Regulation 18 Issues and Options Consultation: Spatial options and key policy areas

Ideally to get to the net zero carbon emission you quote in para 4.5 that will have the required impact before the 2045 deadline the councils will have to address all the existing residential housing stock to keep the UK within the Paris Agreement. What are the plans to convert existing housing stock to carbon net zero. New build is easier to deliver net zero but how do you propose to achieve this? What means of clean energy production are you proposing? more wind turbines, ground source heat pumps, solar? or another incinerator slap bang in the middle of the cotswolds with some CHP piping delivering energy from burning all the trees that the council have chopped down?

What are you planning to introduce as "zero and low carbon development"? what is "biodiversity net gain" in your mind?

New Development must be on brownfield sites.

In and around Gloucester there has been a tremendous amount of development to the south and North regions.

I notice that the area above the balancing ponds A417 called Tinkers Hill for some reason ? should this not be called Chosen Hill which is primarily arible farm land is identified as developable- can you explain why this is being identified for housing? MUST BE GREEN BELT and also land behind Elmbridge Court. Is this why Tewkesbury want to land grab Elmbridge? So it can build on this land against the wishes of Gloucester- Richard Graham needs to get his act together and stop Elmbridge falling into the clutches of the enemy.

the draft vision is a lot of buzz words based upon suppositions:
3.3.a) "climate change" - will not be helped by converting green field sites into concrete housing and roads. The council's prior record of hacking down mature broad leaf trees shows that this is just a few words to be "in vogue" with political rhetoric. A quote from an Eco website "A typical tree can absorb around 21 kilograms of carbon dioxide (CO2) per year, however this figure is only achieved when the tree is fully grown - saplings will absorb significantly less than this. Over a lifetime of 100 years, one tree could absorb around a tonne of CO2. While this seems like a significant amount, humans are creating about 40 billions tonnes of CO2 each year, meaning that we’d need to plant 40 billion trees annually to offset the emissions created. Even if this were possible, land space would be significantly reduced". MORE MATURE TREES!
3.3.b) nature recovery, what will you do here build a local zoo and rubber stamp the paper-Whitehall complied?
3.3 d) Lets build a shed load of houses around Gloucester say Tewkesbury and the County Councillor's sat up in their Ivory Towers in the Cotswolds. What about the roads of Gloucester and the traffic jams as a result of this poor planning- wont bother Nimby Tewkesbury.
3.3 f) right size of homes, hah will you be building starter homes , nah maximise profit for the developer 4 beds are best- hard luck first home seekers. you need to address affordable housing, brownfield sites and build apartments-too bad if it costs more to prepare the site. this must be exhasted before any green field building takes place.
3.3 g) community facilities need to be built to support.....only this week i learn of the closure of Walls sport and social club. has this land been identified as "developable"? sort of saying one thing and then doing another.
3.3. j) Rapid transport routes, like motorways clogged up with lorries, artics and white van people. lets halve the width of the busy road and build a great big cycle path that could be use to land a plane on- yeh that makes sense, oh but its ticking all the boxes in whitehall.
3.5 green growth is that the stuff that grows on the north side of concrete?
what about Gloucester City centre as its an old town like the old mature trees, there is no place for it in your plans for the future?
Gloucester and Tewkesbury have sufficient traveller locations Cheltenham has none, so I suggest levelling up 20 more in Cheltenham.
Ideally I would like this plan scrapped, Gloucester's stolen land by Tewkesbury returned and Gloucester to go it alone on its future course. I dont see it should be decided by Tewks or Chelt council's

Central Gloucester for example seems to be enveloped by the Tewkesbury Borough Council boundary to the North, West and East and has to accept decisions that are made by a remote council and that are not in our best interest. This is an example of Councillors moving borders over time to benefit votes at the election Gloucester boundaries to the North should be encompassing Longlevens, (Elmbridge nearly gone) Innsworth and Churchdown and Brockworth. So Tewkesbury a relatively small settlement with a small town dictates what goes in near Gloucester city. True Tewkesbury is starting to grow as it should, what was mainly farming community 40 years ago. Why is this happening, I can only assume it is to swallow up Gloucester's land so it does not have to build in its own back yard. The tories should be standing up for Gloucester not lying back and letting Tewkesbury dictate. I say the boundary commission needs to be disbanded immediately to save taxpayers money, seem like a bunch of idiots to me. Perhaps Gloucester should remove itself from this SLP joint review and work on kicking the boundary commission to touch. HANDS OFF GLOUCESTER

