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WINCHCOMBE AND SUDELEY NEIGHBOURHOOD PLANCommunity Engagement Statement

Introduction

This document is the consultation statement required under Regulation 15(1)(b) of the Neighbourhood Planning (General) Regulations 2012. It

contains details of the persons and bodies who were consulted about the proposed neighbourhood development plan;

explains how they were consulted; summarises the main issues and concerns raised by the persons consulted;

and describes how these issues and concerns have been considered and, where

relevant, addressed in the proposed neighbourhood development plan.

Section 1 describes how Winchcombe Town Council and the Sudeley Parish Meeting engaged the community in preparing a draft Neighbourhood Development Plan and associated Environmental/Sustainability Statement; and

Section 2 describes, policy by policy, how consultees responded to the formal draft Neighbourhood Plan published in December 2014, and how the Town Council and Sudeley Parish have addressed those responses.

1. Outline of plan preparation and public consultation

Overall process timeline

1. The overall process followed the timeline below: • August 2012: at the annual Country Show postcards were handed out offering

a cash prize for filling the card in with views about Winchcombe’s strengths and weaknesses

• September 2012: postcards subsequently delivered to all Winchcombe and Greet homes

• April 2013: two professionally facilitated brainstorming meetings to which community leaders were invited

• January 2014: the launch of ideas for the Neighbourhood Plan when 1000 people attended and over 250 responded. The display included 16 boards summarising the evidence and asking for people’s views about how to meet them

• March 2014: the Town Council approved a screening document under environmental assessment regulations

• April 2014: draft Sustainability Appraisal initiated• August 2014: post consultation Sustainability Appraisal approved by the

Winchcombe Town Council

• December 2014: Town Council and Sudeley Parish Meeting both approve and launch a draft Neighbourhood Plan and associated Environmental Statement for a public consultation

• January 2015: Town Councillors man a drop-in desk all week in the Winchcombe Town Library

• 13th February 2015: end-date for public consultation• April 2015: opportunity for the public to put questions, at the annual Parish

Meeting• March to August 2015: Steering Group and Town Councillors consider formal

responses to consultation, with regular reports to the Town Council in public session

• September to October 2015: informal consultations with Tewkesbury Borough Council officers leading to drafting changes to ensure that the draft policies are clear and capable of application in practice

• November 2015: Plan proposal approved by the Winchcombe Town Council and Chair of the Sudeley Parish Meeting and submitted to Tewkesbury Borough Council.

Preliminary years (2012-13) 2. The original consultation process was initiated by a Steering Group of town

councillors and community members and involved a stand at the 2012 Winchcombe Summer Flower Show, which launched a postcard consultation (one through every door in Winchcombe and Greet) inviting people to answer three simple questions. A Facebook account was also opened at this point.

3. The postcard questions were:

1. What do you think makes Winchcombe such a great place to be a part of?

2. What opportunities are there to make it even better?3. What challenges do you think Winchcombe will face over the next 20

years, and how should we tackle them?

4. One hundred and nineteen responses were received. A detailed anaylsis of the responses is to be found, along with much other material, on the Winchcombe and Sudeley Neighbourhood Plan website https://winchcombeneighbourhoodplan.wordpress.com, on the Resources page.

5. The Steering Group then organised two meetings in Spring 2013, involving about seventy people, and facilitated by Elin Tattersall of the Gloucestershire Rural Community Council. After those meetings, the Steering Group set up a dedicated website . This website has now received more than 25,000 page views.

6. The transcripts of the meetings and an analysis of the earlier postcard survey

were uploaded to the Neighbourhood Plan website. The work of

Neighbourhood Plan Steering Group has been made public through regular reports at the monthly Town Council meetings (where there is always an opportunity for public participation), and Town Councillors have often report on the meetings on Winchcombe Radio broadcasts. The Neighbourhood Plan process was also explained in Winchcombe Matters - the Town Council’s newspaper circulated free to all households in Winchcombe and Greet - and in an article in Winchcombe Life (a local free glossy magazine then in production).

7. The process leading up to an initial public consultation was made more

difficult and delayed by the need for the Town Council to provide formal advice on planning applications for two major housing schemes (Bloor and Redrow), which proved controversial in the community. The Redrow development was particularly protracted because it involved an appeal to the Secretary of State after the failure of Tewkesbury Borough Council to determine the application; the appeal was allowed despite the Borough’s expert evidence that the landscape impact on the Area of Outstanding Natural Beauty would be severe. There was also public concern about a “major” housing development (ie exceeding 10 homes) permitted - within the designated AONB area - adjacent to a previous development permitted (under the “rural exceptions policy”) only as affordable housing.

8. The next step in the process was an exhibition of 16 panels in an exhibition in

the Pubic Library (previewed at the Community Centre and attracting around 1,000 people). The exhibition was widely publicised through posters around the town and an article in Winchcombe Matters. Coverage was achieved in the Gloucestershire Echo as well as through Winchcombe Radio. Members of the community opposing development on the former Castleways site (where planning permission has now been granted for a Budgens store) also helped to raise awareness of our consultation at that stage.

9. The full report summarising the results of this consultation stage is presented

in three separate documents under the heading “Outcome of Initial Public Consultation” on the Neighbourhood Plan Steering Group website. That site also contains the reports of two consultants’ reports - one benchmarking Winchcombe town centre against other similar places; and another assessing the potential for further convenience shopping facilities (as indicated in the draft Joint Core Strategy).

10. The panels represented a thorough explanation of what a Neighbourhood

Plan could achieve and the processes towards approval. They also went through all the main needs and constraints - economic, social and environmental. The issues put to those attending the exhibition and completing questionnaires included the choice of broad location for housing development, and the types of household we should be providing for. As the Neighbourhood Plan Steering Group were aware of plans from one landowner to develop an upmarket retirement community (which would bring new employment opportunities locally, as well as securing the future of important listed buildings) an indicative plan based on a similar development

in Painswick was included in the exhibition. The relevant site was within both the Area of Outstanding Beauty and the designated Conservation Area - and had previously received planning consent for a major economic development.

11. Most people were positive about the exhibition. But some residents were

concerned that the ideas exhibited might involve development near to their homes, or spoiling their views. Any plan proposing incremental development around a small town is likely to generate such opposition.

12. It was only in the run-up to the January 2014 exhibition that the Town

Council became aware of the potential need for Environmental Impact Assessment. At this stage, it was also not understood that (within the assumptions of the draft Core Strategy covering our part of the County) new housing in Greet would not count towards Winchcombe’s responsibility to provide for new housing as a Rural Service Centre. This latter point is important, because it significantly reduced the potential choice of non-AONB development sites.

Screening stage (2013-14) 13. Initially Tewkesbury Borough Council were uncertain whether it was

formally for the Borough Council or the Town Council to pursue the need for screening for Environmental Impact Assessment purposes. The Town Council therefore initiated the screening stage in December 2013 - through e-mails dated 19th December 2013 to English Heritage (Caroline Power), Environment Agency (Ruth Clare), Natural England (Sally King) and Cotswolds AONB Conservation Board (Malcolm Watt).

14. Replies were received from: English Heritage (9/01/14); Environment Agency (13/01/14); Natural England (15/01/14); and Cotswolds AONB Board (27/01/14). Additional telephone conversations and email exchanges were held between those consultation bodies and TBC. This information was taken into account (along with the criteria specified in Schedule 1 to the Environmental Assessment of Plans and Programmes Regulations 2004) to form the screening determination.

15. Tewkesbury Borough Council had been advised by the Environment Agency that the Isbourne was not a main river and they would not therefore be making a substantive response. In the public exhibition, residents raised concerns about flood risks in several parts of the town. The Borough Council therefore subsequently added David Graham of Gloucestershire County Council to the consultation, who responded on flooding issues. Toby Catchpole then contributed advice on the archaeology and heritage buildings aspect.

16. The responses from agencies consulted ware fully reported to the Town

Council in February 2014, and they made a formal determination for the screening stage. While building more than 10 homes in the designated AONB

was the only trigger of environmental significance on a scale relevant to the European Regulations, other development sites in the area covered by the proposed plan could also affect the AONB. There were also other environmental issues relating to flooding and the setting of heritage assets that we were advised that it would be wise to respect in taking the plan forward. There were no aspects of relevance to the Sudeley Parish, beyond the fact that storm water from rain falling there has been partly responsible for flooding in Winchcombe.

17. At their meeting on 5th March 2014, the Town Council considered the

outcome of the screening exercise alongside a full report of the parallel consultation exercise on the likely elements of a Neighbourhood Plan. Documents such as the library exhibition boards and the results of earlier consultation had been posted on the dedicated Neighbourhood Plan website. The comprehensive analysis of the responses to the Library exhibition and questionnaires was added to the website, was available to the public on request and included the Screening Report.

18. The Town Council meeting included time for public participation before

taking the decision on the Screening Report; the minutes show the degree to which some of the public were concerned, and wanted to exercise their right to add to their responses to the Library exhibition http://www.winchcombetowncouncil.co.uk/documents/minutes_Town_Council_050314.pdf

19. Having considered the Screening Report, the meeting decided that a Strategic

Environmental Assessment should be carried out. The Town Clerk’s Office issued the formal determination under Regulation 9 on 27th March 2014 to the statutory consultees - English Heritage, Environment Agency, Natural England, Cotswolds AONB Board and Tewkesbury Borough Council; it was also posted on the usual noticeboards in public places.

The Scoping Stage (summer 2014) 20. The Town Council were aware that, before going to formal consultation, they

should make sure all the options relating to the significant development triggering the SEA were properly explored. In that, they needed to be guided by the consultation bodies' advice on the scope of the SEA. They also had the benefit of over 250 responses from the public to the ideas that had been set out in the Library Exhibition. The Steering Group therefore looked to the consultation bodies to provide relevant baseline information (to the degree necessary for a strategic site allocation, knowing that a more detailed individual assessment would be needed before any planning consent could be granted). In effect, the action needed under European Regulations would be encompassed within a wider sustainability appraisal, which would also help to ensure that the ultimate plan would meet the legal requirement to accord with sustainable development principles.

21. On 22nd April 2014 a first draft sustainability assessment was sent to about

300 local people who had included their e-mail address in responding to the Library exhibition, and to all “followers” on the Neighbourhood Plan Website. It was also sent to English Heritage ([email protected]) and David Stuart; Environment Agency ([email protected]) and Carl Cording; Natural England ([email protected]) and Amanda Grundy; Nick Croft and Jason Westmoreland at Tewkesbury BC; Toby Catchpole, Robert Niblett, David Graham, Richard Waters, Gary Kennison at Gloucestershire County Council and to Malcolm Watt at the Cotswolds Conservation Board.

22. Tewkesbury Borough Council provided legal advice to Winchcombe Town Council confirming that full formal consultation with the public or other bodies was not needed until the environmental report on the draft plan had been finalised.

23. It was assumed that if one of the two local councils determined that a Scoping

Report would be necessary, a formal determination from the other would not be necessary. While no determination was issued by the Sudeley Parish Meeting, the content and conclusions (and the terms of the draft SEA) were explained by two Winchcombe Town Councillors attending the annual Sudeley Parish Meeting.

24. Tewkesbury Borough Council (Nick Croft) circulated it internally to officers

and agreed to provide a formal collated response prior to our deadline, including updating the JCS section. He also asked the highways contact at the County Council to have a look. The responses were as follows:

• The Tewkesbury Borough Council comments were useful and were reflected in the final version, although not always in such full detail given complaints by Town Councillors and residents about the length of documents. Crucially, the Borough deferred to the national agencies on the AONB issue which triggered the SEA.

• Natural England reported that they had not visited the NP area or the potential development sites and were therefore unable to provide detailed advice on likely landscape impacts. They advised us to engage the Cotswolds AONB Conservation Board (we had approached them already) and to engage a professional landscape assessor (which we subsequently did) whose report could inform conformity with the relevant policy in the National Planning Guidance.

• Gloucestershire Couty Council also provided a useful response.• The most substantial set of comments from residents on the draft

Scoping Report was submitted by Mr and Mrs Chamberlain, which they said incorporated comments from other residents.

• Another slimmer set, but very similar, was received from Mr Parker.

• Four other responses were received from the public. 25. A recently retired Winchcombe GP contributed additional evidence on health

and wellbeing.

