidence from the
evaluation would suggest a correlation between the recorded foci of archaeological activity
and existing topographic high points on the site. The remains recorded are considered to be
of no more than local to regional importance.
Agricultural Circumstances
7.27
An assessment of the effects of the non-agricultural development on the soils and other
agricultural factors of the approximately 49.64 ha of agricultural land at Fiddington has been
undertaken.
7.28
The site has been the subject of an Agricultural Land Classification (ALC) survey and the
results have been analysed and are set out in the table below.
GRADE
% TOTAL SITE
1
-
2
-
3a
13.0
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7.29
3b
81.8
4
-
5
-
Non Agricultural
0.3
Farm Buildings
0.6
Not surveyed
4.3
Total
100.0
The site comprises predominately agricultural land, which is an arable and grassland use
and is occupied by three separate farming/rural businesses/landowners.
7.30
The proposal at Fiddington will involve the development of approximately 49.64 ha of
agricultural land.
The majority of the land (approximately 82%) is not best and most
versatile agricultural land, i.e. land which falls into Grades 1, 2 and 3a of the ALC system.
The proposal will result in the loss of some of the best and most versatile agricultural land,
amounting to approximately 13% of the site area.
7.31
It is noted that the land quality across the site is typical of the area. The Provisional
Agricultural Land Classification map indicates that the majority of the land around
Fiddington is likely to be of Grade 3 quality. The areas of Grade 3a land are in two patches
on the site. Given they cover only parts of fields, it would be difficult to exploit the areas to
their full potential as under normal farming practices the area would need to be farmed to
reflect the qualities of the lowest grade present.
Landscape and Visual Context
7.32
A landscape and visual impact assessment of the site has been undertaken. The site is not
within any landscape designation and is therefore considered to be of low landscape value
in a district context. The high value landscapes of the Cotswolds AONB and Special
Landscape Area are located 3 kilometres to the east of the site. There are three public
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rights of way that cross the site and the long distance trail, the Gloucestershire Way,
adjoins the southern boundary.
7.33
The landscape character of the site is representative of the local character type which is
predominantly Settled Unwooded Vale – a rural landscape at the edge of urban and
commercial centres with considerable influence from major communication routes. Site
features are rural in quality and scale but they are contained by significant built form which
dissects the landscape other than to the south of the site. The application site forms a
transition from urban to rural landscape and the characteristics of each are experienced
differently according to location. From the elevated positions of the Cotswold Scarp and
Bredon Hill the site is seen in the context of established large scale commercial structures
and the residential edge of Tewkesbury within the settled vale landscape.
7.34
Development of the site will have visual effects on immediately neighbouring residential
properties and public footpaths primarily due to the loss of openness and a corresponding
extension of the current urban edge.
7.35
Development of the site will not have adverse landscape or visual effects on the local
settlement areas at Ashchurch, south of Homedowns, Natton east of the railway or west of
the M5 motorway.
7.36
Development of the site will not have adverse landscape or visual effects on the
surrounding settlement areas of Newtown, Walton Cardiff, Northway or Tewkesbury. In
addition the key views experienced of Tewkesbury Abbey can be preserved along public
rights of way and within public open space.
7.37
The overall landscape effects will result in moderate adverse impacts. This is due to the
contrast and magnitude of change experienced overall from open agricultural land to
residential development. In terms of the individual landscape features it is considered that
the development of the land can provide opportunities to protect existing features, introduce
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new landscape features to improve landscape quality and character and provide multifunctional quality green spaces and green infrastructure links.
7.38
From long distance views from the elevated viewpoints within the Cotswolds AONB the
introduction of new built form will be identifiable due to its proximity to large commercial
structures and communications corridors. However, it will be seen in the context of existing
settlement as a small element within the panoramic long distance views towards the
Malvern Hills.
7.39
The site has been assessed as having good potential to mitigate landscape and visual
effects which arise from development using new hedge and tree planting.
7.40
Combined landscape studies have shown that the study area has capacity for the
introduction of new development without significant impacts on both landscape character
and visual amenity. This is due to the predominantly level nature of the site and its context
with existing settlement areas, established commercial built form and communication
corridors.
Hydrology, Drainage & Flood Risk
Assessment of Flood Risk:
7.41
A preliminary assessment of flood risk has been undertaken for the development of the land
at Fiddington.
Level 2 Strategic Flood Risk Assessment (L2SFRA):
7.42
The land at Fiddington is not considered in the Level 2 Strategic Flood Risk Assessment
(SFRA) produced as part of its evidence base for the Gloucester, Cheltenham &
Tewkesbury Joint Core Strategy. The land immediately to the north is however included in
the L2SFRA – Additional Sites: January 2013. The land to the north is referred to as Site T3
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in the assessment; the T3 site has been used as a basis to inform the preliminary
assessment of flood risk for the land at Fiddington.
Flood Mapping:
7.43
The L2SFRA mapping and Environment Agency (EA) online mapping show the site to be
predominantly Flood Zone 1 (low risk, less than 1:1,000 annual probability of flooding) with
the northern edge of the site adjacent to the Tirle Brook in Flood Zone 2 (medium risk,
between 1:100 and 1:1,000 annual probability of flooding), Flood Zone 3a (high probability
between 1:20 and 1:100) and 3b (functional floodplain, less than 1:20 annual probability of
flooding).
