Jeremy Hilton has written to the city council development control team to raise objections to their recommendation to approve Redrow’s planning application 18/00306/FUL to build 100 houses on the former Civil Service Club Sports Ground.
Cllr. Hilton believes this to be inconsistent with the planning committee’s decision on the 4th December when it rejected the application for 89 properties on the same site. The planning committee are meeting on Tuesday the 8th of January at 6pm to determine the application for 100 houses.
Jeremy Hilton has listed ten reasons why the application should be rejected. Here are his objections in full.
A. Housing Types:
The development meets the 20% affordable homes target, with appropriate mix of housing types, but it does not meet the requirement for market housing mix, with no provision for one or two bedroom homes. Kingsholm & Wotton has a good mix of housing and so should any new development in the ward. The applicant proposes 31 three bedroom houses and 49 four bedroom houses. The mix according to SHMA should be 9 one bedroom homes, 23 two bedroom homes, 30 three bedroom homes and 18 four bedroom homes. Rejection on this policy alone would be consistent with the committee decision on the 89 house application.
B. Land Purchase:
The applicants purchased the sports ground from the Civil Service Sports Council Ltd for just £10,000 in 2011 (GR355501). The applicants should publicly declare the details of the uplift clause they have with Civil Service Sports Council Ltd.
I believe it is this legal agreement that is responsible for the maximisation of housing on the site rather than what one would expect in open discussion with the council and community on a development brief that would benefit all. Some degree of housing whilst retaining the main sports field for sport and recreation, would benefit everyone.
C. Alternative sport provision:
It may be that the land has not been used for sport for more than five years, but that is because of a deliberate policy by the landowners to close the ground for sporting activities.
I am disappointed that Sport England have changed their objection to the development. I don’t think a cash gift from Redrow of £2m to the city council to be spent elsewhere in Gloucester on sports provision adequately compensates for the loss of the playing fields that are in the heart of Kingsholm.
The applicant has been unable to identify alternative provision elsewhere in Kingsholm & Wotton and therefore some sports provision should be retained on site. Spartans Rugby Club that is based in Sherborne Street would support the provision here for an additional rugby pitch for the club to use.
D. Joint Core Strategy INF3
The proposed development of 100 dwellings in my opinion is not consistent with JCS policy on green infrastructure. The former Civil Service Sport Ground provides a worthy green infrastructure asset that should be protected to help resolve the shortage of open space in Kingsholm and Wotton.
I believe it is not beyond the wit of Redrow Homes to come up with a development solution that would provide much needed housing whilst retaining a large open space that could continue to be used for sport and recreation.
The impact on the biodiversity from the wholesale building on the site will be negative. Two badger sets as indicated in the report will disappear if the development proceeds. Trees will be felled. The report also states that the development will create the loss of a foraging area for bats.
The proposed tiny public open space is tucked away in the corner of the site giving the impression that it is an exclusive space for residents of the estate rather than one that is inclusive for everyone living in Kingsholm to use. A large percentage of the public open space is set out as a flood attenuation basin, making the space practicably unusable for recreational purposes.
Here is Policy INF3
- The green infrastructure network of local and strategic importance will be conserved and enhanced, in order to deliver a series of multifunctional, linked green corridors across the JCS area by:
i. Improving the quantity and/or quality of assets;
ii. Improving linkages between assets in a manner appropriate to the scale of development, and
iii. Designing improvements in a way that supports the cohesive management of green
- Development proposals should consider and contribute positively towards green infrastructure, including the wider landscape context and strategic corridors between major assets and populations. Where new residential development will create, or add to, a need for publicly accessible green space or outdoor space for sports and recreational on, this will be fully met in accordance with Policy INF4. Development at Strategic Allocations will be required to deliver connectivity through the site, linking urban areas with the wider rural hinterland
- Existing green infrastructure will be protected in a manner that reflects its contribution
to ecosystem services (including biodiversity, landscape/townscape quality, the historic environment, public access, recreation and play) and the connectivity of the green infrastructure network. Development proposals that will have an impact on woodlands, hedges and trees will need to include a justification for why this impact cannot be avoided and should incorporate measures acceptable to the Local Planning Authority to mitigate the loss. Mitigation should be provided on-site or, where this is not possible, in the immediate environs of the site
- Where assets are created, retained or replaced within a scheme, they should be properly integrated into the design and contribute to local character and distinctiveness. Proposals should also make provisions for future maintenance of green infrastructure.
E. Joint Core Strategy INF4
The lack of serious community engagement by Redrow ahead of this planning application, about the future use of the site, is lamentable. They locked the gates and closed down the sporting use, even though it was a well used facility.
Redrow have only presented plans that have proposed the complete building on the site, with the total loss of the playing fields. They have never properly consulted with anyone who lives in Kingsholm.
The proposal for provide £148,784.31 towards the Sebert Street Recreation Ground play area has NOT been discussed with the community. This is currently one of the best play areas in the city that was created by the parents of Kingsholm Kids at Play. I am concerned about possible overdevelopment of the Sebert Street Recreational Ground as proposed in the officer’s report. What about Deans Way Meadow? Why is there no onsite provision?
There is no clarity in the officer recommendations on what the Section 106 financial agreement will be and what positive impact these will have on the local community.