Approval of a sustainability appraisal and scoping report (August 2014) 26. The Town Council followed a model used by other Neighbourhood Plans,

mainly ones where professional consultants had been employed. In the main all the background information supplied by public sector agencies was included - for example from Tewkesbury Borough Council on housing need. The Council did not have the expertise or funds available to second guess this information or test the evidence base that the professional organisations produced - except in the case of landscape issues (the original driver of the need for Strategic Environmental Assessment), where the Town Council followed the advice of English Nature and commissioned an independent study - with a remit to consider all the possible development sites.

27. All responses were taken into account and an amended version of what was

termed a Sustainability Scoping Report was unanimously approved by the Town Council at its meeting on 6th August 2014. The Steering Group then used that document to detail the needs and tests which the draft Neighbourhood Plan should be designed to meet. In particular, the document identified 21 areas and a series of questions that needed to be addressed to satisfy the statutory test of compatibility with sustainable development principles.

Draft Neighbourhood Plan and Environmental Report (December 2014) 28. Both the Winchcombe Town Council and the Sudeley Parish Meeting held

extraordinary meetings during December, to approve formally the draft Neighbourhood Plan and accompanying Environmental Report. In the case of Winchcombe Town Council, a few detailed drafting changes were delegated to Richard Wakeford as lead Town Councillor on Neighbourhood Plan preparation. No changes were suggested at the Sudeley meeting.

29. At the Winchcombe meeting, there was some frustration among the public

attending because the papers considered by the Council had not been made available to them before the meeting; and that there was no time set aside for public participation. This apparently restrictive approach was justified because the planned output from the meeting was a full draft Neighbourhood Plan and Environmental Report for public consultation. The Town Council needed to launch the debate about the plan content, rather than engage in a debate about what they would launch!

30. The consultation was designed to satisfy both Regulation 14 of the Neighbourhood Planning (General) Regulations 2012, and Regulation 13 of the Environmental Assessment of Plans and Programmes Regulations 2004.

31. Both the formal draft plan and the Environmental Report were circulated with a letter dated 30th December 2014 including to:

• Chief Executive, Tewkesbury Borough Council• Chief Executive, Gloucestershire County Council

• Clerk to parishes adjoining Winchcombe and Sudeley• Chief Executive, Natural England• Chief Executive, the Environment Agency• Chief Executive, the Historic Buildings and Monuments Commission for England (known as English Heritage)• Chief Executive, British Telecom• Chair, Winchcombe Business Forum• Chief Executive, Severn Vale Housing• Cotswolds AONB Conservation Board• Disability Action Cheltenham • Bromford Housing• Cottsway Housing • a range of local groups which previously took part in the community leaders brainstorm around Easter 2013

32. A full list of those receiving a letter inviting a response is at Annex A to this document.

33. The requirement to provide an Environmental Report and non-technical summary was met in the formal letters both by

• advertising the availability of the full Environmental Report - which was available through the website - and • ensuring each section of the draft plan, and each policy within that section, was accompanied by a plain English explanation of the background and purpose.

34. The documentation was also brought to the attention of people who live, work or carry on business in the neighbourhood area through:

• Distributing a special issue of Winchcombe Matters and the consultation document (the proposed wording and justification for the neighbourhood development plan) to every house and all business premises in Winchcombe, Greet and the Parish of Sudeley The Town Council website • The Neighbourhood Plan Website • Formal notices on town noticeboards • A drop-in clinic at the Winchcombe Library, open and manned for a whole week during January 2015 • Spare copies available from the Town Council Office • A meeting with the Winchcombe School Parliament

35. The draft Neighbourhood Plan was not sent to neighbouring parish councils, because it was judged that no policies in the draft would have any impact on the adjoining areas.

36. The document distributed made clear how people should respond, by commenting in the spaces provided alongside each draft policy in the document, and in a section for general remarks. It also made clear where and when representations must be received.

37. The Town Council judged that, in particular, the letters to local groups and the blanket distribution to all households would meet the requirements of Paragraph 1 of Schedule 1 of the Neighbourhood Planning (General) Regulations 2012 – in particular to consult:

voluntary bodies some or all of whose activities benefit all or any part of the neighbourhood area;

bodies which represent the interests of different racial, ethnic or national groups in the neighbourhood area;

bodies which represent the interests of different religious groups in the neighbourhood area;

bodies which represent the interests of persons carrying on business in the neighbourhood area; and

bodies which represent the interests of disabled persons in the neighbourhood area.

Testing alternatives to development affecting designated assets and flood risks

38. In terms of testing alternatives where proposals might affect the AONB or heritage assets, archaeological and heritage and evidence provided in some detail by the County Council (and summarised in the Environmental Report) was used.

39. The Almsbury Farm site is wholly within a Conservation Area and adjoins a long established historic park, which would demand tough conditions on any development there. But as the site had benefited from a planning consent for extensive retail and other development in the late 1990s, the Town Council felt that the site could be potentially suitable for a non-farming use involving significant construction, if it met the needs tests set out in current Government guidance. The Town Council saw specialist housing for the elderly on that site as meeting as a local need and the government tests, given its much lower traffic aspect (traffic was the main obstacle to the implementation of the previous consent) and the evidence of need for such housing in Winchcombe.

40. Draft specific conditions for that site were included in Section 6 of the draft Plan; the Town Council specifically invited those responding to the consultation to mention other considerations that should be covered by conditions or a potential Section 106 agreement for that site.Potential storm flood issues were also taken into account. The majority of the land in Almsbury development itself is well clear of the flood zones shown on the Environment Agency mapping.

41. Any development of the West of Winchcombe site would also need to take account of its role in capturing water from the fields above and channelling it into culverts through the town. We received no advice that the application of Sustainable Urban Drainage Standards would not be feasible on this site - or indeed on the Almsbury Farm site.

42. In terms of the areas identified for business development, the draft Plan focused on areas where there is already such development. Tewkesbury Borough Council was reported (by one of the Borough Councillors) to have undertaken to resolve the current storm water flooding issues at the Isbourne Business Park; the Plan assumed that the remedial work would be complete by the time of adoption.

43. In terms of impact on historic assets, the whole of the town is embraced by the Town Design Statement (approved as Supplementary Planning Guidance). Because of public concerns in the town that Tewkesbury Borough Council had not previously placed sufficient weight on that document in their decision making, the draft Neighbourhood Plan contained clearer draft policies on protecting the AONB and heritage assets generally; these were supplemented by a set of draft site specific policies in section 6 of the draft Neighbourhood Plan.

Joint decision taking (2012-2015)

44. At earlier stages of the plan preparation, the Neighbourhood Plan was led by Winchcombe Town Council on behalf of both areas with the full agreement of the Chair of the Sudeley Parish Meeting. The Sudeley Parish Meeting Chair attended consultation events and the exhibition in the Town Library in January 2014. Residents of Sudeley had the opportunity to engage in the process at their annual meetings in 2013 and 2014 - both of which were attended by Winchcombe Town Councillors who made presentations about the Neighbourhood Plan. In the case of the 2014 meeting, the Chair of the Sudeley Parish Meeting made a special effort to engage the 80 or so residents, by hand-delivering the agenda to each house, knocking on the door and being ready to listen to people’s concerns.

45. In terms of the formal SEA requirements, the only issue in the consultation draft plan of sufficient significance to triggering the formal process was the potential development of more than 10 homes on each of two sites adjoining Winchcombe, wholly within the Winchcombe Parish (although one site is promoted by the Sudeley Castle Trustees, based in Sudeley Castle in the Parish of Sudeley). The statutory consultees would have been well aware that the draft plan in preparation would cover both parishes.

Public consultation responses

46. The public response to the draft Neighbourhood Plan covered a wide range of issues. All Town Councillors have been involved in analyzing the responses and proposing amendments to the draft Plan.

2. Summary of responses to the draft Neighbourhood Plan and changes made following formal consultation

47. This section of the Statement of Community Engagement document runs through each of the consultation draft policies in turn. For each draft policy, it gives: a short summary of the purpose of that policy the crude numbers of responses, as reported by the consultant the main issues raised by members of the community responding to the

consultation points made by statutory consultees, including cross references to

Borough Council saved planning policies changes made by the Town Council in response to the points made in

consultation

48. A detailed collation of public responses to the formal consultation, prepared by independent consultant George Reiss, has been uploaded on to the Town Council’s website and is available on request from the Town Council office.

Section 1: Guiding development to appropriate locations

Policy 1.1: Development to respect the distinctive character of Winchcombe

This overarching policy is intended to ensure that all new development respects the character and appearance of the surrounding area, and the principles of sustainable development.

A very large majority agreed. In favour 362; against 18.

Those disagreeing wanted the policy strengthened to rule out all development in the designated AONB area.

There were many and diverse suggestions for additions to the policy – some of which needed to be considered under the more specific policies in later sections.

Statutory consultee response: Cotswolds Conservation Board welcomed reference to the AONB at Paragraph 1.1 of the draft Plan and the work undertaken in the Landscape and Visual Sensitivity Study.

Tewkesbury Borough Council suggested that ‘demonstrating good quality design’ should comprise a specific bullet point rather than being incorporated into the first sentence. They also advised a check of general conformity with saved Tewkesbury Borough Local Plan policies that relate to these issues:

o policy GNL2 design requirements for major development proposals; o policy HEN2 the setting of conservation areas; and o policies NCN3, NCN5 and NCN6 for nature conservation, where these are

in conformity with the NPPF.o The emerging JCS policies SD7 and 8 which relate to landscape matters,

SD9 relates to the historic environment, and SD10 to biodiversity. o The emerging TBP policies ENV1-6 relate to the environment/landscape,

and HER1-6 to historic assets]

Gloucestershire CC Ecology team supported draft policy 1.1 but suggested that text could be sharpened up with items b) and c) combined to say “protecting and enhancing biodiversity including areas of ecological importance”. Item d) could perhaps have a qualification so as to protect other habitats, ecosystems and landscape character – they suggested an alternative text of “maintaining and improving woodland and where appropriate increasing tree cover”.

GCC Historic Environment: suggested that the wording of f) could be improved by the addition of the following at the end of the clause “protecting Scheduled Monuments and significant undesignated heritage assets”.

Changes suggested by the Town Council as a result of the consultation: Minor changes have been made in the draft policy to reflect Tewkesbury Borough Council’s suggestions; and the Town Council has checked general conformity with

the policies specified by the Borough. The main public concerns were to rule out development in the designated AONB area, but this would fall foul of Government guidance.

The Town Council has also checked general conformity with saved Tewkesbury Borough Local Plan policies:

o policy GNL2 design requirements for major development proposals; o policy HEN2 the setting of conservation areas; and o policies NCN3, NCN5 and NCN6 for nature conservation, where these are in

conformity with the NPPF.o The emerging JCS policies SD7 and 8 which relate to landscape matters, SD9

relates to the historic environment, and SD10 to biodiversity, and o emerging TBP policies ENV1-6 relate to the environment/landscape, and

HER1-6 to historic assets

The Town Council also followed Tewkesbury Borough Council’s advice to revise the wording to ensure that the policy would apply only to development having an impact on one or more of the elements specified. The reason for the policy has also been strengthened to ensure that no potential developer is unaware of the presumption against major development that applies in designated AONB areas.

Policy 1.2: Development to minimise loss of productive land

This policy is designed to prioritise development on land not currently used in order to ensure that land used for food production will be available to future generations too.

There was general agreement on not losing productive land. In favour 352; against 23.

Some disagreeing wanted the policy strengthened so that no agricultural land could be developed (and no allotment land either), or to introduce a “presumption against development”; others wanted the policy to differentiate between arable and grazing land, or by land quality; there was also a question for the Town Council to answer - what is the demand for more allotments?

Statutory consultee response: In section (a) is there a good reason for selecting a 5 year test for redundancy of land use? In section (b) the drafting needs to be clearer. In section (c) how would making provision for allotments be applied in any planning application? And is there any demand for allotments in the area anyway?

Changes suggested by the Town Council as a result of the consultation: The reference to “brownfield” land has been omitted as there seems very little such land in the Neighbourhood Plan area. It is hard to see how the policy could be clearer in its intention – to steer development away from agriculturally productive land where there are other options. The position on allotments has been made clearer in the REASON FOR THE POLICY section.