7.44
The Tirle Brook has been modelled to accurately define the flood extents for the 1:100 +
climate change and 1:1,000 flood events. The results of the modelling have been agreed
with the EA and the EA has confirmed that the agreed extents should be used for assessing
flood risk.
Recommendations (based on the L2SFRA – Additional Sites):
7.45
The flood mapping and modelling show that parts of the site are affected by Flood Zones 2,
3a and 3b with historic flood outlines showing that areas of the site have been affected by
fluvial flooding. In addition, there is a risk of flooding from surface water and a residual risk
from culvert blockage (Tirle Brook culvert under M5).
7.46
The SFRA recommends that the Sequential Test approach of locating development in the
areas of lowest probability of flooding should be followed. If following the application of the
Sequential Test it is not possible to locate development in the areas with a lower risk of
flooding then the Exception test should be applied (see Technical Guidance to the NPPF
Table 3).
7.47
It is recommended that for all development, it must be ensured that the vulnerability of
flooding from other sources is considered as well as the effect of the new development on
surface water runoff.
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7.48
Any modifications of ground levels within Flood Zones 2, 3a and 3b will require flood
compensation. Compensatory flood storage and adequate flood risk management must
show that there is no increase in flood risk elsewhere.
7.49
The site is almost entirely green-field so any development is likely to result in an increase in
surface water run-off, however this can be appropriately managed through the development
of a SuDS management/treatment train for the site.
7.50
The site is underlain by Mudstone which is typically made up of clay particles that give rise
to very limited permeability. Therefore infiltration based SuDS techniques are not likely to
be appropriate at this site.
7.51
The Exception Test must be applied to all More Vulnerable development in Flood Zone 3a
(<1% AEP). The flood hazard shown for the 1% AEP event within the site is generally low to
moderate and the flood risk area covers a reasonably small proportion of the overall site
area. Safe access and egress to the site should be possible from the A46 north of the site.
Therefore there is a good prospect of suitable flood risk management measure being
employed to enable development to pass the Exception Test.
7.52
It should be noted that much of the area within the 1% AEP flood extent also lies within the
functional floodplain (Flood Zone 3b). The Exception test cannot be applied to support
development other than Essential Infrastructure in the functional floodplain (Water
Compatible development is also considered suitable). This will likely preclude most types of
development being considered in this part of the site.
NPPF Sequential Test:
7.53
In accordance with the National Planning Policy Framework (NPPF) Sequential Test
approach to development and flood risk, and in accordance with the recommendations of
the L2SFRA, development will be located in Flood Zone 1 which has the lowest risk (less
than 0.1% or 1:1,000 annual probability).
7.54
In accordance with the NPPF and L2SFRA development in Flood Zones 2 and 3a will be
restricted to water compatible development such as amenity open space, nature
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conservation and biodiversity, outdoor sports and recreation and essential facilities such as
changing rooms.
Site Specific Flood Risk Assessment (FRA):
7.55
In accordance with the requirements of the NPPF and the L2SFRA recommendations a Site
Specific FRA will be produced to demonstrate that the site can be safely developed without
flood risk, from any source, and without increasing flood risk elsewhere.
Sustainable Drainage System (SuDS):
7.56
Surface Water will be managed through the use of an appropriate sustainable drainage
system incorporating the surface water management train principles and including green
infrastructure such as basins, ponds and swales. The FRA will include details of a surface
water drainage strategy incorporating SuDS, including green infrastructure such as ponds,
basins and swales.
Water Quality:
7.57
The FRA will consider water quality and demonstrate that the development of the site will
not adversely affect the water environment and will identify ways in which the development
can contribute towards the enhancement of it, helping to improve the ecological status of
downstream watercourses in accordance with the Water Framework Directive objectives.
Development Levels:
7.58
To ensure that the proposed dwellings are not at risk from flooding floor levels will be a
minimum of 600mm above the 100 year flood level, including allowance for climate change.
Flood Routes:
7.59
The FRA will identify existing and proposed flood routes and ensure that existing paths are
maintained or enhanced and that new routes are provided to direct any surface water flows
safely through the development without causing flood risk to existing or new properties.
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Safe Access:
7.60
Safe dry access is available from the A46 to the north. The access will cross the Tirle Brook
through Flood Zones 2, 3a and 3b. The access is considered to be essential transport
infrastructure which has to cross the area of risk. In accordance with the requirements of
the NPPF Exception Test the FRA will demonstrate that the road link will not impede flows
or increase flood risk elsewhere through the provision of flood compensation areas and
flood culverts under the road.
Foul Sewerage Infrastructure:
7.61
Severn Trent Water has confirmed that there will be capacity within their foul sewerage
infrastructure to accommodate flows from the proposed development without any increase
in the risk of flooding.
Conclusion:
7.62
The preliminary assessment concludes that there is no significant flooding or drainage
issues that would prevent the development of the site. Therefore in terms of flooding or
drainage the land is considered to be a sustainable location for development.
Summary
7.63
The environmental baseline survey work undertaken to-date and summarised above
demonstrates the suitability of this site for the development proposed.
4 December 2013
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