After reading this review, which to be honest is likened to something a year 8/9 student would produce, there are lots of statements or quotes and not one of these has been referenced or linked to an published or factual document. You state 35,700 homes need to be built over the next 20 years, where has this information been taken from? I am sure that locals born & bred in Glos, Chelt & Tewks will not need housing at that rate, so I can only assume you are destroying greenbelt land, green field sites and natural habitats 1) to develop and satisfy the need to accomodate rich people from London etc. who find they can now work from home a lot cheaper in Gloucester. 2) To satisfy 2nd home owners and buy to let landlords 3) To house all the illegal immigrants and migrants that tory BREXIT policy has failed to stop 4) To keep the construction trade at work & massage the unemployment figures. "we have forecast 23,000 families will need to move to the area" where does this quote originate from, or is it a guess? Gloucester was once a big "local" employer at Dowty Rotol, Smiths, W&J, Lucas Bryce, Dowty for eg had around 25 buses from outlying areas that workers used. It can only be said that the demise of these huge companies was brought about by government policy /lack of support when it was most needed to compete with foreign subsidised competition, and engineering reforms. The transport infrastructure you talk of in this document existed in the 1960 & 70's. We had more rail tracks a lot of which has now been built on. Norman Tebbit said "get on your bike" to address the unemployment problems the Tories had created and so many people took to the car to commute to outlying Counties. I speak from experience, that as self employed consultant a commute to a location as far as 80 miles is now not unusual (a 160 mile round trip). Lorries and Artic trucks clog our roadways, why? This should all be transported by rail- ah but the tracks have been taken up and buit on! Have you actually undertaken a study on where Gloucestrians actually work for example, you may be surprised that many work in London, Swindon, Bristol, Wales etc. That suggests that too many houses not enough work to me. If you actually tried to get a freight policy together it may just help before you kneejerk into turning the area into concrete. Take freight off the roads onto train and canal, use local airports (again you are doing your very best to get the airport closed at Staverton by withdrawing funding and hoping to sell it at a profit for development land). With freight off the motorways for example it should be possible to build a rail line using the redundant but existing fast lane to connect major cities by rail while using the existing rail network for commuters. This SLP is not a discussion with the public it is "this is what we are going to do"

15 years is reasonable.
Since this SLP review was cobbled up last year and then thrust in front of an unaware audience, I can only assume you did not want any of us to comment. I have to say this was very poorly publicised the first I knew of this was by a chance person talking of it on social media. Looking at the attendance on you open day events in Gloucester Chelt & Tewkesbury where only one or two people turn up suggests this is a fact. (these may have been local govt employees) This was not properly circulated to the electorate and I suggest that the closure date for review is postponed until the end of April, so that we all get a chance to review this. I have already complained to MP Richard Graham. You need to revise the way you consult with the public.

Within the three areas covered by this strategic plan we do not seem to have much in the way of renewable energy generation or storage. Maybe some of the large fields around Tewkesbury and between Cheltenham and Gloucester could be used for building solar panels, and some of the higher parts of the area such as Cleeve Hill could have wind turbines built on them (I am guessing that Robinswood and Churchdown Hill would be too small due to the nature of their landscape and the risk of birds being injured)

I would like to see incorporated the need to review continuously developments that have been approved to check that they met the goals at the time approval was given. We see small scale developments in Churchdown to which objetions had been made, and now the properties have been built they do not fit with the surrounding properties and are not selling. We should learn from past mistakes

Hi Team, whilst we must accept that there is a need for housing within the Gloucester, Tewkesbury & Cheltenham triangle we must continue to preserve the Green Belt area so that each town/city preserves it's own integrity and identity. Whilst there is, without doubt, small pockets of land within the hamlets in the green belt that could sustain small numbers of new build housing, if we allow a 4000 house new town in Boddington, it would effectively create an urban sprawl similar to Bristol by joining all 3 Towns together. Is this the grand plan or is the suggested Boddington scenario simply commercially driven because of the 1,200 acre ownership by a major developer currently being farmed as Boddington Estates? There are already plans to build 1,300 houses between Hayden and Springbank across towards GCHQ which is all on greenfield sites of which 800 or so fall within the Boddington Parish boundary but still retains the green belt buffer. We should treasure rural areas like Boddington and ensure that we preserve for our future generations to enjoy both as residents and as visitors.