The Town Council has checked general conformity with saved Tewkesbury Borough Local Plan policies that relate to these issues:

o emerging JCS policy SD15(vi) relates to agricultural land;o emerging TBP Policy HOU6 relates to Change of Use of Agricultural Land to

Residential Curtilage

The Town Council has also made clear that land used as woodland is also to be regarded as productive, given its economic, biodiversity and climate change mitigation importance. The policy reference to allotments was also relocated to Section 4, since it related more clearly to services for health and wellbeing.

Policy 1.3: Flood avoidance

This policy aims to reduce the risks to people and property of future flooding by normally ruling out development in the relevant flood zone designated by the Environment Agency.

A strong majority agreed but a strong minority (50+) thought that the policy should be changed so as to ban all development in the flood plain.

In favour 312; against 43.

On the evidence of 2007 some commented that development should also be ruled out in other locations where natural springs and storm water flow occurs.

Statutory consultee response: Tewkesbury BC have asked for the draft policy to be amended to:o make clear the flood zone the policy applies to (it is Environment Agency

Flood Zone 3); o add a reference to the “sequential test” - a risk based sequential approach to

steer new development to Flood Zone 1o include a reference to the adopted Tewkesbury Borough Council

Supplementary Planning Document on Flood and Water Managemento define “major development” for this policyo ensure that the reference to S106 agreements complies with the statutory

tests necessary to make the development acceptable in planning terms directly related to the development; and fairly and reasonably related in scale and kind to the development

Severn Trent Water: Severn Trent fully supports the policy to minimise flood risk associated with storm water run- off. Whilst the policy specifically relates to overland surface water and fluvial river flood risk, the uncontrolled run-off from new development can also increase flood risk in the sewerage system. It is therefore essential that new development drainage provision consists of separate drainage with no connection of surface water into the foul sewerage system.

Severn Trent supported the draft policy to ensure that surface water on new development is managed sustainably through the use of sustainable drainage to mitigate against the increased flood risk in the receiving water body or connection to the existing surface water sewerage system.

Changes suggested by the Town Council as a result of the consultation: The Town Council has made clear what is meant by “major development” and has specified the appropriate flood protection zone. The Council takes the view, however, that it is unnecessary to repeat the content of Tewkesbury Borough Council supplementary planning guidance, or the national tests for Section 106 agreements. Nor does the Town Council intend to apply the sequential test, given that the Borough continues to grant planning consents in Flood Zone 2. The point raised by many members of the public – that no development should be allowed in the flood plan - is the approach that the Town Council wants, but an absolute presumption against development might rule out engineering or other works relevant to river management.

Winchcombe Town Council has also checked general conformity with saved Tewkesbury Borough Local Plan policies that relate to these issues:

The emerging JCS policy INF3 relates to flood risk. It also covers matters such as cumulative impact and reducing existing flood risk.

The saved Tewkesbury Borough Local Plan policy ENT5 covers flooding issues and EVT9 SUDS, insofar as they are in conformity with the NPPF.

After further discussion with Tewkesbury Borough Council officers, the draft policy was retitled to make clear its purpose of preventing development in the designated floodplain unless there is no alternative location for the type of development proposed. To avoid duplication in the Plan, references to the design of new buildings have been concentrated in section 5 of the Plan. References to Section 106 agreements also needed to be removed, given changes in legislation and government policy, and the transition to Community Infrastructure Levy.

Policy 1.4 Sustainable connections

This policy draws on sustainable development goals that should encourage development where it is easy for residents to reach services on foot or cycle rather than driving and adding to town centre congestion.

This proposed policy raised a very large number of individual suggestions

In favour 319; against 52

Most of those objecting seemed to feel that it was unrealistic – that residents simply would not walk. One frequently voiced area of concern was the ability of the current road system to accommodate traffic in a rural area where people need cars.

Cycle paths attracted many comments, and there were also proposals about car parking and the idea of a one-way system in the town.

Lack of good quality public transport was frequently raised although the potential of any NP to act on this is limited.

Statutory consultee response: Tewkesbury BC invited the Town Council to make the policy clearer by

stating whether the intention is that this applies to change of use applications, subdivision and conversions

setting out in the supporting text some examples of what is meant or envisaged by the terms (a) ‘short safe direct’, (b) ‘attractive’, (c) ‘good’ and ‘close’, (d) ‘good’.

GCC Highways: a). what is meant by ‘short routes’? Distance or walking/cycling time? The CIHT suggests that 1000m is an acceptable walking distance. Walking and cycling are two distinct forms of travel and not necessarily compatible modes on the same piece of infrastructure. c). ‘Good access’ is vague. d). published good practice would be Manual for Streets, are the Town Council aware of this guidance?

Changes suggested by the Town Council as a result of the consultation: The Town Council has amended the policy to define what good connections and good access should be taken to mean in Winchcombe. The 500m distance used is less than that suggested by Gloucestershire County Council, to reflect that Winchcombe residents are older, and some are able to walk only short distances to facilities. In considering the views that encouraging development within walking distance of facilities was a pointless goal, the Town Council’s response is that health and wellbeing are important priorities – to which walking and cycling can contribute (and should be encouraged)

The Town Council have also checked general conformity with saved Tewkesbury Borough Local Plan policies:

Saved Tewkesbury Borough Local Plan policies TPT1, TPT3, TPT5 and TPT6 relate to access and transport, and public transport corridors are covered by saved Policy TPT9 insofar as they are in conformity with the NPPF.

The emerging JCS policies INF1 and INF2 relate to access and the transport network.

The emerging TBP policies TRAC1 and 2 relate to cycling and walking. TRAC3 relates to public transport.

After further discussion with Tewkesbury Borough Council officers, the draft policy was further amended to be sufficiently precise for use in development management decisions.

New Policy 1.5 Important Open Space

On advice from Tewkesbury Borough Council, the Town Council separated the previous Local Green Space policy into two elements. Land that clearly satisfied the Government policy guidance on Local Green Spaces is covered by new policy 1.6. The new policy 1.5 is designed to protect the important and distinctive green gap between Winchcombe and Greet, which:

sustains the separate identities of the two settlements through the green gap created by extensive school playing fields on the one hand and agricultural land, along with a protected Scheduled Ancient Monument on the other;

protects the identity of Winchcombe as a small Cotswolds town in important views from the surrounding hills by ensuring a break in what would, if developed, appear to be a much more extensive town

plays an important role in protecting the adjacent Area of Outstanding Natural Beauty Land from what would be a significant adverse impact if developed for purposes other than open agricultural fields (see the detailed description of the significance of this landscape in sections 1B and 19D of the Cotswolds AONB Landscape Character Assessment).

is particularly important in defining the urban boundary when approaching Winchcombe from Gretton, due to the extensive views across to Greet and to the AONB land beyond Greet rising to the scarp face of the Cotswold Edge (see the detailed description of the significance of this landscape in section 2E of the Cotswolds AONB Landscape Character Assessment).

Protecting this area from development is in general conformity with the extant Tewkesbury Borough Plan Policy LND5 – which has a distinctly different aim that Local Green Space policy.

Policy 1.6 (1.5 in the consultation version) Local Green Spaces

This policy proposes the designation of land where development will be ruled out, other than in very special circumstances, consistent with the pursuit of sustainable development and complement investment in sufficient homes, jobs and other essential services. Government policy limits the application of this policy to green space that is local in character, which is not an extensive tract of land, is reasonably close proximity to the community it serves, is demonstrably special to a local community and holds a particular local significance, for example because of its beauty, historic significance, recreational value (including as a playing field), tranquillity or richness of its wildlife.

Many comments linked the question of the proposed new Local Green Spaces to the overall shape of any new developments in Winchcombe.


Some objectors opposed designation in principle, but the majority of them were in favour of the principle, but saw ruling out development on areas 1a and 1b to the West of Winchcombe as more important than the fields proposed by the

policy – designed to maintain the open gap between Winchcombe and Greet until 2031, at least.

Statutory consultee response: TBC note that six ‘local green space’ areas are identified on the proposals map, which in effect circle the town to the north, east and south. The implication of this appears to be that should future development be required around the town it would be directed to the west and south west within the AONB. The areas identified are fairly large and evidence to support their designation needs to be provided (setting out how they confirm to the NPPF: 76-78 requirements that are referred to in the supporting text).

Although the designation does not depend on the permission of the landowner, and in some ways is therefore akin to any other planning use designation, TBC advise that contact should have been made with landowners at "an early stage" about any proposals to designate their land. Landowners will then have "opportunities to make representations in respect of the proposals" appearing in a draft plan.

TBC also ask what agricultural/horsiculture/forestry activities should be considered in these locations?

GCC Ecology Draft policy 1.5 should perhaps be tempered to end “… that ensures the land is maintained predominantly as green space.”

Changes suggested by the Town Council as a result of the consultation: The Town Council gave full consideration to representations from the community to extend the designation of local green space beyond those proposed in the draft Neighbourhood Plan to the fields to the West of the town, above Kyderminster Road, Delavale Road and Orchard Road as far as Harvey’s Lane. They concluded, however, that there was not sufficient public access to this land to satisfy the national Government policy. They also reconsidered their proposals for designation of other sites, and decided:

In the case of AONB designated land to rely on the Government guidance without further designation

In the case of the sports and recreation fields along Greet Road, to rely on public ownership rather than making any designation.

The submitted plan will therefore designate only: The fields along Broadway Road between the edge of town and

Winchcombe Garage The two parcels to the north of Meadowfort Grange, starting extending as

far as the public footpath from Greet to Gretton Road – with the intention of maintaining the open gap between Winchcombe and Greet at least until 2031.

The revised wording follows the recommendations of Tewkesbury Borough Council planning officers as being more effective in achieving the Town Council’s goals.

Section 2: Development of a Thriving Economy

Policy 2.1 New Commercial and Light Industrial Development

This policy identifies areas where premises for small businesses are to be encouraged to provide opportunities for investment and new jobs that can sustain the town’s overall “living and working” character

The main comments concerned the capacity of the road system to absorb increased use, and the area around Almsbury Farm / Vineyard Street where a wide range of suggested changes were made.


Objectors referred to the need to respect the AONB where business development required expansion, conversion, re-use and adaptation of rural buildings; and also the need to protect buildings of historic or architectural value. They also pointed out the importance of protecting Vineyard Street parking.

Statutory consultee response: TBC suggest that the Plan makes clear the extent to which these proposals have been tested through

the SEA process makes more explicit the need to provide a range of premises size and

types, which allow for enterprise progression from start-up/incubator units – to small workshops, and to light industrial uses

refers to access and design issues (The saved Tewkesbury Borough Local Plan policy that relates to design issues for major development proposals is policy GNL2)

They also ask: why we chose 100 sq m to define small business premises why there is no policy wording relating to the goal to develop skills

training

Changes suggested by the Town Council as a result of the consultation: The Town Council takes the view that none of the developments envisaged by this policy are of sufficient significance to require strategic environmental assessment; and the potential scale of development is not sufficient to require economic development strategies of kind suggested. And while some traffic growth may result from expanding local business premises, it will be modest and offset by increased job opportunities for local people (who may drive less as a result). A modest change in the policy has been made to reflect the skills training dimension, to the extent that it is relevant to a development plan.


saved Tewkesbury Borough Local Plan policies EMP2, EMP3, EMP4 and EMP5 where in conformity with the NPPF

emerging JCS policy SD2 relates on employment issues emerging TBP policies EMP2-5.

Minor drafting changes were made to improve the effective application of this policy as advised by Tewkesbury Borough Council planning officers.

Policy 2.2 Postlip Paper Mill

This policy is intended to enable the major business at Postlip Mill to adapt their premises to remain competitive.

There was general agreement but a large group of comments reflected concerns that lorries travelling to and from the Mill were going through Winchcombe Town.


Some objectors wanted this firm to locate elsewhere rather than expand, while a much larger number of those commenting wanted tougher rules on how new buildings on the site should fit into the landscape. Another set of comments were looking to influence the routes freight vehicles would take to the Mill.

Statutory consultee response: TBC suggest that some reference to access and design would be useful

Changes suggested by the Town Council as a result of the consultation: None; the Town Council believes that other policies in the Plan cover access and design suffiently


the saved Tewkesbury Borough Local Plan policy that relates to design issues for major development proposals is policy GNL2.

Policy 2.3 Protection of Business Premises

This policy aims to discourage the conversion of business premises into residential use.

There were very high levels of agreement with this proposal.


