Ma’am, as you will be very aware from our written and verbal evidence to this appeal we believe that the present, creaking, infrastructure in and around Fairford must be upgraded and modified before this, the Gladman development, or any more new developments, are approved. Due to the lack of an adopted Local Plan for CDC, Fairford, like a number of communities which are outside the AONB in the Cotswolds, has been targeted by speculative developers. The CDC Planning Officer was asked whether CDC still held to the figure of 260 new dwellings for Fairford in the years 2011 to 2031, which is quoted in the CDC Emerging Local Plan. The answer, qualified by the fact that their Local Plan has yet to be adopted, was yes. If this is the case, it is very hard to understand why the building of 317 new dwellings has been approved in Fairford over the past 12 months, on top of the 140 ‘holiday homes’ on the nearby Lakes site.
The core of our submission is that Fairford’s sewerage infrastructure cannot cope with the existing pressures of the population, and residents already fear the effects of the permitted new developments. The proposed Gladman development of 120 more houses would add still further to the present severe sewerage/drainage problem and result in more suffering for Fairford’s residents, both those existing and those moving to the The appellant has made it clear that should they win this appeal it is their intention to insist on their right to join their site to the current sewerage and drainage system.
Clearly, this is their right, but the exercise of this right comes with consequences. It is the responsibility of the planning system to consider these consequences very carefully and to protect residents from potential harmful outcomes. If this site were connected to Fairford’s present, overloaded, sewerage system, we submit that there will be serious negative consequences for the whole community. We know, here and now, that Fairford residents will, literally, be walking in sewage during periods of storm or extended wet weather. We know it and Thames Water, with their 3 tankers on standby, clearly knows it. We have had enough of sewage in our streets and homes, with all its dangers to if this development were approved, it is vital that adequate provision for surface water run off from the site be made. This requires a holding system (SUDS) and safe discharge to ground, sewer or watercourse in a way that doesn’t increase flood risk downstream. The appellant has not demonstrated this; in fact there is evidence i) that the groundwater level on the site in wet seasons is much greater than they show, and hence the holding capacity much less and ii) that the stream they propose to discharge into already floods around Mere in wet seasons, and the holding pond they propose will likewise already be full in wet seasons. In fact the FRA is inadequate, but neither CDC, EA nor TW picked this up, although there is a disclaimer at the end of the LK Consult report and the additional Hydrock report agrees that further investigation is required to establish actual ground water levels. We simply have no confidence that a SUDS system for the Gladman site will adequately protect residents, particularly in the light of the problems we hear are now being encountered on the Bloor homes site. There is also concern that the mains water problem will not be properly addressed.
Thames Water has clearly accepted that the supply to the potential site will be inadequate and yet no-one appears to be concerned. We find this totally baffling. Surely the secure provision of water is one of the fundamentals of statutory service supply? Even now some residents in Fairford are experiencing reduced mains water pressure. If there is any possibility that an increase in the number of properties supplied results in decreased water pressure elsewhere, then surely the development cannot proceed. The appellants may well say that they will agree to conditions which will enable the infrastructure to accommodate the additional ‘output’ from this development but, as we have detailed a number of times during this appeal, there are several other new housing developments in Fairford now approved. We have seen nothing to show that the Environment Agency and Thames Water are looking at Fairford’s infrastructure as a whole, but only on a case by case basis. However, we would submit that the EA and TW now have a clear picture of the size and rate at which Fairford is developing and the problems the town is encountering. Through this appeal, we are relying on the planning system to protect us from the consequences of yet more development. The service providers must be persuaded that they cannot approve this, or any new further developments, until they have studied, costed and fully implemented the additional sewage/water infrastructure which Fairford needs, in totality. Only then can we ensure that Fairford will be a sustainable community, both now and in the future. It is vital to us that outline planning permission not be granted, since even with Grampian conditions which do not allow occupancy before the surface and foul water situation is resolved, once the houses are built there will be overwhelming pressure to connect. It has been reiterated a number of times during this appeal that Fairford is regarded as a ‘sustainable’ community. This is based on the town’s facilities i.e. shops, schools etc. with figures and observations derived from past years. We believe that this statement must be qualified by the fact that the growth of Fairford has been gradual i.e. around 1% per year, and up until the past decade, the infrastructure has just about kept up with this growth. This is no longer the case. Once all the new houses have been built in the permitted new developments, and were this appeal to succeed, Fairford’s population would grow by around one third over the next few years and the town would very quickly become even more unsustainable. It will also be very difficult to integrate all the new people into the local community with such rapid growth – a healthy, functioning community being an important aspect of living in a country town such as Fairford.
