Forest of Dean’s Strategic Options Consultation  

In 2021 Highnam Parish Council (HPC) joined with five other Parish Councils in strongly objecting to the FoDDC’s then Local Plan Consultation. This proposed the establishment of a 6,000-house new settlement straddling the Highnam and Churcham Parish boundaries with about 2,000 houses being accommodated in Highnam, the balance in Churcham. After further consideration this proposal was dropped.

Whilst the current consultation exercise does not specifically propose the allocation of additional houses in Highnam, indeed  the FoDDC  has no power to do so as the village lies  outside the district boundary, the prospect of a significant new settlement on its immediate doorstep , coupled with the possibility that Tewkesbury Borough Council might consider this initiative provides an opportunity to accommodate some of its additional housing requirements in this location to create an even larger new settlement , is  a matter of significant concern.

On 3 September representatives from Churcham, Huntley, Westbury, Minsterworth and Highnam Parish Councils met to discuss whether, once again, to make a composite response. It was unanimously agreed to do so. At its meeting on 16 September Highnam Parish Council unanimously resolved to join with the other five Parish Councils in opposing the concept of a new settlement in this location. What follows is a composite response endorsed by all six Councils.

Outline Summary:

The Forest of Dean District Council (FODC) declared a climate emergency in 2020 and wished to become carbon neutral by 2030.  The options consultation makes claims to respond to wider Government commitments to have zero emissions by the middle of the century. However, the proposal to abandon the existing strategy of distributing development according to the existing settlement hierarchy in favour of a new settlement on green field land at Churcham and elsewhere is totally counter to this ambition.

The preferred option fails to create a plan to enhance the economy of the Forest of Dean and grow small businesses in the right place to best serve the local economy and to create and sustain vibrant communities. It fails to protect the environment and in the case of flooding presents a real threat to not only existing households in affected areas but to the economy of the wider Forest area through increased risk of large-scale flooding and being cut off.

The preferred option simply creates a developer’s charter where emphasis is focused solely on meeting government housing targets, and its strategy will simply create an out of character commuter estate for Gloucester City and fails to meet the housing needs of the local population including affordable housing in the right places, so they are easily accessible where generations wish to remain and live in proximity. The plan is predicated on unsustainable car travel and fails to protect and enhance the natural environment.

It would be more honest if the FODC stated: “Our strategy right from 2019 has been to dump as much of our housing allocation as we possibly can at a location that will be serviced by the neighbouring City of Gloucester. In this way we get rid of it and we care not about the sustainability or the impact on the growth and prosperity of the rest of the Forest of Dean”.

For this reason, we strongly reject the preferred options and urge the FODDC to abandon this strategy and adopt one that respects and is in line with the existing settlement hierarchy and serves the needs of the whole Forest of Dean.

Introduction

In this response we have tried to take a high-level view and not try to pick the preferred options consultation apart with respect to the 4 tests of sustainability and the NPPF since we anticipate other consultees will have issued a comprehensive response in this regard. Instead, we are focusing on common sense issues.

As a general comment the preferred options document lacks any detail or evidence to back up the assertions stated, we also found some of the statements contradictory, so it was difficult to deduce what was the exact line of thinking or strategy we were being asked to comment on.

Future Vision

The Forest of Dean is a unique environment that has the potential to be prosperous and a great place to live. It has the combination of historic towns and villages that are surrounded by nature and a diverse natural environment.

Several shifts were happening before Covid 19 impacted the country, as it was the case that the growth in employment is being driven by small and medium sized enterprises many of these in the technology sector. These companies attract high skilled employees, and they are finding that by being in more rural areas where they are not only nice places to work but also promote a healthier fulfilling lifestyle, they are able to recruit more easily those high skilled professionals. Smaller employment sites appealing to technology or other knowledge-based companies located across the Forest is a strategy that will help promote internal investment.

Another shift however is that such professionals are looking to live in towns and villages that have an established community and historical sense of place with a public house, local shops and a mix of house types from all periods in history.

Housing and employment planning that fosters this small-scale development in established communities together with employment facilities that are easily accessible locally is a pattern that can a protect and enhance the environment, can grow small and medium sized businesses and meet the housing needs of the local population through affordable and accessible housing is eminently sustainable.

The preferred option of creating a mega mono-culture commuter estate for Gloucester has none of these attributes and should be abandoned immediately.

Q1- Do you have any comments or views on the proposed plan period for the new Local Plan? (Please set out below with evidence or justification to support your comments) Should the plan look forward to the year 2043? (If not what year and what is your reasoning?)