The most frequently suggested change would increase the length of unsuccessful marketing period to more than the 12 months suggested in the policy.

Statutory consultee response: TBC suggestions:

In the ‘need’ column – where it say ‘its’ – should this say ‘the areas’? In the draft policies column -

a) is securing a new operator the correct wording – should it be ‘securing a new business enterprise or tenant’? b) How would you define that the use is no longer needed in the town? Would this not need to be linked to the viability of the business itself? Or make it general to employment activity so everything is covered?

Changes suggested by the Town Council as a result of the consultation: The Town Council has cut out the implied “needs test” in the draft Plan, as it would be unclear how the need for a particular retail or other business would be tested.

The Town Council have also checked general conformity with saved Tewkesbury Borough Local Plan policies that relate to these issues:

saved Tewkesbury Borough Local Plan EMP5 where in conformity with the NPPF

emerging TBP policies EMP2-5

Policy 2.4 Buildings for Rural Business

This policy seeks to ensure that the buildings needed by farmers, foresters and other rurally focussed businesses are particularly sensitively designed – in size, scale, design and appearance.

There were very high levels of agreement with this proposal and just a few divergent opinions in the comments.

In favour 383; disagree 7

Three of those objecting to this policy in fact disagreed with every policy in the draft Plan without making any comment.

Statutory consultee response: TBC ask whether we mean only agricultural/horsiculture types of uses and development, or some other wider definition of rural business

Changes suggested by the Town Council as a result of the consultation: The policy heading has been amended to make clear that it is intended to apply only to the types of business that use the buildings and shelters specified.


Saved Tewkesbury Borough Local Plan policy RCN6 relates to this type of development where in conformity with the NPPF

other saved policies in that plan relate to other rural recreational businesses such as golf courses (RCN7) and noise/nuisance from countryside sports (RCN9).

Policy 2.5 Home Based Working

This policy seeks to encourage home based working – which is generally good for the economy of the area and contributes to sustainable development goals.

There were very high levels of agreement: with the most frequent comments looking for the policy to be defined more tightly.


Faster Broadband was mentioned as a priority by some, and is near to implementation. Others wanted the Town Council to clarify what “adverse impact” and “unreasonable” meant – for example by words such as “any disturbance to normal residential enjoyment of [a neighbouring] property”.

Statutory consultee response: TBC ask why there is no reference to potential for or encouragement of live work units in the document

Changes suggested by the Town Council as a result of the consultation: None. The Town Council believes that this policy does embrace live work units. And the proposed elaborations of “unreasonable adverse impact” would make the policy clearer but no more certain.

Policy 2.6 Tourist Accommodation

The goal for this policy was to improve the image and attractiveness of the town, but the policy itself focussed largely on accommodation

The high number of comments on this policy came from many angles: some were wary of any increases in holiday accommodation and there were detailed questions about need, type, design, and location. Overall, hotels raised more questions and concerns than Bed and & Breakfast.


About 15 objectors suggested that no hotel is needed in Winchcombe. Over 30 commented that more bed and breakfast accommodation was needed (and said that there was evidence to support that); but it is hard to see how planning policies could reverse that trend. The Winchcombe Town Trust say that they aim to expand the Old Town Hall museums to become a major focal point in the town. Others are clear they want “no theme park type attractions”.

Statutory consultee response: TBC point out that the justification text refers to ‘tourist facilities and attractions’, however these are not then mentioned in the draft policies section, and the section itself is entitled ‘tourist accommodation’. They ask if this needs to be broadened to reflect the wider matters being referred to in the supporting text? What about bed and breakfast? Caravan/camp sites?

TBC recommend revised wording: ‘Other types of new holiday accommodation will be supported...’ ‘Strong support will be given to proposals to provide tourist

accommodation to meet the needs of visitors and residents of Winchcombe and Sudeley provided conditions are applied to ensure that they do not become permanent residences….’

Changes suggested by the Town Council as a result of the consultation: The Town Council have amended the policy as advised by Tewkesbury Borough Council. The goals for Old Town Hall are compatible with this and other policies in the Plan.

The Town Council has checked general conformity with saved development plan policies that relate to these issues:

saved Tewkesbury Borough Local Plan policies TOR1, 2, 4, 5, 6, 7 where in conformity with the NPPF

saved Tewkesbury Borough Local Plan policy GNL2 emerging JCS policy SD2 (supporting text) and SD3 relate to tourist issues emerging TBP policies TOR1 and 2 cover these type of issues

Policy 2.7 Retail Development

The policy encourages improvement and redevelopment of shops to meet local and visitor needs, in line with policies in the draft Joint Core Strategy

This policy attracted a very high level of agreement.


The main focus of comments was on meeting the practical needs of local residents in terms of the location and type of shops. A few promoted the idea of a “proper supermarket” with parking, at the edge of town. Others were concerned that the town has too many tourist trivia, charity and antique outlets crowding out shops which they say local people would find more useful. This is not within the scope of planning control.

Statutory consultee response: TBC ask what floorspace the two retail developments mentioned represent. They also suggest clearer wording:

‘in the town centre conversion of former shops back to retail use from residential or office uses will be encouraged’

Changes suggested by the Town Council as a result of the consultation: The Town Council has amended the policy to reflect the Tewkesbury Borough Council proposals. No other changes were called for in the light of the consultation response.

The Town Council has also checked general conformity with saved development plan policies that relate to these issues:

saved Tewkesbury Borough Local Plan RET3,4,5,6,8,9 where in conformity with the NPPF

saved Tewkesbury Borough Local Plan policy relating to design issues for major development - policy GNL2.

emerging JCS policy SD3 emerging TBP policies RET1-6

Policy 2.8 Promotion of Local Products

This policy would encourage the removal of two parking spaces in Abbey Terrace to make an area in front of Lloyds Bank available for market stalls for occasional use by local food producers

Although more than twice as many people agreed than disagreed, this policy had one of the higher levels of opposition and many comments.


By far the largest concern was to do with any loss of parking in Abbey Terrace that might result from a farmers’ market in that location - followed by concerns over the possible impact of competition on local traders. There were many individual suggestions about other possible locations for a farmers market.

Statutory consultee response: None

Changes suggested by the Town Council as a result of the consultation: The Town Council has amended the policy, which was never intended to encourage development on a scale that would significantly affect parking. The REASON FOR THE POLICY now also makes clear that the intention is to bring more customers to benefit existing shops – as has been the case in many other places.

Policy 2.9 Sudeley Castle

This policy provides positive encouragement to the operators of Sudeley Castle to develop in ways that support the local economy, but not in any way that listed buildings and scheduled ancient monuments regulations would prevent.

There was a very high level of agreement and relatively few comments on this policy


The main group of those responding felt the policy was too vague, and were concerned about the possibility of a major events venue (not promoted by the plan) that would threaten Winchcombe’s tranquility.

Statutory consultee response: Make clear whether this covers development at Sudeley Castle, in its gardens, and (if applicable) in its designated parkland and other adjoining fields

Changes suggested by the Town Council as a result of the consultation: The Town Council has redrafted the policy to make it more specific.

Policy 2.10 Winchcombe Pottery

This policy is designed to encourage growth in Winchcombe Pottery and diversification into other potential attractions bringing more jobs and businesses to the town

There was a strong majority in favour of the proposal, but there were some concerned comments

Agree 331; disagree 48

Looking through the comments of those who oppose this policy reveals a range of concerns; some want no development at this entry point to the town; some are concerned that the site is at risk of flooding; some do not wish to see a car park on the land opposite the Pottery in Becketts Lane.

Statutory consultee response: TBC suggest defining “immediate vicinity”

Changes suggested by the Town Council as a result of the consultation: The Town Council remains keen to see this local asset develop to its full potential and believes that immediate vicinity can only be judged at the point when any planning application is made.

Policy 2.11 The Old Town Hall

The policy proposed the creation of a more pedestrian friendly space at this, the heart of town, and upgrading of the Tourist Information Centre and other museum attractions

Although most agreed, this policy had the highest level of disagreement.


Of the 414 responding to this proposed policy, 45 opposed the removal of the railings and 45 (not all the same people) also opposed the proposal to glaze the understorey. The Winchcombe Town Trust supported the idea of glazing, but not the proposal to open up the public space at the corner (their response suggested that the railing protects the building from vehicular damage and people gathering in the evenings causing a nuisance; the railings also provide security for the building and the stocks.

Statutory consultee response: TBC suggests using the phrase “public space” rather than “open space”

Changes suggested by the Town Council as a result of the consultation: The Town Council have modified the policy so as to be open to proposals from the Town Trust to make a better use of the building and its forecourt. The wording has been amended to refer to “public space”.

Policy 2.12 The Gloucestershire and Warwickshire Railway

The policy supports the development of new enterprises or attractions at Winchcombe Station, to encourage tourists to get off the train and contribute to the town’s economy

There was general agreement and relatively little response to this proposed policy


The reasons given by those against the policy includes using land here for housing; not allowing development because the GWR already creates problems; not allowing development given the lack of car parking. Other comments suggested improving public transport, “tourist transport” ((eg a road train) and walking routes to the station.

Statutory consultee response: No substantive comment

Changes suggested by the Town Council as a result of the consultation: None needed

The Town Council has also checked general conformity with the development plan policies that relate to these issues:

The saved Tewkesbury Borough Local Plan policy that relates to the Gloucestershire and Warwickshire Railway is policy TPT11. And in the emerging TBP the policy is TRAC11.

Section 3 Development of places to live

In commenting on this section in particular, Tewkesbury Borough Council emphasised the importance of ensuring that sufficient homes/jobs can be provided to meet the needs of the area. Whilst there is no requirement for a Neighbourhood Plan to allocate sites it should not promote less development than set out in the Local Plan or undermine its strategic policies. The strategic policy covering this aspect is still ‘emerging’ through the submission version of the Joint Core Strategy (JCS) and thus in respect of the Planning Practice Guidance the NP will not be tested against these policies (as currently stands at the present time). However the Town Council should be aware of the reasoning and evidence underpinning the JCS in this respect as should there be a conflict between a policy in a neighbourhood plan and a policy in a Local Plan, section 38(5) of the Planning and Compulsory Purchase Act 2004 requires that the conflict must be resolved in favour of the policy which is contained in the last document to become part of the development plan.

Similarly, the emerging Tewkesbury Borough Plan (TBP) will provide further information on how the levels of development expected through the JCS should be delivered within the borough. It is noted that the draft NP was prepared ahead of the detailed information in the TBP being known and therefore further discussions will need to take place between the NP group and the LPA to ensure that the plan has the greatest chance of success at the independent examination.

Winchcombe is one of two Rural Service Centres and the JCS (albeit not yet tested or approved) sets out a requirement for the two settlements to provide (at least) 1860 homes, much of which are committed and the balance to be found is 114 (assuming all commitments are built - particularly important where we have only outline permission, and reserved matters come in lower).

As part of the evidence for the NP it would be useful if there were a demonstration that there has been discussion between the two rural service centres about how many homes they think they can accommodate. It would also be helpful to set out any evidence used to underpin Winchcombe’s housing requirement on which the need for site allocations in the plan has been based.

The emerging Tewkesbury Borough Plan is out for public consultation and identifies rural options at Winchcombe and one at Bishop’s Cleeve. The total capacity that is identified in the Draft TBP for public consultation would indeed provide far in excess of the levels required based on current evidence, but it is not clear that the NP would provide sufficient. It is appreciated that the TBP is at

an early stage but we would wish to avoid a situation where the NP progresses successfully, only for the TBP to follow and then supersede that document by providing additional/alternative allocations.

The Town Council has responded to Tewkesbury Borough Council’s draft Borough Plan suggesting that it fundamentally misunderstands the overall context and characteristics of the town, and in comparison with Bishops Cleeve is an unsuitable location for any large scale development. Winchcombe is severely constrained by the AONB and associated Special Landscape Area, has an historic core containing many Listed Buildings, relatively poor public transport connections, and limited employment opportunities.

On the other hand Bishops Cleeve has none of these constraints, and is a much more sustainable location, as has been shown by the past rate of growth. Bishops Cleeve is the dominant settlement and is capable of taking further future growth without serious adverse consequences. Winchcombe, should only be required to accept very modest and sensitive growth to meet identified local requirements. If any further general housing is required in Winchcombe, then it should be programmed for the latter part of the plan period and be limited to meeting the locally identified needs. There are many more sustainable locations in other parts of the Borough that can accommodate further growth without impinging upon areas of national landscape significance.