The A417 in Fairford is a notorious bottleneck and is a major cause of concern with residents and passing travellers alike. We find it very hard to understand how Gloucestershire Highways can say that the additional traffic from over 430 new houses, plus holiday homes, can be accommodated on a road that is only 3m wide in many places due to the narrowing of the road between the bridge and the library, and due to the large number of cars which have to park on the road. The queues that users of the A417 through Fairford have to put up with on a day by day basis, together with the danger to pedestrians, is already totally unacceptable and the observation by Curtins that the road is only operating at 50% capacity is totally unrealistic. We also cannot understand how it is relevant that in the past 5 years no major accidents have occurred on this stretch of the A417, given that during that time there were no major entrances/exits onto this road, whilst there are now 2 entrances from which, we are told, there will be a minimum of 120 entrances/exits during the morning and evening peak hour. As outlined in our witness statement, the nature of the bend at the bottom of the hill, plus the seemingly close proximity of the planned pedestrian island to the corner, will exacerbate the problems caused by vehicles slowing to enter, and departing from the new developments, even with speed restrictions.
We have clearly shown that Fairford has very limited employment opportunities, which have been seriously reduced due to the recent loss of the second largest private employer in the town, Invertec, even though we have heard from Miss Collins that the overall employment in the Cotswold will continue to rise. In addition we have been told that more people equals more economic activity. Our submission explains clearly why this is disputed, but even if this were to be the case, over 5501 residents are already due to arrive in our town. The other problem we have detailed was the lack of realistic travel alternatives to transport by car. For those who do not live in the area it is possible to glance at the bus timetable and assume from this that Fairford has an adequate bus service. However, the timings of the buses do not work for those who wish to commute to Swindon, they are marginally useful for Cirencester, and certainly do not provide useful links to a station. These two towns are the main sources of employment in the area. The distances needed to be travelled and the dangers of the A417, also preclude all but the bravest of cyclists from attempting this mode of transport, and we simply don’t have the jobs for them – they will commute.1230 economically active residents accepted by Gladman on 120 houses. Pro rata this gives 306 on the Bloor/Linden Homes + Horcott road sites (170 houses); 230 on the London Road site (120 houses) and 42 on the Sunhill Close/Saxon Way site (22 houses). Total excluding Gladman is 578 and including Gladman is 766. The distance between the proposed development and Fairford’s shops is at, or over, the maximum advisable. The route requires pedestrians to cross, and is almost entirely along, the busy A417. It is therefore doubtful that many people will choose to walk into Fairford but will either use their cars, or more likely due to Fairford’s parking problems, shop out of town. This hardly constitutes a travel plan which meets the requirements of the NPPF and the Government’s widely stated aims of reducing our carbon footprint and meeting climate change objectives.
Of the two other infrastructural areas of concern that FPW has highlighted, we would again state that we have no further comments to add concerning Education, but stand by the comments included in our written submission, based on those made to us by parents with children either at the school or who will be going to it.
With regard to Fairford Surgery, we are at a loss to understand how CDC can accept the assurances from the NHS that the surgery can cope with this development when the written response is from the NHS Estates Dept. and is not a view formed on the basis of clinical assessment. The long waiting times of two weeks or more for an appointment to see a doctor are already a major concern to Fairford residents.
With regard to landscape, heritage and housing supply issues, Fairford Planning Watch supports CDC in their objection to this development and subsequent appeal. Specifically we fully agree with CDC that this development, if approved, will seriously damage the visual aspects of the western approach to Fairford and have a material and negative effect on the country setting in which the historic house, Burdocks, is presently seen and From a visual perspective, CDC has presented clear evidence that any development of the proposed site will have a serious, adverse, effect on the visual approach to, and exit from, the west of Fairford. Notwithstanding the existence of the Bloor/Linden homes development, any building on this site would directly reflect on the continuing potential of Fairford as a place tourists wish to visit – an important element to maintaining and attracting increased employment in the town. The proposal shows a lack of appreciation, or even care, for the sensitivities and importance of the site as the main entrance to Fairford and the Cotswold Water Park. There is certainly no understanding of the historic nature of the town or the unique value of the site as the last remaining fragment of main entrance to the town which signals the town’s long agricultural roots and its position as an important hub on the drove road network of west England.
We also concur with Mr Overall, that the new Linden/Bloor Homes development to the North of the A417, is situated on land which not only connects directly to the existing, more modern, housing on the west of Fairford, but by nature of the topography and position of the site, blends more easily into the landscape. We are, however, equally concerned with the effects that the Linden/Bloor Homes development will have on the town’s infrastructure (especially the sewerage), as with those which could potentially result from the Gladman proposals.