Hi Team, whilst we must accept that there is a need for housing within the Gloucester, Tewkesbury & Cheltenham triangle we must continue to preserve the Green Belt area so that each town/city preserves it's own integrity and identity.
Whilst there is, without doubt, small pockets of land within the hamlets in the green belt that could sustain small numbers of new build housing, if we allow a 4000 house new town in Boddington, it would effectively create an urban sprawl similar to Bristol by joining all 3 Towns together.
Is this the grand plan or is the suggested Boddington scenario simply commercially driven because of the 1,200 acre ownership by a major developer currently being farmed as Boddington Estates?
There are already plans to build 1,300 houses between Hayden and Springbank across towards GCHQ which is all on greenfield sites of which 800 or so fall within the Boddington Parish boundary but still retains the green belt buffer.
We should treasure rural areas like Boddington and ensure that we preserve for our future generations to enjoy both as residents and as visitors.

Pro's and con's for green space, GI and biodiversity look a bit slim.

Option 6 - yes I think this option has legs.

Option 3 - worse! Green belt is a 'strategic' designation to prevent town/cities from merging. I don't think that is still a valid argument, with the amount of housing we need. Also development between Cheltenham and Gloucester could be quite sustainable, re transport.

Option 2 - I don't support the extensions around Tewkesbury. Avoiding the watercourses and floodplains is leading to a development pattern a bit like spokes on a wheel. The new development is too far away from the town centre and shouldn't count as a sustainable urban extension. I expect the same is true for Cheltenham and Gloucester.

Option 1 - support, but need to ensure not building on greenspace.

The layout of the questions means a lot of scrolling up and down to remind what the options are - bit of a mare!

Shops. Schools.

All infrastructure! They should be self sufficient as far as is possible. 15 minute neighbourhoods. However linking into their surrounds.

Green infrastructure and self-propelled modes of transport ie walking and cycling.

There could be a case for more town centre housing. Residents to support the very local economy in the town centres, including night time economy.

Sustainability around social and environmental limits needs to be a key consideration in reaching the right figure. Not after the number has been decided.

No, because would not want to stifle schemes coming forward in other locations. New development should be required to wash its own face, and deliver wider community benefit. How it does that it up to the developer.

Schools and green spaces.

Carrant Brook should be a priority green corridor. Delivery of BNG to increase it's value for wildlife, including birds such as curlew and others coming up from the Severn Estuary SPA. Natural flood risk management should be delivered here, including the creation of wetland areas. The proposed developments at Mitton and in the area formally known as the Garden Town will put pressure on the brook and should be required to deliver this green corridor. It should be whoppingly big, to actually deliver it's function.

Yes. However, I believe DCLG is now saying this needs to be justified. Could the need for natural flood management be part of the justification? Certainly larger developments should do more than 10%, 10% is pretty paltry and we're talking about a plan in place for many years. Well until the next review!

By requiring new development to be carbon neutral, promoting district level renewable energy and heating, and then rolling out retrofitting in existing housing stock. E.g. new development generating district level renewable energy is then required to hook up existing built environment to their system. E.g. better grants to retrofit. This would be innovative and requires proper join up between planning and other arms in the council.

I would like to see an objective around design to allow children (of all ages) to play. 85% of UK children are not getting enough exercise. Children become less active with each year of primary school. And girls do less than boys. This is going to be a physical and mental health epidemic within this plan period - if it is not already.

Would be good to see something like this - A catchment approach will be taken to flood risk management. Natural flood management will be a priority, with urban watercourses greened and buffers promoted along rural watercourses. Features such as permeable paving and raingardens will be commonplace in urban areas, there will be more tree cover, and wetlands areas will be expanded. The delivery of multifunctional benefits for people and nature will be prioritised, with watercourses at the heart of a green infrastructure network.

It's an ok vision but it is the same really as every other Local Plan vision. It could be about anywhere.