Following consideration of all the responses to the draft Neighbourhood Plan, the Town Council has identified one development site that, in meeting the special need for dedicated housing for older people, may accommodate 70 homes and a care home facility. There may also be a need for further new homes to meet a likely need for younger families after 2021. Together with some further infill development, the Town Council believes that it can contribute no more than 100 new homes, during the current period of adapting to the three significant developments permitted in the last three years – adding over 200 new homes.

Policy 3.1 Incremental growth

This policy sets the scene for other, more detailed policies about housing by making clear that no developments of over 10 homes will be allowed on other than the specified sites in Section 6 of the Plan, and that all other housing development will need to be limited to 5 units or fewer and fit with all the other policies in the Plan. The policy also requires developments of more than six houses to contribute affordable housing within the development.

This policy generated a large number of detailed comments, despite being supported by about a 3:1 majority of respondents.


About twenty of the objections came from those who believe that the Neighbourhood Plan should be delayed until Tewkesbury Borough Council have set the number of new homes for the town (and presumably the allocated sites too, if there is no Neighbourhood Plan at that point). Another 10 felt that Winchcombe lacks the infrastructure to support any more homes. Many of these objectors also suggested that this policy should be extended to prevent any new development on designated AONB land. There were different views about the need for affordable housing: some said there was a need; some said that there was already too much; yet others disliked the presumption that market housing had to be developed to pay for the affordable housing the town needs.

Statutory consultee response: TBC have suggested that the plan should align affordable housing contributions with the new national requirements and include conversions leading to 10 units

Severn Trent Water: Whilst smaller scale development does not usually raise concerns relating to sewer capacity, it is vital that surface water run-off from smaller ‘infill’ development is also managed sustainably, where practicable to do so, to ensure there is no deterioration in the collective surface water flood risk.

Changes suggested by the Town Council as a result of the consultation: This policy is designed to encourage modest incremental growth of the town, except in the case of two major developments that may be required to meet local needs in the years up to 2031. The Town Council has amended the policy to add a list of general requirements to apply to all housing proposals, including the Sustainable Urban Drainage System requirement that should satisfy Severn Trent Water. Infrastructure is addressed by other policies. More significantly, this policy now refers to a new policy 3.5 which identifies two potential sites for more than 10 homes, but subject to significant conditions related to local needs and the requirement to respect national policy to protect designated AONBs from damaging development.

The Town Council has checked general conformity with the development plan policy that relate to these issues:

saved Tewkesbury Borough Local Plan policy GNL2 relating to design issues for major development proposals

The Town Council also check for general conformity with saved Tewkesbury Borough Local Plan policies that relate to these issues:

o policy GNL2 design requirements for major development proposals; o policy HEN2 the setting of conservation areas; and o policies NCN3, NCN5 and NCN6 for nature conservation, where these are in

conformity with the NPPF.o The emerging JCS policies SD7 and 8 which relate to landscape matters, SD9

relates to the historic environment, and SD10 to biodiversity. The emerging TBP policies ENV1-6 relate to the environment/landscape, and HER1-6 to historic assets

Policy 3.2 Infill development

This policy encourages sensitive infill development or redevelopment of housing within the town’s built up area

A very large majority in favour


Those commenting expressed concerns about “town cramming”, pressure on parking in the streets affected and the need not to disadvantage neighbouring properties, including through excessive height. The Town Council are asked to make clear that infill development does not mean backland development at the ends of gardens.

Statutory consultee response: none

Changes suggested by the Town Council as a result of the consultation: The Town Council believes that terms of this policy, taken alongside other policies such as those requiring gardens and off-street parking will defend the town from the adverse impact of “town cramming”


saved Tewkesbury Borough Local Plan policies HOU2 - 14 where in conformity with the NPPF

emerging TBP policies HOU2-8 emerging JCS policy SD11

Policy 3.3 Regeneration

This policy is designed for areas where housing needs to be replaced as a result of not meeting the needs of today’s community

A huge majority were in favour


The most frequent comment on this policy was that replacement homes should be limited to two storeys.

Statutory consultee response: When replacing/ regenerating affordable homes, or any homes for that matter, it may not be possible to match the numbers. Flats for example may be seen as not suitable for regeneration but that the land will be re-developed and therefore provide better quality accommodation but reduce overall numbers. Concern is that this is limiting Tewkesbury Borough Council, the housing association and the town in stating that numbers cannot reduce. It is an encouraging statement but limiting.

There is the possibility of redeveloping garage sites that have a positive impact on regeneration (usually due to anti-social behaviour they can cause). It would be useful to understand the Town Council’s views on such land and other council/Severn Vale land that is un-used and whether they feel it should be redeveloped to improve areas and build more affordable homes.

Changes suggested by the Town Council as a result of the consultation: The Town Council sees no need to amend the draft policy


saved Tewkesbury Borough Local Plan policy GNL2 relating to design issues for major development proposals

Policy 3.4 Meeting Local Needs for New Homes for those with Modest Incomes

This policy is designed to ensure that there are new homes for those from the locality who need “affordable housing” – delivered as a proportion of all larger developments of six or more homes. It also proposed limiting the so-called “rural exceptions” policy to rural locations away from the town, to avoid edge of town sprawl (in the shape of authorised “breaches” of AONB policy).

A large majority were in favour.


The main objection came from those who believe that Winchcombe already has enough affordable housing to meet needs for the duration of the plan; and who believe that the town’s infrastructure is already under too much pressure. Some were concerned about the affordable housing being allocated to families in need from outside the Plan area. Another line of objection was directed against the so-called “rural exceptions” policy; given the unfortunate precedent of Mount View, which in turn made the Redrow development at Meadowfort easier to approve at appeal, objectors did not want it to apply anywhere in the AONB of the two parishes.

Statutory consultee response: TBC would favour the current approach whereby affordable housing on market sites is intended for families in need anywhere in the Borough, with priority within that for people with local connections. “Market sites (s106) are to deliver market need and our (ie TBC) 40% emerging policy is based on a borough-wide need for new affordable homes. This is the evidence and that it is negotiated with the borough council essentially. It is not appropriate for local connection to be applied to all circumstances as there is a struggle to house people in need – as local connection trumps need. Therefore people just move around the area and those in housing

need from other areas are overlooked due to local connection. It is for the council to determine housing need and therefore the allocation of homes should be flexible.”

TBC are also unhappy about the plan proposals that would see “rural exceptions” sites being limited to areas well clear of the built up edge of Winchcombe. They ask that the plan provides more justification of that.

Changes suggested by the Town Council as a result of the consultation: The Town Council has clarified the wording and explained in the REASON FOR THE POLICY why they believe that the 100% rural exceptions policy should not apply on land near or adjoining the urban area of Winchcombe.

The Town Council has also checked general conformity with the development plan policies that relate to this issue:

Development of rural exception sites is covered by the emerging JCS policy SD13 (7)

Policy 3.5 Meeting Needs for New Homes for those of Retirement Age

This policy is designed to meet the need for new housing for older people, in a community large enough to enable support services to be provided to residents. While not specifying the site at Almsbury Farm put to the Town Council by the landowner, or the extensive West of Winchcombe site where the developer had an option for a similar development, the policy made clear that if such development did not go ahead, those sites should not be regarded as suitable for market housing

A significant majority favoured this general approach to providing housing for the older sector of the community.


While there was a significant majority in favour of this approach, many respondents questioned whether there was a need for a purpose built facility, suggesting instead that new housing developments should be mixed, including housing for older people. Others suggested that Winchcombe was not the place for “luxury” developments. No responses mentioned the economic potential arising from the new jobs a dedicated facility would generate.

Statutory consultee response: TBC Housing Officer has made a comment that isn’t easy to interpret, explaining that there are plenty of opportunities for housing associations to provide specially designed accommodation, with care, to fulfil older people’s aspirations. This way the homes can be well-financed and achieve affordable homes for older people without their own means to buy, as well as providing quality housing with care for the open market needs. He then points out that parish councils “forget” that open market housing can be sold to anyone; and homes will sell to those who wish to buy wherever they come from

– a housing provider can make some provisions to ensure the local need is catered for in perpetuity whereas a private scheme may not.

Changes suggested by the Town Council as a result of the consultation: The Town Council’s consultation sought to separate the principle of such development from any preferred site (which was proposed in section 6 of the draft Neighbourhood Plan consultation). In the light of the responses to both this and the proposal in Section 6, it has now brought the site proposal for development at the former Almsbury Farm and a comprehensive set of conditions into this policy. The Town Council remains convinced that there is a need for a development of this kind, which would bring social and economic benefits to the town and trigger the restoration of a long underused historic asset.

The response from Tewkesbury Borough Council infers that our policy for a market funded development to regenerate the Almsbury Farm site is intended only to meet local demand – when the Town Council’s arguments in favour are in fact rather wider; development by a housing association on either Almsbury or the West of Winchcombe site proposed earlier would be unlikely to be viable without a significant element of market housing (as has been recently approved on appeal in Broadway).

The Town Council have also checked general conformity with the development plan policies:

saved Tewkesbury Borough Local Plan policy GNL2 relates to design issues for major development proposals

elderly persons accommodation is covered by policy HOU11.

Policy 3.6 Support for Services

This general policy is intended to trigger “planning gain” through Section 106 financial contributions to address the off-site impact of development on local highways, medical, educational and other services. Such contributions are expected to be lower (if and) when a Community Infrastructure Levy is introduced by Tewkesbury Borough Council – bringing higher payments (25% rather than 15%) to communities with “made” Neighbourhood Development Plans.

This policy attracted a very high level of agreement.


The main question raised was whether sufficient funds would be raised to meet the projected impact of major new development on infrastructure. Did the policy raise unrealistic expectations? But equally, did it exceed what national policy policy specified?

Statutory consultee response: TBC advised a caveat on CIL ‘if a decision is made by TBC to adopt”. And they reminded the Town Council that the use of

S106 restrictions will need to be considered in relation to the new tests set out in regulation 122 and 123 of the Community Infrastructure Levy Regulations 2010 as amended. The tests are:

1. necessary to make the development acceptable in planning terms2. directly related to the development; and3. fairly and reasonably related in scale and kind to the development

Changes suggested by the Town Council as a result of the consultation: The phrase “where legally possible through a Section 106 agreement” refers to the statutory tests, which the Town Council does not see a need to repeat in the policy. One concern expressed locally is the lack of engagement when such agreements are negotiated. The Town Council seeks to overcome that by seeking to be involved in finalising such agreements and applying the funds where the local impact is greatest. The draft policy has therefore been revised.

Policy 3.7 Bungalow Extensions

The policy is intended to maintain the stock of bungalows by making it harder to convert single storey buildings (which many older people see as a housing need) to two storey houses if the development concerned requires a planning application

A strong majority in favour but much less so than for most other policies


The main concern was that this policy was too prescriptive, and would penalise young families in bungalows wanting more space without moving home.

Statutory consultee response: Tewkesbury Borough Council happy with changes made to the Town Council’s earlier draft policy

Changes suggested by the Town Council as a result of the consultation: The Town Council gave full consideration to the views expressed – whether supporting the draft policy or opposing it. Their conclusion was to take the draft policy through to the submitted draft Neighbourhood Plan, but also to add specific encouragement to developers to provide almshouses or small bungalows on suitable infill sites.

Policy 3.8 Off Street Parking

The policy sets minimum on-site parking standards to ensure that roads and pavements in residential areas are not overwhelmed by on-street parking

Although a strong majority agreed there was a substantial minority that did not


By far the largest number of responses argued for increased parking levels in all new developments including sheltered housing, to ensure that roads are not blocked by on-street parking. A couple of responses wanted it made clear that garages should not be counted as parking spaces – as they are generally not used for cars. Other ideas were offered, including car parking areas at a distance from dwellings, presumably to allow more efficient use of land.

Statutory consultee response: GCC Highways Where is the evidence base to support the proposed minimum parking standards. Have the issues referred to in paragraph 39 of The Framework1 been taken into account? Proposed parking standard appears to relate to the number of bedrooms not number of habitable rooms.

Severn Trent Water: Increases in off-street parking can result in increased run-off during storm conditions. It is therefore essential that although individually they may be small area they can collectively contribute to increased flood risk. We therefore would support the use of sustainable drainage where possible to reduce increases in run-off.