The plan should not look forward beyond the planned programme period of 2041 to 2043 since this adds a further 1200 houses to the target figure. We believe the level of growth dictated by an 82% uplift is not a realistic figure since by no stretch of the imagination does this reflect the actual housing need within the Forest of Dean.

Q2- Does the need for sustainable development mean trying to locate new development where there are existing services or where new services can be provided?

It is a well-known that Forest of Dean towns lack inward investment and critical mass to sustain high street shops and to attract potential employers to its towns. Recent Gloucester County Council insights report details that the Forest of Dean has a higher level of deprivation than the rest of the County with areas in Cinderford and parts of Lydney being among the most deprived with significant households affected by multiple deprivation. Sustainable development should mean improving the lives of those in existing deprivation and this can only be done by expanding existing facilities to make them better, fit for purpose and viable moving forward. This will only happen if new development is located with existing services.

The preferred option of proposing a new settlement on the periphery of the Forest of Dean, again is puzzling since this is a terrible option for sustainability. The proximity of Gloucester to the location of the new settlement means that it effectively becomes a commuter estate of Gloucester and will serve only Gloucester and regions to the east. It has long been known that a very high proportion of the eastern residents of the Forest of Dean work in the Gloucester-Cheltenham region or use motorway access at Junction 11 or 11a.

This reality has meant the A40 at Over Farm is one of the County’s most congested roads, and the geography and rivers constrain traffic which means at peak times traffic is regularly backed up on the A40 and A48 for several kilometres. This congestion can occur at any time of the day because the roads are already over capacity meaning any minor event can cause huge tailbacks. This situation makes it impossible to plan arrival times and impacts the area in other ways covered in the economic impact section.

Adding to this congestion by building a new settlement of 2,000- 3,000 houses resulting in thousands of new journeys at the most congested part of the road network makes no sense whatever since it will only compound a problem that already exists.

The provision of improved public transport whilst good in theory does not solve the problem because these jobs are dispersed over a wide area so public transport is not a realistic option since a traveller would typically have to catch 2 or 3 buses to get where they need to go. All public transport links terminate in Gloucester city centre where you would have to catch other buses if the location you want to go is not the city centre

Economic Impact 

Closely associated with sustainability issues we were disappointed that the preferred option effectively ignores the needs and future prosperity of the Forest of Dean. This preferred option robs the Forest of Dean of inward investment and does nothing to create vibrant communities and sustainable jobs in the wider Forest since it simply concedes that all the jobs and future economic growth will be in the Gloucester, Cheltenham, Tewkesbury area, and the Forest will just become a commuter belt for Gloucester and beyond.

This is a shameful dereliction of duty by the FODDC. Its primary focus should be creating prosperity across the entire region, for the benefit of the entire region. A great many areas within the Forest of Dean especially in the centre have high levels of deprivation, the preferred option of focusing on a new settlement on the periphery of the region means that there is no driver or incentive to create jobs and accessible quality homes near the most deprived areas.

Similarly, the impact of a new settlement on the already congested A40 and A48 at one of its critical pinch points will deter companies from locating in the Forest of Dean because of the impact of hour-long traffic jams on logistics and other required movements will simply make the area unviable for attracting externally funded inward investment.

It is being promoted that the new settlement will be ‘self-contained’ in that houses, employment and shopping and other essential infrastructure will be co-located and will not result in a wave of commuting to employment sites further afield. This is clearly implausible, owing to the amount of land needed to create in the order of 3,000 jobs would be enormous and would need to accommodate a wide range of professions. Similarly, the proximity to a new settlement of extensive supermarket and shopping facilities in Gloucester will be an obvious draw which means shopping facilities further into the Forest that are already struggling to be viable miss out and are more likely to close which further impacts existing communities who don’t have the proximity to Gloucester.

Q3- Section 9 includes reference to basic constraints to development for example flooding. Would you agree or wish to add or remove any of them? Please add comments to support your changes.

What would we add – known flood areas, populated areas that are outside the flood zone but due to geographic features and geology would be flood impacted by any nearby development due to the loss of water retentive land that would naturally absorb this water runoff. Access for emergency response, food security – productive farmland, geological features that increase flood risk, air pollution.

Q4 – The document is accompanied by the Sustainability Appraisal ‘Further Interim Report for the Local Plan Options to Deliver the Additional Housing Requirement’ which is cross-referenced in Sections 10 and 11. Do you agree with the Sustainability Appraisal methodology and the outcomes for each of the Options? If not, please give your reasons why’

No – there are a lot of assertions made in the methodology with no supporting evidence, therefore its conjecture.

