West Dean PC Local Plan Consultation Response

West Dean Parish Council are pleased to submit the following report in response to the Forest of Dean Local Plan- Second Preferred Option.  These comments are based on detailed discussion of the preferred option paper and reflect the concerns and comments raised by Councillors at these meetings. It also reflects concerns from the general public gathered at a public consultation event held in Bream on the 24^th September.

In its current form the Local Plan lacks a vision for the Forest of Dean which is safe for its residents and the planet.  To be more specific there is a lack of infrastructure or provision for local employment, schools, health care, and green infrastructure including wildlife corridors, cycleways, footpaths, public transport, and alternative/green energy.  The lack of provision of these vital community elements means that the Local Plan fails to address how we sustain `strong, vibrant and healthy’ communities both now and in the future.  This lack of vision and ambition means that the FODDC will be unable to respond to climatic changes and societal changes.

The preferred option contains words that allude to the commitment of improving biodiversity and reducing carbon or encouraging development that doesn’t deplete natural resources.  This should be the overriding commitment in every section of the plan, and it should underpin all aspects of any proposal for any future development.  The UK has signed the COP26 agreement and there is no mention of this, and the targets enshrined in this agreement within the current Local Plan.  How is this to be addressed?

The Local Plan fails to describe an exciting or enticing vision for the future of the Forest of Dean, nor does it provide guidance in contributing to a strong, responsive, and competitive economy by supporting growth and innovation through local employment and attracting new businesses to the area and providing a mixed economy.  Nor does the plan (in its current form) contribute to the protection and enhancement of our natural, built, and historic environments. 

We urge the FODDC to explore the employment of an officer to bring inward investment into the area and attract employers, especially those developing green technologies, which would bring highly skilled employment opportunities to the area and prevent outward migration of people for such employment opportunities.

The Local Plan needs vision, ambition, and drive to meet the challenges of climate change, biodiversity loss and encourage moving to a low carbon economy that doesn’t perpetuate the acceptance of the current practice of driving to work and the provision of dormitory towns.  It also needs to reflect the reality of the science of climate change and acknowledge it’s impacts.  The mitigation and adaption that needs to be inherent in the plan is currently missing, nor is there detail that will embrace passive buildings designed for sustainability as well as providing space for increased homeworking within these design principles.  The local plan must be aspirational and seek to achieve the highest possible standards in every aspect of all areas covered within the local plan.

There are some big issues which require careful consideration and it’s likely that evidence-based assessments will be needed to identify where, what, and how development can be undertaken.  There may also be needs for a heritage assessment of the towns and villages within the Statutory Forest to be completed, although the Forest Edge South NDP covers six villages in some way for this type of assessment

The current preferred option lacks ambition and sophistication in its description of the types of homes we need to be building; these need to be homes fit for purpose now and in the future, no homes should be built that has a sole reliance on gas or oil for heating.  It inadequately addresses the real housing need, as detailed in the FODDC’s own housing needs assessment, instead it complies with the Governments algorithm for housing allocations is reliant on developers building for profit  and doesn’t seek to challenge the number of homes imposed on the authority.  This is compounding the issues being experienced by the already overloaded existing local services i.e., schools, medical support for an aging population, and sewage. Any new development should be designed to meet the capacity needed and not add to these issues.

This local plan needs to meet local needs and provide a vision for the future that provides for local employment, reduces the need for travel especially using private vehicles, that provides homes that young people can afford to buy or rent so that it will reduce the outward migration of our young people, and that enables community cohesion to develop whilst also providing for our aging population.

The version on which we are responding feels somewhat hastily cobbled together and seems to describe a vision of a plan; rather than a plan which guides and sets out the ambition and vision for the district over the next 20 years.  Another concern is that the Levelling Up Funding is centred on Five Acres, Hartpury and Cinderford yet the Local Plan intends to make Lydney the main focus of development, but the town doesn’t gain any benefit from this additional funding opportunity, although we do note the investment in the Lydney Harbour regeneration project.

WDPC endorses the CPRE paper, and the report written by Dr John Payne `Forest of Dean Local Plan, An Alternative View’ and would encourage the district council to embrace these documents and their thoughts in developing a plan which protects and enhances the natural environment, grows small scale and medium-sized businesses, and meets the housing needs of local population through affordable and accessible housing.

Question 1 – Do you agree with the Council’s approach for enhancing the role of Lydney featuring additional growth and improved facilities?