Changes suggested by the Town Council as a result of the consultation: The policy has been re-expressed in more straightforward terms, putting the onus on the developer to ensure no added pressure to on-street parking.

Section 4: Services that Support a Good Quality of Life and Wellbeing

Policy 4.1 Protection and Improvement of Community Facilities

This policy is intended to protect existing community facilities for sport and recreation, or for the wide range of recreational activities that already take place in our community buildings. It also suggested tapping developers for support for such facilities, where possible within government policy limits

A large majority agreed with the proposal, and suggestions were made as to which potential amenities should be prioritised.


1 Not sure what The Framework is…

Some objections were based on the premise that unwanted development might be encouraged as a way of delivering the facilities the community needs. This was made worse, in their view, because the development to be tapped were not defined in the policy. One response called for a BMX track, another two agreed with the need for a skateboard park; one opposed it on the grounds that it would lead to anti-social behaviour. Rather more responded that the town needs a larger place for social interactions and leisure activities – adding to the Abbey Fields Centre and the Methodist Church Hall.

Statutory consultee response: TBC advise: more clarity on what community facilities would be required, and could

be funded, through new development. Is there a clear priority on what improvements or new facilities are required most?

events and festivals or playing pitches – are they a deliberate decision or has there been no feedback on this.

Changes suggested by the Town Council as a result of the consultation: A modest clarification that replacement facilities need to be at least as comprehensive as those to be replaced

Policy 4.2 Indoor Sports and Youth Facilities

This policy is designed to protect and improve indoor sports and youth facilities, whether at the Old Boys School site or in an alternative location as the result of a developer agreement

A large majority agreed with the proposal, and suggestions were made as to which potential amenities should be prioritised


This policy was widely criticised as being too vague. A dozen or so responses wanted to maintain facilities at the Old Boys School site in any event – regardless of other proposals. Others were looking for more detail in the policy, or proposed sporting activities currently not possible in the existing facilities.

Statutory consultee response: No specific comment

Changes suggested by the Town Council as a result of the consultation: A modest clarification that replacement facilities need to be at least as comprehensive as those to be replaced

The Town Council has checked general conformity with the development plan policies that relate to these issues:

saved Tewkesbury Borough Local Plan policy RCN2 relates to these types of development where in conformity with the NPPF;

saved Tewkesbury Borough Local Plan policy GNL2 relates to design issues for major development proposals

emerging JCS policy INF5 relates to community development issues.

Policy 4.3 Facilities for Older Residents

This policy proposes improving the facilities at the Winchcombe Day Centre and the development of a bowling green somewhere in the town serving the needs of older residents

A large majority agreed with the proposal


In this policy, those disagreeing often did not say why, and many who did respond with comments said that the policy was “stereotyped” and could be considered offensive to older people. Others argued against improvement of the Day Centre facilities because too nfew Winchcombe residents use them. There was a general call for intergenerational thinking in the Plan.


Changes suggested by the Town Council as a result of the consultation: The Town Council has made modest amendments to respect the views put forward in the consultation


saved Tewkesbury Borough Local Plan policies GNL2, GNL15 and RCN1 and 2 where in conformity with the NPPF

emerging JCS policy INF5 relates to community development issues emerging TBP policy IRC1 relates to community facilities.

Policy 4.4 Facilities for Younger Residents

This policy proposes a younger persons’ multiple activity area at the Greet Road end of the sports pitches to be created beyond the Pennylands development

A very strong majority supported the policy.


One objector felt that the site would be too remote and difficult to monitor. Others felt it was wrong to segregate facilities for different generations, and there was a general concern to respect neighbours and avoid development that encouraged anti social behaviour. But overall, there was a general sense that such a facility would be good for those who wanted to use it, alongside a more general playing field area. Some said that this could be better located on the Abbey Fields site.


Changes suggested by the Town Council as a result of the consultation: The Town Council has changed the name of the proposed facility to a “Youth Activity Park” so as to enable full engagement of the community in the facility and activities served.


saved Tewkesbury Borough Local Plan policies GNL2, GNL15 and RCN1 and 2 where in conformity with the NPPF

emerging JCS policy INF5 relates to community development issues emerging TBP policy IRC1 relates to community facilities.

Policy 4.5 Walking and Cycling Routes

This policy, important to contribute to sustainable development and wellbeing objectives, encourages the development of a better network of walking and cycling routes

A very large majority agreed with the proposals


Walkers are Welcome in Winchcombe suggested deleting this policy in its entirety (there does not appear to be a response to the consultation from the Winchcombe Cycle Club). A large number of comments concerned mixing pedestrians and cyclists. Lots of more positive individual suggestions were made for paths and cycle routes to provide safer routes around the town.


Changes suggested by the Town Council as a result of the consultation: The Town Council believes that both walking and cycling have a place in a sustainable transport policy that encourages better health and wellbeing. There is a need for walkers and cyclists to share facilities where they are suitable. It has added a requirement for better signposting to help encourage walking and cycling and to reduce areas of potential conflict.


saved Tewkesbury Borough Local Plan policies TPT1,3,5,6 where in conformity with the NPPF

the emerging JCS policy INF1 and the emerging TBP policies TRAC1,2,3

Policy 4.6 Car Parking

This policy is designed to ensure that any development in the former Almsbury Farm area, likely to increase traffic flow in Vineyard Street, should be required to provide alternative parking (to compensate for more than that lost in Vineyard Street) and additional parking (to enable Abbey Terrace parking to be reorganised to remove the need for cars to reverse on and off the main road)

There was a large majority of nearly 4:1 in favour of the policy


This policy generated a very large number of individual comments about parking across Winchcombe. The general theme was that the amount of public parking should be protected – the purpose of the policy – and that relocated or additional

facilities need to be provided in advance of any realignment of Abbey Terrace parking to improve safety. Some suggested residents’ permits as a way of managing the pressure. Others wanted the location of any new parking to be more clearly defined in the policy – to be on the same side of Vineyard Street as the redundant farm buildings.

Statutory consultee response: TBC suggest that the phrase ‘a reasonably free two way flow’, needs clarification.

Changes suggested by the Town Council as a result of the consultation: The Town Council has concluded that more research is needed of the use of car parks and the need and location of additional spaces. They have therefore deleted this draft policy and will instead look to come up with a clearer strategy for examination in the planned Neighbourhood Plan review in 2020.

Section 5 Design Standards for Development

Policy 5.1 Design of New Development

This policy seeks to ensure that new development complements the quality of the town and its surroundings through its positioning, architecture and landscaping

This draft policy had very high levels of agreement


Those objecting to this policy included those opposed to any development in Winchcombe, or to development in the AONB. Others encouraged sympathetic innovation and diversity in style – to avoid turning the town into a pastiche vernacular “chocolate box”. And then there were ideas for improving the wording.

Statutory consultee response: TBC suggest the Plan makes clear that good design is a goal for the Sudeley Parish too – if it is.

Changes suggested by the Town Council as a result of the consultation: The Town Council believes that no change is needed,


saved Tewkesbury Borough Local Plan policy GNL2 that relates to design issues for major development proposals.

Policy 5.2 Winchcombe Conservation Area

This policy is designed to protect the designated Conservation Area, by referring decision makers to the characteristics identified in the Conservation Area Appraisal



The main theme of those responding was that no development should be permitted in the Conservation Area. Others were concerned that the policy was too vague and required more specific wording.

Statutory consultee response: No specific response

Changes suggested by the Town Council as a result of the consultation: No change is proposed except an improved reference to heritage assets, as suggested in the statutory consultee view on draft Policy 1.1


saved Tewkesbury Borough Local Plan policy HEN2 relates to the setting of conservation areas and is policy where in conformity with the NPPF.

emerging JCS policy SD9 and the emerging TBP policies HER1,2,3,4 relate to historic assets.

Policy 5.3 Illuminated Signs and Shop Facia

This policy sets out where illuminated signs will be appropriate, and where not



Some responding wanted to see fewer illuminated signs, others a more pragmatic approach to deciding whether such signs would be appropriate. This policy also triggered concerns about security lighting in residential areas leading to light pollution.


Changes suggested by the Town Council as a result of the consultation: The Town Council considered that no change was needed


saved Tewkesbury Borough Local Plan policies HEN2,6,7 and 17 and GNL13 where in conformity with the NPPF.

emerging JCS policy SD9 and the emerging TBP policies HER1,2,3,4 relate to historic assets

Policy 5.4 Extensions and Alterations to Existing Buildings

This policy sets out a policy to ensure that extensions and alterations complement the quality of the town and its surroundings through positioning, architecture and landscaping

This draft policy had extremely high levels of agreement


The main question in respect of this policy (and some others in this section) was whether the policy is any different from those that apply under the Tewkesbury Borough Plan and the national planning policy framework

Statutory consultee response: TBC suggest that extensions and/or alterations don't need to "reflect" the characteristics of existing...to be good design. Juxtaposition can often create the very best architectural dialogue between elements of buildings and their setting. Therefore as worded this is being unnecessarily and inappropriately restrictive, maybe wording such as ‘complements the character of’ may be more suitable?

Severn Trent Water: Extensions and alterations to existing buildings can increase surface water run-off, whilst misconnection of foul drainage to surface water sewers can something result in pollution incidents. Where practical to do so surface water run-off from extended roofs and other paved areas should be managed sustainably to reduce the undue flood risk of increase flow into the sewerage system and/or local water bodies. It is also vital that sufficient checks are made to ensure any alterations or new connections of foul drainage are not inadvertently connected to the surface water system, thus increasing risk of pollution due to misconnections.

Changes suggested by the Town Council as a result of the consultation: The Town Council considered that no change was needed except a modest improvement to the reference to “nearby existing buildings”


saved Tewkesbury Borough Local Plan policies HOU8 and 9, where in conformity with the NPPF.

Policy 5.5 Gardens

This policy looks to ensure that all new homes have worthwhile gardens



Responses mainly focused on the need for family homes to have “family-sized” gardens, possibly a minimum area defined by reference to the floorspace of the home. Other proposals were that parking on gardens should be prevented, as should large conservatories that effectively remove garden space.



Policy 5.6 Safety

This policy is intended to help avoid crime and the fear of crime, by applying “Secured by Design” principles; it also seeks to ensure that development is shaped where possible to improve safety for pedestrians and cyclists



Most of the responses provided details of dangerous points on our highway network



Policy 5.7 Resource Efficiency

This policy encourages energy and water use efficiency in all new developments



The main concerns of those responding were to rule out wind turbines altogether and look to encourage solar panels only where they would not be prominent


Severn Trent Water fully supports this policy relating to rainwater harvesting and grey water usage.

Changes suggested by the Town Council as a result of the consultation: The Town Council has amended the draft policy to reflect the need for care in the location of any solar energy generation – on roofs or on land.


saved Tewkesbury Borough Local Plan policies GNL8 and EVT1 where in conformity with the NPPF.

Policy 5.8 Flood Protection

This policy is designed to minimise surface water and run-off through requiring all development to meet Sustainable Urban Drainage System requirements



The main concern expressed was that any development which may add problems from surface water run-off, including from fields, should be refused (presumably irrespective of the application of the new SUDS approach, which is designed to avoid such run-off).

Statutory consultee response: TBC comment that this policy duplicates policy 1.3; but that is not the intention. Policy 1.3 deals with development in the flood plain; whereas this policy deals with all development and ensures that storm flows from the development are minimised through good drainage design

Severn Trent Water supports the need to ensure new development incorporates sustainable drainage systems to provide resilience against changes in rainfall patterns.

Changes suggested by the Town Council as a result of the consultation: The Town Council has added to the draft policy a requirement to identify how SUDS installations were to be maintained in the longer term

Policy 5.9 Waste Reduction

This policy, also contributing to sustainable development principles, is designed to help manage waste flows to increase reuse of materials and recycling

This draft policy had extremely high levels of agreement


No fundamental concerns expressed

Statutory consultee response: Severn Trent Water supports the effective management of waste to ensure inappropriate items (such as nappies, sanitary products, fat) are not disposed of into the sewerage system.

Changes suggested by the Town Council as a result of the consultation: The Town Council has proposed no change to the consultation draft policy.

Section 6 Consideration of sites for new homes

General points

The analysis of all consultation resources contains a general objection, with reasons, from 21 respondents (15 households) to all elements of Section 6 of the draft plan. The majority of these respondents own properties close to the sites that the Town Council chose to propose for development.