As an example on point 8 (To maintain and improve air quality) Options 2&3 marked as red state:  ‘Development and traffic generation causes air quality issues through increased traffic congestion. Less potential to select sites with improved opportunities to travel by public transport’.

Option 4 marked as neutral states: ‘Development and traffic generation causes air quality issues through increased traffic congestion. However, opportunities through master planning to create opportunities to travel by public transport.

Where is the evidence to make this assertion? It is equally valid that the combined traffic of a new settlement will cause much greater and concentrated congestion on feeder roads which will have a greater impact on air quality since it is concentrated. The scale of any new settlement would require substantial public transport which unless figures are provided as to the scale then the statements made in the table are purely and assertion so is not a valid methodology.

Q5 – The main settlements listed above have some major constraints as well as opportunities. Do you agree with these or are there some opportunities that need to be explored further, or some constraints that have not been included?

Given the pressure placed on the Forest of Dean by the 82% uplift in housing the policy surrounding restricting growth at Coleford makes no sense since it is a very sustainable location and does not appear to be impacted by flooding and is well connected to other towns and major villages. The consultation document states a number of constraints together with the

Bream is equally sustainable given its current size, the constraints listed in the consultation document land to South and West of Bream would appear to be developable.

Given Mitcheldean’s status of a major employment hub it has always felt like a town that failed to develop properly and sustain a vibrant centre

Q6- Which option or options (described in Section 10) would you support (please say why and please do suggest general or specific locations that should be considered for new development)?

We would support options 1 and 2 –

Q7- Do you have any further comments on the range of options or suggestions of alternative options?  It may be helpful to consider the following:  Are there any particular difficulties with some?  Which may be the most sustainable?  How may they be implemented?  Which general locations may be best suited to further development?

Given that the consultation option for a new settlement references land located in Churcham as a possible location it is important to point out as has been pointed out in previous responses to the local plan consultations the area is notorious for serious flooding and much lies in a category 3 flood zone.

The east of the Forest of Dean from Highnam roundabout, Birdwood on the A40 and from Highnam to approximately Chaxhill on the A48 is low lying, close to the River Severn and regularly floods. These flood events are becoming more regular and severe, in line with scientific predictions on global warming.

In February 2020 both the A40 and the A48 were cut off due to serious flooding. From Over Farm to Birdwood and from Highnam roundabout to approximately where the Severn Bore Public house is located was under several feet of water and was impassable to traffic, as were all the secondary roads because of the area flooding. This event not only flooded all roads and surrounding farmland it completely cut off the Forest of Dean eastwards to Gloucester. Just 10 months later in December 2020 a repeat flooding event in Churcham forced the Police to close the road from Over Farm to Huntley.

Another factor that compounds the flooding problem is the ground in the region is composed of a dense clay ‘Marl’ that water cannot permeate through easily thus making the area particularly prone to flash flooding.

Climate scientists are predicting increased precipitation as a consequence of global warming and in the most comprehensive international NTU study in May 2020 Sea levels are predicted to rise by one metre by the end of the century. Much of Churcham and Minsterworth serve as a flood plain for the river and its tributaries, a rise of this magnitude in sea level will mean existing flood plains will increase in size and the increased precipitation, as we are starting to see now, will flood the area on a regular basis, as typified in 2020. It was also the case that much of what flooded in 2020 was outside the designated Category 3 flood zone.

Simply if you drop a brick into a bowl of water the water will be displaced. Given the area is already flooding and many houses in the region are at risk of flooding. Any new settlement will obviously displace water making flooding events more severe and water run-off making flash flooding more severe also.

We hope you can see why we are puzzled with the location suggested. It is more the case that FODC should be focused on trying to protect the existing region and the residents from flooding and devising evacuation plans to cope with the events that will be a near certainty in the future, certainly not suggesting building a new settlement. The geography, geology and flooding events have meant that there are no concentrated developments east of Huntley and this is for a reason.

Q8- Do you feel the ‘most sustainable combination of options’ (a combination of Option 1 and Option 4 set out in Section 11) is an appropriate approach, are there any changes that you could suggest? 

No   Q9- Are there any further comments you wish to make about the strategy that have not been covered by other questions

No

Q10- The questions posed in this document may be used as a basis for responses. However, the purpose of this consultation is to obtain a wide range of responses covering any subject that is relevant to the new Local Plan strategy. If you have any additional points you wish to raise, please do so. There will be further opportunities for comments on a revised Draft Local Plan however if you have any additional points or suggestions you wish to raise now, please do so. 

Response by Highnam Parish Council

It is recommended that HPC continues to work with the other four Parish Councils in completing this response, making a composite submission to this consultation exercise.

  Chair: HPC 11.9.25