Sports facilities, flood management and biodiversity have been lumped together. Feels like a bit of a strange combination. In my opinion it would be better to unpick that paragraph.

2.4 d covers the conservation and enhancement of the natural environment but does not specifically mention biodiversity. Nature recovery should be covered as a strategic issue.

As a resident of Up Hatherley, I have a particular interest in the inclusion of land south of Up Hatherley Way and land at Oak Farm, Chargrove Lane, in the SLP. I wish to comment in relation to the Draft Strategic Objective “Promoting Healthy & Resilient Communities”
Chargrove Lane is much valued locally as a quiet country lane for taking exercise. There are pleasant views, little traffic, high biodiversity and the lane has an unspoilt feel about it. This is rare, so close to Cheltenham. As a Health Walk Leader, I lead a weekly Health Walk of 30 to 40 people, often along Chargrove Lane and across the adjacent fields. You acknowledge the value of access to nature and green spaces and indeed my walkers really look forward to, and appreciate the benefit of, these excursions. We used to explore the fields which have now disappeared under the Brizen Park development and I sincerely hope we will not be deprived of another local area so conducive to the well-being of so many Cheltenham residents.

I would strongly suggest two areas from the Tewkesbury Borough CouncilHELAA Map:
SHUR029
Site_Location Land south of Up Hatherley Way GL51 3YF
Capacity 1793
Housing - Overall Assessment Potentially developable

SHUR025
Site_Location Land at Oak Farm, Chargrove Lane, Cheltenham, GL51 4XB
Capacity 417
Housing - Overall Assessment Potentially developable

AND SURROUNDING LAND CURRENTLY IN THE GREENBELT

WILDLIFE / BIODIVERSITY NET GAIN
These areas already include an orchard with trees protected by TPO, visited by tawny owls and bats which need a green habitat preserving around them to stay viable. The land supports large mammals (foxes and roe deer). It is a hunting ground for large predatory birds: buzzards and red kites. It is visited by lapwings – a ‘Red List’ species which needs every support. I have seen a kingfisher on the stream which runs through the small Nature reserve. There are varied species of butterflies e.g. Marbled White on wildflowers in rough grass, Gatekeepers on brambles. Violets and periwinkles are currently growing by the roadside. There are magnificent mature oak trees, each supporting hundreds of species – and in very urgent need of TPO protection. A remarkable amount is surviving within conventional farming. With some nature-focused management – e.g. wildflower plantings on headlands – even more species could be encouraged. This is a rich oasis near dense housing, much appreciated. It should NEVER be considered for housing and the Councils should work to see how it can be made even more wildlife friendly.

RECREATION
These areas are used by hundreds of people of all ages for recreation: cycling, walking, dog-walking, running. People who prefer or need a hard surface to walk can use Chargrove Lane to enjoy views of the countryside, trees, deer and birds. There is also an extensive and very well-used network of public footpaths across this area. These allow the public to observe nature at close quarters -e.g. the many imposing oaks. They are also a link to the area’s history. Up Hatherley people for centuries walked to Shurdington Church. Vitally, hundreds of people can reach this area ON FOOT, which is healthy and reduces pollution. The local beauty spots such as Cooper’s Hill and Crickley Hill are excellent – but they cannot be reached via public transport by people who live near Chargrove Lane and Up Hatherley Way. Since the pandemic, there has been much public comment on problems with mental health, and the need to engage with nature. Doctors now prescribe walking, and there is at least one regular publicly organised walking group. These areas are an ideal resource for healthy recreation and wildlife watching – and should be permanently protected from development.

FLOOD RISK MITIGATION

This land is needed to absorb local rainfall. Covering even part of it with hard surfaces would displace floodwater elsewhere. Quite simply, it is very, very wet land, especially around Brickhouse Farm. The document

GREENBELT FEB 2024 Reg18-Dec-HELAA-Spreadsheet-1 (1)

notes ‘surface flooding’. That is extremely obvious at the time of writing! If this land is not used for housing, it can protect local houses from the misery of flooding, and could also be managed as a specialised wildlife habitat. This would enhance both its biodiversity and recreation values!

SUMMARY
The very narrow greenbelt south of Up Hatherley Way in Cheltenham is so heavily used for recreation, rich in biodiversity and liable to flooding that it should remain and be enhanced as greenbelt, however strong the pressures from potential developers. No one can ‘offset’ or ‘recreate’ what is here already! It must not be destroyed.