They are part of a total of 97 (of some 440 responses) objecting to Parcel 3 (Serviced Housing Development for Older People on land at Almsbury Farm). Two thirds of those objecting to this development also objected to the other site proposed for housing development (market housing on Parcel 1B for first time buyers and young families). Just under half of the 97 offered no ideas for alternative sites – suggesting that their objection was to the need for any development in Winchcombe at all. The ideas of the 51 who did suggest alternative locations for housing development are included in the analysis below.

Of the 254 positively agreeing with the proposed development at Almsbury Farm, only 15 were against West of Winchcombe and a further 10 had no view about it. This suggests that a significant majority of those responding were content with the proposed locations for meeting the needs of older people through a managed community, and meeting the needs of younger families through homes within easy walking distance of the Winchcombe Abbey School.

Suggested Alternative Sites

Of the 97 comments responding to the Town Council’s invitation to suggest alternative sites, 27 were generally opposed to any development and recommended that new housing should be built outside the two parishes. Twenty one responded that the town should be extended further beyond the current Redrow site in the Special Landscape Area, thus effectively merging Winchcombe and Greet into a single settlement. Another 7 suggested that Greet itself was a more suitable area for new housing.

Section 6 was designed to invite ideas about housing developments of more than 10 homes. The following table reflects the Town Council’s view on each of the proposals put forward by those consulted.

Withytrees Farm – replacing existing buildings This area is predominantly in light industrial use, with new single storey buildings. It is an AONB site, where housing would be obtrusive. It is in Greet rather than Winchcombe, and thus fails the test of general conformity with more strategic plans.

Land south of Enfield farm A prominent AONB site, rather further from the town centre than the proposed sites, and thus more likely to generate car journeys.

Telephone Exchange, Greet Rd Only a small area of land is ever likely to become available.

Telephone Exchange land should be reserved for a bowling green

Noted; not an alternative site for housing.

Unused Electricity Building off Back lane If unused, this would be a small infill site only.

Broadway Rd AONB land between Puck Pit Lane and Broadway Road was considered by the Town Council, but rejected given the potential landscape impact.

Kyderminster Road An AONB site that would have a more significant impact on the landscape than that proposed in section 6b of the draft Plan.

Littleworth area / old Scout Hut area / old chicken farm– not on AONB – needs a boost

It is in Greet rather than Winchcombe, and thus fails the test of general conformity with more strategic plans. Not compatible with sustainable development principles.

parcel 2b A small AONB site judged as having an important adverse impact in the landscape assessment.

4b would be a better site in terms of traffic flow, A small AONB site judged as having an

access to the football ground and provide a safe path to Vineyard St.

important adverse impact in the landscape assessment, while also adding to traffic across the narrow Corndean Lane bridge into the B4632 at a dangerous corner.

South side of town to reduce traffic issues, on C’ham Rd before old Hospital to ease commuting pressures.

All sites considered showed an important adverse rating in the landscape sensitivity assessement, and none were judged “deliverable” given ownership.

Behind / opposite / either side of Winchcombe School towards Greet

This is “parcel 7” – see below.

Parcel 7 is better because it involves (1) no loss of amenity, (2) is in keeping with neighbourhood given recent dev.s, (3) low visual impact on the wider landscape, (4) better road access, (5) pedestrian access to schools (6) no encroachment on AONB. It could have a mix of small homes and bungalows, and be separated from Gretton by a substantial belt of tree planting.

Even if this site were “deliverable” (in other words the landowner had indicated a willingness to see development take place) the Town Council would prioritise other sites which would better deliver the sustainable development requirement. Development on this site would have an “important adverse” impact on landacpae (according to the objective assessment commissioned by the Town Council). It would not be a suitable location for either the older persons’ accommodation, or homes for young families (the type of development identified as needed, given the recent boost in numbers of more general housing), due to its distance from the social and retail facilities in the town centre and from the primary school.

Fields adjoining Redrow, Gretton Road, This is “parcel 7” – see above.Fields between Bloor Dev and the Senior School instead of some of the proposed Green Space (Detail in 209)`

This land is more valuable to community as an extended sports field, helping to deliver health and wellbeing objectives.

Between Pennylands and school: room for 20-25 houses + a green space and public toilets

This is the same suggestion as above.

Greet Area (include shops and nursery provision) Use tree belts to separate from Winchcombe

Greet is not a service village, not is it a part of the “rural service centre” – which is how Winchcombe is designated in the Joint Core Strategy and draft Tewkesbury Borough Plan. So, new housing there could not offset the obligation those plans for delivery in Winchcombe.

Land near Becketts Cottage, Becketts lane This is a similar suggestion as above; similar response.

Harvest Home in Greet This is a similar suggestion as above; similar response.

Corndean Lane (4a, b,c ) would suit pol.s 4.1. 4.5. 5.2

AONB site judged as having an important adverse impact in the landscape assessment, while also adding to traffic across the narrow Corndean Lane bridge into the B4632 at a dangerous corner.

Rebuild Abbey View for sheltered housing as it on the bus route etc. – new homes will be needed for tenants now there

Infeasible due to multiple ownerships.

Parcel 4a, 4b, 4c and ground behind. Foot and cycle paths to town centre, access to play area, access to C’ham road

AONB site judged as having an important adverse impact in the landscape assessment, while also adding to traffic across the narrow Corndean Lane bridge into the B4632 at a dangerous corner.

Parcel 5 Greet is not a service village, not is it a part

of the “rural service centre” – which is how Winchcombe is designated in the Joint Core Strategy and draft Tewkesbury Borough Plan. So, new housing there could not offset the obligation those plans for delivery in Winchcombe.

Parcel 6 – (e.g. 1 bedroom apartments for young single people who cannot get independent accommodation)

Again, a Greet site, but meeting a distinctive need not previously identified in the Town Council’s research.

Parcels 5,6,7 See above for responses on each area.Parcel 9: (Western half above the flood line and be single storey, with tree planting)(better access to C’ham)

AONB site judged as having an important adverse impact in the landscape assessment, and increasingly distant from town centre shops and services.

Old Hospital, Old Boys school, Community Centre Site, Some on park by library (Abbey Fields?)

These are all potential infill sites, if owners chose to bring them forward, but not “deliverable” and therefore unable to be counted towards satisfying the needs identified in the Plan. The last two would fall foul of scheduled monuments protection.

Former Oaklands rest home, Gretton Rd Another potential infill/redevelopment; but response above applies.

Castleways site Now being redeveloped as a convenience goods store and car park.

Retirement complex would be better in former Giles Yard warehouse / Old Boys School

Insufficient land for such a complex to be economically viable.

Detailed Comment on Parcel 1A with 25+ names attached as Appendix 1

Since the Town Council did not specifically consult on this site, it would be wrong to bring a specific proposal forward at this stage

If needed, Parcel 1A (with a connecting road to B4362 through parcel 10)

Since the Town Council did not specifically consult on this site, it would be wrong to bring a specific proposal forward at this stage; the “connecting road’ would be expensive

Between Puck Pit Lane and B’way Rd / parcel 8 away from the flood area

See above under “Broadway Road”

Castle Street, orchard behind cottages owned by Sudeley Castle

Small site, which might be considered alongside the adjacent Almsbury Farm site

Gardens behind Olivers, Langley Rd AONB site judged as having an important adverse impact in the landscape assessment, and increasingly distant from town centre shops and services.

“The unmarked area next to the present building in Greet Rd”

This (we believe) is the Scheduled Ancient Monument site; not developable

Green site next to the Medical Centre as it almost a level route to Town

This site is about to become dedicated public open space in our growing town

Statutory consultee response:

TBC suggest that the land parcels on the proposals map need individually labelling so that they can be identified in respect of the policy that relates to them.

TBC suggest that the flood risk delineation could usefully distinguish between flood zones 3a/b and 2 (but our cartographer was not able to superimpose these clearly on the map accompanying the draft Plan)

TBC offer further thoughts on the Pan approach to flooding issues:

Whilst it is understood the focus was on sites in the statutorily designated Area of Outstanding Natural Beauty, and it was undertaken with a landscape and visual sensitivity priority. Given the sensitive nature of flood risk and the mention of Section 106 money in relation to flood management, I was surprised no reference of flood risk was incorporated in the selecting of preferred sites. The Almsbury Farm site has sections in Flood Zone 2 and 3 and as the development would be classed as ‘More vulnerable’ would need the application of the Sequential Test and most probably the Exception Test.

Proposal 6.1 in Parcel 3

This site is proposed as the best location to provide up to 75 units of housing as part of a serviced community for older people – possibly also including care facilities.

This draft policy had high levels of agreement, especially among those who did not take the view that all development should be ruled out in Winchcombe.


The main objections concerned: access through Vineyard Street, and the impact of additional car parking the proposal to develop land that is designated as Area of Outstanding

Natural Beauty and that offers a very attractive approach to Sudeley Castle’s drive and parkland

whether Winchcombe needs to provide so many homes, given the success of Bishops Cleeve (and Winchcombe) in attracting almost as many planning permissions as the draft Borough Plan proposed for the two Rural Service Centres

whether a housing complex designed for older people would best meet Winchcombe’s housing need – in particular if it was too “up market”

whether older residents (over 55s) would be capable of walking up Castle Street or Vineyard Street

the impact on the River Isbourne at times of heavy rain whether Winchcombe really needs a hotel, or a bowling green

The proposed list of conditions in the plan were generally supported, but further points were offered:

Cotswold stone should be stipulated Through route to Castle St could be facilitated via the long garden at the

back of Lloyds Bank Take steps to reduce surface water run-off

The new cycle path will be under pressure for use by vehicles; restrictions needed

The development should include a small health club, gym, and pool for older retired residents

A mix of bungalows and low cost housing for young people would meet local needs better

One frequent comment was that the former farm buildings should be converted for older people’s housing or some other use; and the fields behind should not be developed. The Town Council’s understanding, however, is that conversion of the historic buildings to residential use is not feasible if their heritage value is to be secured for future generations.

Statutory consultee response:

Cotswold Conservation Board: The Board does not raise a specific issue over the proposed site at Almsbury Farm given the site history and contained nature of the site.

Gloucestershire CC: the third bullet point could be improved to say “investigate areas of ecological importance and include measures to protect those areas and enhance the site’s biodiversity overall (1.1)”

Severn Trent Water comments that their sewer capacity modelling indicates that there is a small possibility that they may need to undertake some localised foul water capacity improvement immediately downstream of this development. Whilst they have no records of reported flooding issues in this area they would need to undertake more detailed assessments once they have received a new connection developer enquiry. If capacity improvements were required then these would be funded by Severn Trent with improvement work undertaken to ensure the development is not unduly delayed. We do not believe this should prevent the development of this site. They also assume that surface water would be connected to the adjacent watercourse in a sustainable manner to mitigate against downstream flood risk.

English Heritage comment that the re-use of the site for the purposes indicated in the Plan provides in principle a positive outcome for those heritage assets it contains and proposes to retain, and may even to some degree assist in the promotion of complementary objectives within the Plan such as boosting the viability of the Castle itself. At the same time it is necessary to be sure that those uses in their in-principle nature do not in themselves compromise the historic character of the site as part of the Conservation Area and in its relationship with the Castle. We appreciate that the site has previously been granted consent for development but that this has now expired. While this may provide a useful benchmark it is important to bear in mind that it may have been originally approved using policy considerations which are different to those in the National Planning Policy Framework which now exist.

Changes suggested by the Town Council as a result of the consultation: The Town Council has taken the site specific proposal for Almsbury Farm into policy 3.5, and incorporated a more comprehensive list of conditions that should apply to any development on this site. The revised list of conditions includes the proposal from Gloucestershire County Council, and reflects many of the concerns expressed about development on this site.

The crucial factor in the Town Council’s decision to include policy 3.5 in the submission draft Plan is that it is satisfied that the development described in that policy is likely to meet the Government's exceptional circumstances test which allows permission to be granted for major development in a nationally designated landscape only after assessment of :

a. the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

b. the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and

c. any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

Proposal 6.2 Market Housing on Parcel 1B for first time Buyers and Young Families

This site was proposed as the best location to provide up to 25 units of housing of a design suitable for first time buyers and young families, provided direct pedestrian access could be provided close to the junction of Barnmeadow Road and Orchard Road

This draft policy had high levels of agreement, especially among those who did not take the view that all development should be ruled out in Winchcombe.