We totally reject and find it hard to understand, Mr Beardmore’s ‘personal’ claim that building on the south of the A417 will complement the Linden/Bloor Homes development and improve the visual aspects of this part of Fairford. We would submit that the exact opposite will be true and instead of the eye being drawn to an open, pastoral view of fields when approaching or leaving Fairford, the initial view would be of a suburban housing estate before entering a ‘canyon’ of new development at the entrance of the town. This is totally at odds with the existing historical character and views of Fairford and militates against all efforts to improve the attractiveness of the town for visitors and tourists – the main area for potential employment growth.
Much has been made of the fact that this area does not have any protection in terms of official designation and that no efforts have been made to provide any protection. We would suggest that the reason for this is that the site has always been well outside the development boundary of the town and so there was no perceived risk or threat to the landscape i.e. through development.
We again concur with CDC’s view, that the proposed development will have a serious and lasting, negative effect on both the setting of Burdocks, the importance of the house in a historical context and to the present owners living there. In particular, we find totally inexplicable Mr Beardmore’s statement that the introduction of a housing estate next to an historic site, set in open countryside, is acceptable and inevitable in the modern era. We would submit that the presence of the new development, so close to the boundary of Burdocks, has to have a major, negative, effect on its character due not only to visual changes but also to the effects of noise and light pollution. It would also constitute a permanent, irreversible change to the historic asset. Were one to take the view of Mr Beardmore, that one should start with the current situation and move into the future from there, then this would be to ignore all efforts to maintain and restore historic buildings, gardens and landscapes – not a view generally taken in the conservation world.
Policy and Planning
As we do not have the experience and knowledge to comment on the specifics of policies affecting decisions relating to this appeal, we are able to add little to this debate.
However, from what we have heard, the question of whether the CDC has been able to show, or not to show, that it has sufficient planned housing over the next five years, rests on opinion and argument: a situation which most of Fairford residents would find hard to understand, given the weight of other factors which could have such a negative effect on the town if this development were to be approved. All we can add to the five year housing supply debate is the fact that development of this site will not improve these figures as no work should be capable of being started until such time as Thames Water has planned, funded and implemented a surface and foul water drainage plan for the whole of Fairford – and this is unlikely to be completed within five years. The provision of affordable housing has been presented as a benefit to the town, but 136 affordable houses are already built, or are included in the developments already Fairford, the Fairford area or with connections to Fairford; this number rose to 94 in 2 Pip’s Field – 18; Bloor Homes – 52; London Road – min. 60; Horcott Industrial Estate – . In 2011 a total of 81 people were registered for affordable housing from 2014 (as stated in the Officer’s Report to the Kensington and Edinburgh site to the east of Fairford Application No. 13/03793/OUT). Thus the town’s affordable housing needs have already been met. One important quality of Fairford is its position on the edge of the AONB, the Cotswolds, the Cotswolds Water Park and, indeed, on the edge of Gloucestershire. This historic role goes back for centuries, back to a time when Fairford was in Mercia and Kempsford in Wessex, and beyond. It seems only fair that attention be paid to what is on the other side of that edge and in our case, that is Swindon, a rapidly growing town with the active intention to add 22,000 more homes in the next 12 years. There is sufficient housing within 10 miles of Fairford i.e. in Swindon, to cater for local employment needs; we simply do not need these extra houses. In building more houses in Fairford, which all are agreed will result in more commuting generally, and commuting into Swindon in particular, CDC is going directly against the stated aims of Swindon Council’s plans and the NPPF to reduce commuting. We are told that this is a plan led system. If planning is to mean anything it must mean building homes in the places where they are needed and which can sustain them, neither of which is true in this case – otherwise we are simply in a numbers game.
Ma’am, we have listened closely to 6 days of presentations, questioning and answers from a wide range of experts, during this appeal. Whilst we are not qualified to comment on some areas, the people of Fairford feel very qualified to comment on others, based on real life experience of living in the town. We thank you for the opportunity to present our case at this appeal and to you for listening. In conclusion, we would stress that we have heard nothing which conflicts with the original recommendation to reject this appeal. In fact, on matters of visual, historic and infrastructural matters we believe that the evidence presented reinforces this decision.
Ma’am, we would urge you to take local, informed opinion into account and reject this appeal, as this development is totally unsustainable and if allowed would be seriously damaging to Fairford and all its residents, now and in the future.
6 Aug 2014
We strongly oppose granting the appeal for the reasons detailed above. However, as we have been asked which conditions we would recommend, were the Inspector be minded to allow the appeal, then we propose the following conditions.
Development shall not commence until a drainage impact study and drainage strategy detailing any on and/or off site drainage works, including all potential drainage from other new developments, has been submitted to and independently (eg. CDC drainage engineers) approved in writing by the LPA in consultation with the sewerage undertaker, and fully implemented.
Development shall not commence until the mains water supply is secured so as to ensure that there are no detrimental effects on other residents of Fairford, such as inadequate water pressure.