In general - if we're planning for the future, focusing on transport is the only way to ensure that any of these goals could possibly be met. There is too much reliance on private cars to plug the gap left by missing public infrastructure. Gloucestershire should also be looking to follow Manchester and bring our bus routes into local council management - this could be a money maker for council but also a useful tool in local planning. We must not continue building flood-prone sprawl, we can be better.

Agree. Building standards need to be strengthened, so that living in an apartment complex or row house doesn't feel that you are living on top of each other with paper-thin walls. It's possible for higher density housing to be high quality, we just don't legislate for that.

A combination of 1 and 6 are the best way forward for Gloucestershire. We must concentrate development in existing urban centres, building up rather than out and also build along existing public transport corridors. This might mean new busways, new railway stations alongside existing lines or reopening old railways alongside new development. All other options will either create sprawl or destroy a large amount of our natural environment.

Fully in support of this comment. We absolutely must protect our rail rights of way for the future.

100% provision of rights of way for railways and cycle paths is incredibly important. Even a dedicated bus lane can become a future tram line, if it is protected.

Nearby public transport corridors and their integration into the development. Rural roads will get overloaded with private vehicles if this isn't provisioned for. This may mean we need to reopen old railway lines or provide dedicated busways.

You shouldn't need to own a car if you live in one of these new settlements - in fact, it should be less convenient to use a vehicle in them. As others have said, make it easier to travel from these new settlements to where employment and education actually are in established settlements.

Transport! Dedicated bus and cycle lanes leading to these developments can greatly reduce reliance on private cars. People should feel safe and relaxed while travelling to and from home.

There's a lack of medical facilities and post offices in the more suburban areas of Cheltenham in particular, meaning that people have to drive often to access basic services. We should be rectifying this by working in conjunction with the Post Office and NHS to provide more locations people can access these services on foot from their homes.

There's no point in using buses if they get stuck in the same traffic as everybody else. We need dedicated bus corridors to our town centres to make taking the bus a more attractive option, and dedicated cycle lanes and bike parking to make taking a bike from the suburbs more appealing.

Provision of low cost, small-scale rental units for local businesses which are located along key public transport corridors and cycling routes. This may include subdividing areas within town centres to provide opportunities for more businesses.

Gloucestershire absolutely needs higher density, high rise and high quality housing. We need to be focused on building up rather than outward, and Cheltenham in particular is constrained by the Green Belt. As an example - instead of taking up housing in St Pauls which could be used long term for families, students to the university should be provisioned for with several high density developments along transit corridors. The university should take responsibility for the students it is bringing to the area and contribute towards development that helps both the university and the community it is located within.

Currently we have a shortage of housing in general, and I think we need more than what is calculated and we should be building more, and more densely. If Gloucestershire can position itself as an affordable place to live by bringing down the local cost of housing, workers will follow and drive innovation locally.

With housing it is always safer to overbuild rather than underbuild. I think whatever the Standard Method spits out, we should be building at least 10% more. Affordable housing will be automatically created when demand better matches supply.

Agreed. Beyond large-scale kinetic energy storage (ie hydroelectric dams) battery storage technology is not at a point where we should be devoting space to it which could be used for housing.

Every house in Gloucestershire should be producing energy through solar. We can both house people and produce energy, we don't have to choose one.

Transportation is the most important provision that needs to be considered in new developments. How are all of these people going to get to work / school? If the answer is "cars" or "hourly bus" that's absolutely not acceptable.


If we really want to combat climate change, we need to make it easier and cheaper to take public transport than it is to take a car.

Broadly, I agree with the draft vision and it's encouraging to see there's a particular focus of creating walkable neighbourhoods. However it focuses on new developments - which is great - but doesn't focus on the housing and developments we already have.

The places people will want to visit in the future are more than likely to be the places people visit today - town centres, shopping precincts, parks and recreation spaces. We need to focus on making it easier to access these spaces by improving the neighbourhoods and development on the periphery of these. Removing parking and adding dedicated bus / cycle lanes, blocking off main road access to residential streets, speed bumps to reduce rat runs.

There is no point in creating isolated islands of good development if they don't lead anywhere - people will just use their cars regardless.