The main objections concerned: No need for the development – given the permissions already granted in

Winchcombe and Bishops Cleeve Concern about a single age-group “ghetto” of young families Building on a greenfield/AONB designated site and loss of views from

existing homes Terraced housing would cause a loss of visual amenity Lack of identifiable access to an apparently landlocked site for vehicles or

on foot/cycle The risk that Winchcombe Abbey School would be oversubscribed Increased flooding; Natural Springs on Langley Hill and flash flooding

from snow melt Increased traffic (e.g too far to walk to Town Centre, extra vehicles)

The proposed list of conditions in the plan were generally supported, but further points were offered:

Stipulate new housing must match existing housing Stipulate the provision of a child play area Stipulate any terraced houses should have pedestrian access to rear

gardens Respect the topography of this sloping site Condition that there must be homes to rent All these houses should be for local people only (and affordable) Encourage terraced housing as they will look better than rows of

detached houses

Statutory consultee response

Cotswolds Conservation Board: site 1b West of Winchcombe is a greenfield site, outside the settlement boundary and in the AONB. The Cotswolds Conservation Board still need to be satisfied that the “exceptional circumstances” test of Paragraph 116 has been satisfied

The Board considers that 116 has not been correctly applied as it does not consider “convenience of access” as an “exceptional circumstance” to justify major development in an AONB. Paragraph 116 of the NPPF requires an application for major development within an AONB to be refused, unless there are exceptional circumstances (“exceptional” in this context connotes rarity and relates to the development itself and not any benefits to the future occupiers). There is a requirement through Paras. 115 and 116 of the NPPF to assess the need for the development (eg housing) in the AONB, the scope for developing elsewhere outside their area or meeting the need in “some other way” whilst giving “great weight” to conserving landscape and scenic beauty.

Therefore, further consideration in justifying a site selection should address the following questions (i) Given Winchcombe’s recent additional new housing and its constraints in relation to the AONB, is there the need/ability to accommodate more housing? (ii) By reason of Para.116 all options outside the AONB should be considered in greater detail not just in relation to Winchcombe, but also in respect of District and Joint Core Strategy level . Therefore, can housing need be met in “some other way” outside the AONB or even within the existing settlement thereby avoiding harm to the AONB?Brandon Lewis the Minister of State for Housing and Planning wrote to the Planning Inspectorate on 19th December 2014 to highlight the need for Councils to consider in their Plan preparation whether there are environmental and policy constraints which will impact on their overall final housing requirement. The Minister also highlighted the need to consider whether there are opportunities to cooperate with neighbouring planning authorities to meet needs across housing market areas. It may therefore be beneficial inthe light of this ministerial statement, to approach the District Council again to see what the expectation is of Winchcombe given its specific “environmental and policy constraints” in the delivery of new housing.

Gloucestershire County Council: the second bullet point could also be improved to say “investigate areas of ecological importance and include measures to protect those areas and enhance the site’s biodiversity overall (1.1)”.

Severn Trent Water do not envisage any issues accommodating the foul drainage from the 20-25 homes on this site. They assume that surface water would be sustainably connected to the watercourse to the south but as this is not a Severn Trent asset they have no comments.

Changes suggested by the Town Council as a result of the consultation: The Government's exceptional circumstances test would only allow permission to be granted for major development in a nationally designated landscape after assessment of :

a. the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;

b. the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and

c. any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.

The Town Council have not received enough information through the consultation process to be satisfied that all these three tests can be met by the proposed development of homes for young families just getting onto the housing ladder, on the area of land West of Winchcombe indicated in the consultation.

Recent housing developments in Winchcombe have delivered almost 100 new affordable homes in the course of just a few years – more than meeting the demand estimated in recent surveys. The Town Council takes the view that there is currently a lack of compelling evidence that new housing anywhere along the western edge of Winchcombe would pass the Government’s tests, so long as there are other potentially suitable sites for elsewhere in the Borough.

The position in the 2020s is, however, far from clear. The Town Council therefore proposes to commission work to explore the local need for new housing in the 2020s and bring forward amendments to the the Neighbourhood Plan for implementation in the period to 2031. The reference to this approach can be found in policy 3.1.

COMMENTS ON MAP ACCOMPANYING THE PLAN

Statutory body responses

GCC: Within the draft map accompanying the draft Neighbourhood Plan it is recommended that Salter’s Hill Key Wildlife Site is shown as an outlying constraint (details available from GCER at http://www.gcer.co.uk/ ). Traditional orchards should also perhaps be mapped and for this see second map on the webpage at http://ptes.org/get-involved/surveys/countryside-2/traditional-orchard-survey/orchard-maps/ . However in looking at the PTES maps we notice

http://ptes.org/get-involved/surveys/countryside-2/traditional-orchard-survey/orchard-maps/

http://ptes.org/get-involved/surveys/countryside-2/traditional-orchard-survey/orchard-maps/

http://www.gcer.co.uk/

that only orchards of poor or unknown quality seem to exist in the immediate area.

The Town Council is not aware of any remaining areas of traditional orchard land; Salter’s Wood is not in either Winchcombe or Sudeley Parish, and no policies in the plan would have any impact on that wood, to the best of the Town Council’s knowledge.

Annex A: List of organisations to which an email or letter was sent inviting a response the December 2014 draft Neighbourhood Plan

Organisation Address1st Winchcombe Scout Group

Email address only: [email protected]

Royal British Legion Email address : [email protected] held Winchcombe Conservative Club, Abbey Terrace, Winchcombe GL54 5LW

Castleways No longer in existenceCatholic Church Chandos Street, Winchcombe GL54 5HXChildrens Society St Peters Centre, Gloucester Street, Winchcombe GL54 5LUChandos & Dents Applewood,Corndean Lane, Winchcombe GL54 5NL

Cotswold Christian Centre

Gretton Road, Winchcombe GL54 5EE

Country Market Email address only: [email protected] Community House, 15 College Green, Gloucester GL1 2LZFriends of Winchcombe

Committee now changed –Chairman – 45 Gloucester Street, Winchcombe GL54 5LX

Brownies Email address only: [email protected] Guide Hall, High Street, Winchcombe GL54 5LJHandbell ringers Email address only: [email protected] Border Morris

Treasurer, 13 Huddleston Road, Winchcombe, GL54 5HL

Isbourne Quilters No address: J Warner 01242 602363Isbourne Singers Guide Hall, High Street, Winchcombe GL54 5LJFlood Action Group Email address only: [email protected]

Friends of St Peters St Peters Centre, Gloucester Street, Winchcombe, GL54 5LUFriends of Winchcombe Station

Winchcombe Station, Greet Road, Winchcombe

GWR The Railway Station, Toddington, GL54 5DTWinchcombe Medical Centre

Greet Road, Winchcombe, GL54 5LB

Member of Parliament Constituency office, 22 High Street, Tewkesbury GL20 5ALMethodist Church High Street, Winchcombe GL54 5LJNorth Gloucestershire Chess

Contact: Barry Whitelaw - No info – website only

North Godswold Homeopathic Group

Email address only [email protected]

Patients Group Medical Centre

Winchcombe Medical Centre, Greet Road, Winchcombe GL54 5LB

Police Gloucestershire Constabulary, No. 1 Waterwells, Waterwells Drive, Quedgeley, Gloucester, GL2 2AN

Radio Winchcombe Old Boys School, Gretton Road, Winchcombe GL54 5EE

mailto:[email protected]







Stanway House Stanway, Cheltenham, Gloucestershire GL54 5PQSt Peters Church Gloucester Street, Winchcombe, GL54 5LUTewkesbury Councillors

Cllr Ron Allen, Touchwood, Duglinch Lane, Gretton, Glos.Cllr Janet Day, Manor Farm, Market Lane, Greet, Glos.Cllr Jim Mason, 55 Abbots Leys Road, Winchcombe, GL54 5QX

Winchcombe C of E School

Back Lane, Winchcombe, Glos, GL54 5PZ

Winchcombe School Greet Road, Winchcombe, GL54 5LBSudeley Castle Sudeley, Winchcombe, Glos.Townswomens Guild Methodist Church Hall, High Street Winchcombe, GL54 5LJWinchcombe Art Club Email only [email protected]

Winchcombe Badminton Club

Sports Hall, 8 Gretton Road, Winchcombe, GL54 5EEEmail: [email protected]

Winchcombe Bridge Club

Day Care Centre, Langley Road, Winchcombe GL54 5QNEmail: jimoflichfield6|@hotmail.com

Winchcombe Bowls Club

Email only: [email protected]

Winchcombe Business Forum

Rapport Interiors, 15 Isbourne Way, Broadway Road, Winchcombe GL54 5NS

Winchcombe Concert Brass


Winchcombe Community Choir


Winchcombe Country Show


Winchcombe Cricket Club

The Pavilion, Corndean Lane, Winchcombe GL54 5NLEmail: [email protected]

Winchcombe Cycling Club

Gretton Hill Farm, Gretton, Glos GL54 5EW

Winchcombe Day Care Centre

Langley Road, Winchcombe GL54 5QN

Winchcombe Festival of Music and Arts


Winchcombe Football Club


Winchcombe Greening Group


Winchcombe Playgroup

Abbey Fields Community Centre, Back Lane, Winchcombe, GL54 5QH

Winchcombe Probus Email only: [email protected]

Winchcombe Probus Ladies

(see above)

Winchcombe Sports Gretton Road, Winchcombe GL545EE










mailto:jimoflichfield6%[email protected]



HallWinchcombe Sports Hub

Greet Road, Winchcombe, GL54 5LB

Winchcombe Table Tennis Club


Winchcombe Town Council

Abbey Fields Community Centre, Back Lane, Winchcombe GL54 5QH

Winchcombe Town Trust

2 North Street, Winchcombe, GL54 5JL

Winchcombe Welcomes Walkers

31 Delavale Road, Winchcombe, GL54 %YL

Winchcombe Womens Institute

Methodist Church Hall, High Street, Winchcombe, GL54 5LJ

Womens Institute Greet


Working Mens Club Abbey Terrace, Winchcombe, Gl54 5LL

Village Agent Email only: [email protected]

Alderton Parish Council

Clerk, 9 Bowler Road, Tewkesbury

Buckland Parish Council

Clerk, Grimmetts Orchard, Laverton, WR12 7NA

Dumbleton Parish Council

The Parish Clerk, Dumbleton Parish Council, 2 St Peters LaneDumbleton WR11 7TL

Gretton Parish Council Email only: [email protected] Parish Council Clerk to Parish Council, 5 Sheppey Corner, Stanton, Broadway

Worcs,WR12 7NEStanway Parish Council

Clerk to Parish Council, Lanes Farmhouse, Hill StanwayCheltenham, GL54 5PH

Toddington Parish Council

Clerk of Parish Council, 5 Okus Road, Charlton Kings, CheltenhamGL53 8DU

Tewkesbury Borough Council

Chief Executive, Council Offices, Gloucester Road, Tewkesbury GL20 5TT

Gloucestershire County Council

Chief Executive, Shire Hall, Westgate Street, Gloucester, GL1 2TG

English Heritage Chief Executive, 29 Queen Square, Bristol, BS1 4NDSevernvale Housing Society Ltd

Chief Executive, Shannon Way, Ashchurch, Tewkesbury, GL20 8NB

Gloucestershire Wildlife Trust

Chief Executive, Conservation Centre, Robinswood Hill Country Park, Reservoir Road, Gloucester, GL4 6SX

Disability Action Cheltenham

287 High Street, Cheltenham, GL50 3HL

Natural England Chief Executive, Foundry House, 3 Millsands, Riverside Exchange, Sheffield, S3 8NH





Environment Agency Legal Services, Horizon House, Deanery Road, Bristol, BS1 5AHBritish Telecom Chief Executive, Head Office, 1 Lochside View, Edinburgh EH12Severn Trent Water Chief Executive, 2 St John’s Street, Coventry, CV1 2LZCotswold AONB Conservation Board

Chief Executive, The Old Prison, Fosse Way, Northleach, Glos, GL54 3JH

Bromford Housing Chief Executive, Brabourne Avenue, Wolverhampton Business Park, Wolverhampton, WV10 6AU

Cottsway Housing Cottsway House, Avenue Tow, Witney, Oxon, OX28 4YG

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