I believe Redrow have failed to meet the requirement of Joint Core Strategy policy INF4 for social and community infrastructure
Here is Policy INF4
- Proposals to develop land or buildings currently or previously in use as a community facility will demonstrate, including evidence of engagement with relevant local community groups and partner organisations, why the facility is no longer required and, as appropriate, how, when and where suitable local replacement facilities will be provided. Provision of replacement facilities will have regard to the locational and other relevant elements of this policy
- Where new residential development will create, or add to, a need for community facilities, it will be fully met as on-site provision and/or as a contribution to facilities or services onsite. New or refurbished provision will be of an appropriate type, standard and size. From an early stage, developers will be expected to engage with the relevant local authorities and infrastructure providers and, as appropriate, relevant local community groups where they exist, to ensure that new provision meets the needs of the community that it will serve and is t for purpose
- Social and community infrastructure should be centrally located to the population it serves and
be easily accessible on foot and by bicycle. It should be located so as to have the potential to be well-served by public transport. Developers should aim to provide flexible, multifunctional facilities within mixed-use developments, creating shared space which maximises benefits to the community and minimises land-take. In the case of open space, ‘easily accessible’ means it is located within reasonable walking distance of the development it serves. New facilities should be accessible to all members of the community, and be planned and phased in parallel with new development.
F. Joint Core Strategy INF6
This development, as did the one for 89 houses, fails to meet the requirement of this policy. The site will increase carbon emissions rather than reduce them with large increase of vehicles into the area around Denmark Road. It will reduce the opportunity to improve the health of local people in the area by reducing the local opportunity for sport and recreation for residents of Kingsholm.
Kingsholm Primary School, which is a vibrant and popular school has expressed concern about their ability to cope with the additional children going to the school and the possible detriment to children from traveller families, who may no longer be able to get it.
Here is Policy INF6
- Where infrastructure requirements are generated as a result of individual site proposals and / or having regard to cumulative impact, new development will be served and supported by adequate and appropriate on- and / or off-site infrastructure and services. In identifying infrastructure requirements, development proposals will also demonstrate that full regard has been given, where appropriate, to implementing the requirements of the Joint Core Strategy Infrastructure Delivery Plan
- Where need for additional infrastructure and services and / or impacts on existing infrastructure and services is expected to arise, the Local Planning Authority will seek to secure appropriate infrastructure which is necessary, directly related, and fairly and reasonably related to the scale and kind of the development proposal, including:
- Broadband infrastructure
- Climate change mitigation/adaptation;
- Community and cultural facilities and initiatives;
- Early Years and Education;
- Health and well-being facilities and sport, recreation and leisure facilities;
- The highway network, traffic management, sustainable transport and disabled people’s access;
- Protection of cultural and heritage assets and the potential for their enhancement;
- Protection of environmental assets and the potential for their enhancement;
- Provision of Green Infrastructure including open space;
- Public realm;
- Safety and security including emergency services.
3. Priority for provision will be assessed both on a site-by-site basis and having regard to the mitigation of cumulative impact, together with implementation of the JCS Infrastructure Delivery Plan
4. Planning permission will be granted only where sufficient provision has been made for infrastructure and services (together with their continued maintenance) to meet the needs of new development and / or which are required to mitigate the impact of new development upon existing communities. Infrastructure and services must be provided in line with an agreed, phased timescale and in accordance with other requirements of this Plan.
G. Draft City Plan Policy SA06
The provision of 100 dwellings is in my opinion is overdevelopment of the site, which is in the heart of Kingsholm. Council policy as identified in the draft City Plan, which was approved by council in December 2016, recommends a maximum of 20 dwellings (SA06).
The proposal of 100 dwellings exceeds this policy by 500%, with the complete loss of the playing fields.
A compromise of 40 dwellings, for example, on this site would mean that the former sports field could be brought back into use
H. Layout of the site:
The layout of the site does not follow the usual street pattern that is evident in Kingsholm. It is adjacent to both the Kingsholm and Denmark Road conservation areas.
I am concerned that the narrow streets on estate may become clogged up with motorists parking their cars on footpaths. This is a problem that will be exacerbated during times when there are rugby matches being played at the Kingsholm stadium.
If 89 houses was an overdevelopment of the site as mentioned in the minutes of the December meeting then surely 100 houses is more so. There is still concern about the closeness of houses next to Bijou Court. There are a few areas where the relationships are below 21 metres separation, a concern raised by the planning officer.
I. Highway access:
The proposed access onto Denmark Road is unacceptable. It closes the slip road to Lansdown Road and removes much-needed parking spaces on Denmark Road.
The closure of the slip road will create more vehicle conflict at the other junction with Lansdown Road. This will be a particular problem when school coaches use this junction. Parents often park illegally on double yellow lines at this point. The problem will become much worse.
The closure of the slip road will also remove the U-turn provision it provides for the houses serviced off the dual carriageway section of Denmark Road on the south side.
J. Public open space:
Kingsholm & Wotton has a low level of public open space as identified in the city council’s open spaces strategy. The officer report confirms this to be the case. The council’s public open space standard is 2.8ha per 1000 population.
Based on the new ward boundaries introduced at the 2016 election the ward has just 0.49ha per 1,000 population. Or 3.59ha for a population based on mid 2016 of 7,259 persons.
An opportunity is being missed in the proposed development to achieve a good increase in public open space provision in the ward because of the wholesale development of the site.