There was an understanding of the need to improve Lydney, but this should not be to the detriment of the other Forest Towns or the rich agricultural land which surrounds Lydney.  There are opportunities and benefits that improved facilities in Lydney could bring to Lydney and the surrounding villages with improved transport links, health, leisure, and shopping.  There is a sad lack of vision and investment in the infrastructure to support these ambitions, these have not been developed, planned, or costed and the current new build programme is supporting this concern.  There are already issues with commuting out of the area to work and the pressure this adds to an already overstretched transport network and the increased atmospheric pollution issues, already being monitored, at the network nodes is a cause for growing concern.

The general premise seems to be one of build the housing and employment opportunities will follow but this has the potential for Lydney to become a dormitory town for Bristol, Gloucester, Cheltenham and further afield!  The development at Higher Lydney Park already has connectivity issues with the rest of the town and the links to remove this barrier such as bus lanes, footpaths etc is still lacking meaning this area and its residents are left isolated and remote.

Question 2 – Do you agree with the Council’s approach for the development of land at Newent?

No : The document briefly mentions a masterplan for the development of Newent, but the current building programme seems to be developing a series of satellite communities to the town and not encouraging integration with the town centre, there would appear to be a lack of access for walking, cycling etc from these areas to connect with the town centre and this should be reversed in any subsequent build programme. 

There does seem to be a lack of vision and inward investment in this area, which much of the current build programme being located on good agricultural land, which should be retained for food production.

Question 3 – Do you agree with the Council’s approach of supporting mixed use development at major villages and towns?

WDPC supports the need for social housing provision within the towns and villages and would recommend the levels as being those identified with the parish housing needs survey. 

There is ambiguity in the document about what constitutes mixed development!

There needs to be a greater emphasis on community-led building projects that meets the needs of residents, environmental concerns and provides employment opportunities.

Question 4 – Do you support the Council’s approach for redevelopment for mixed uses of land at Beachley?

Not as described in the Plan. WDPC would welcome investment and opportunities in this area, but it will require investment in its transportation infrastructure prior to any further development taking place due to the location of this site, this would need to be done in conjunction with the MOD.  There are also concerns about potential flooding due to climate impacts for this peninsula and the mitigation measures that would be potentially required to protect this area and any development that may take place.

Question 5 – Do you support the Council’s approach for sustainable development at villages?

WDPC have concerns around settlement boundaries and the Statutory Forest designation and the protection status this could have on its further encroachment.  A Government Paper in 1947 in which the Wye Valley (now an ANOB), Woolhope Dome and the Forest of Dean Plateau (excluding the Severn side villages from Tidenham to Westbury) including an area defined around Cinderford as a Conservation Area implies that the Designated Statutory Forest should be at least recognised as a Conservation Area (supplied by Cllr Yeates).  Any development needs to be supported by high standards of design and build guidance, which is currently being consulted on by FODDC, (WDPC through the FES NDP has already commissioned a professional Design Guidance Document and we would recommend due attention is given to this) so this question cannot be answered until this document is finalised.

Question 6 – Do you support the Council’s approach for addressing climate change?

Not as described in the Plan. This question is very difficult to provide an answer due to the lack of a defined local plan and until this is more clearly defined WDPC feel unable to respond.  The ambition to be net zero by 2030 is noted but this ambitious target needs much more detail about build technologies, energy generation, thermal efficiency, transport networks and alternatives transport options etc to be provided. 

This element of the plan needs to be evidence based and guide developers and those undertaking improvement projects in greater detail of the requirements and standards that that need be met in any build and how residents personal transport options can be developed to be low carbon, to achieve this aim.  The science of climatic change needs to be fully integrated into the local plan to guide any future developments whether large or small scales works.

Question 7 – Do you support the Council’s approach for improving and protecting the environment?

WDPC in principle would support the protection and improvement of the environment but this is sadly lacking in detail and makes providing any comments difficult as it lacks any thought or specifics of how this will be achieved.

Question 8 – Do you agree with the Council’s approach to achieve a high standard of sustainable design?

No, because there is a lack of vision and any element of ambition in achieving the highest possible build standards that provide carbon neutral housing development.  A core element is the need to consider the local housing needs analysis, commissioned for all Gloucestershire authorities, with the emphasis being on providing the right homes in the right places to enable young people to remain in the district, this could be achieved through good quality social housing provision, which is not currently identified within the plan. 

Question 9 – Do you agree with the Council’s assessment of the strategy against the overall points from the plan vision?

No, the current plan is elusive and doesn’t have a strategy or vision for the future which builds community resilience to the climatic and biodiversity emergencies.

Question 10 – Do you agree with the Council’s approach for the scale and distribution of housing?

No, WDPC doesn’t believe that the algorithm used to base the plan on is fit for purpose and it should be challenged by FODDC.  The housing need should be based on the identified needs within the community and as identified in the housing needs survey already undertaken by GCC and the six local authorities.