In this report the East Midlands Regional Plan is shortened to EMRP and the Charnwood 2026 − Planning for Our Next Generation is shortened to Charnwood 2026 1. Brownfield/Greenfield/Farmland EMRP − Spatial Strategy Policy 3 (page 23) In assessing the suitability of sites for development priority should be given to making best use of previously developed land ....., contributing to the achievement of a regional target of 60% of additional dwellings on previously developed land......(as stated in Planning Policy Statement PPS3). EMRP − PPS11 (page 57) PPS11 advises that Regional Spatial Strategies should include targets for the proportion of new dwellings to be built on previously developed land. Achievement in the East Midlands has been improving and in recent years has exceeded 50%. This is lower than the 65% achieved nationally. There is often scope for improvement from past performance and so the national target of 60% of new housing development on previously developed land should also apply at the regional level in the East Midlands. Charnwood 2026 − Location of New Development (page 30) 4.12 In accordance with Government guidance, priority will be given to maximising appropriate opportunities for the development of previously developed land and buildings within settlement limits. The Region is already well behind both the Government target of building 60% of new housing on previously developed land and even further behind the 65% achieved nationally. The preferred options of building west of Loughborough will be totally on a greenfield site (the Garendon Green Wedge) in addition to a major road through Garendon Park. This will significantly worsen Charnwood’s poor record in relation to these policies. On the other hand, a development on the Wymeswold airfield brownfield site would make a major contribution to the performance of both Charnwood and the Region towards achieving national targets. Charnwood 2026 − Directions for Growth (page 98) The area on and around Wymeswold Airfield has also been appraised as it has been raised by a number of respondents to Core Strategy consultations as a suitable site for development as the airfield is a previously developed site. Baker Associates Report March 2007 (page 29) The size of Wymeswold Airfield at 155 ha could facilitate a development of significant size to support an appropriate level of facilities and public transport provision. It is clear that Wymeswold airfield (east of Loughborough) is the most appropriate site for housing development. This is a large brownfield location that could easily accommodate the required number of houses as well as providing employment land adjoining existing light industrial units both on the site and on Melton Road. The evidence base clearly points to option 6 instead of option 4 as the preferred option. Policy 3 of RSS8 specifies the sustainability criteria that must be taken into account when selecting land for development under the sequential approach. a) the availability and location of previously developed land: no brownfield sites are available in Option 4 (which is totally greenfield) whereas Option 6 is almost totally brownfield. Though Option 6 is more distant from Loughborough than Option 4 there is not a great deal of difference and Wymeswold airfield cannot be considered as remote. A future development at Option 5 would create what is more or less an SUE to the east of Loughborough. b) The accessibility of development sites by non −car modes and the potential to improve such accessibility to town centres, employment, shops and services: If a town the size of Mountsorrel was built at location 6 then, of course, bus services would be provided. These improved bus services would also be available to the villages of Wymeswold, Prestwold, Hoton, Burton on the Wolds and Cotes. The existing hourly No8 bus service to Melton Mowbray would be operated at more frequent intervals continuing to serve all the relevant Wolds villages as well as the new settlement. A new development at Wymeswold airfield would be large enough to provide shops and services Ð and some employment Ð not only to the town itself but also to the surrounding villages thus reducing the need to travel into Loughborough for a sizeable population. c) The capacity of existing infrastructure to absorb development: Roads west of Loughborough are already congested and cannot cope with existing traffic at peak times. Other developments already agreed (Shepshed landfill centre, an expanded truck stop and a widened M1) will add to this problem. Building a road from the A512 to the A6 will bring much more traffic onto these two already congested highways. A large settlement on the Garendon Estate would make the situation unsustainable ie the existing infrastructure could not absorb development. These problems would not arise with Option 6 since a new distributor road would be built and residents would be able to travel to Leicester via the A46 as well as north to Nottingham which would ease congestion in Loughborough d) Physical constraints on the development of the land including flooding: Wymeswold airfield is an ideal site for building since it is flat and firm with no flooding problems. The Garendon Estate site is undulating, has many long established trees, wildlife habitats and ponds. There is also a water course running through it that sometimes causes flooding problems. There are virtually no constraints on the development of Option 6 − but many with Option 4. e) The impact that the development of sites will have on the region’s natural resources and environmental assets: Building on the Garendon Green Wedge would have a detrimental affect on the regions natural resources and environmental assets. Valuable farmland, an area of scenic beauty and many wildlife habitats would be lost. The historic Garendon Park would suffer the unacceptable intrusion of a major road going through it, a highly congested A512 to the south, a widened M1 to the west, a major housing estate to the east and now a town the size of Mountsorrel to the north. The Wymeswold option would be on a brownfield site without any of the above problems. Funding from the development could also be used to improve the environmental assets on the Prestwold Estate and the surrounding Wolds countryside. f) The likelihood that the site can be viably developed: The landowner and developer have submitted plans to build on the Garendon Estate − so from this aspect the site can be viably developed. But this is also true for east of Loughborough. A developer has submitted plans for a large development on land at Cotes (Option 5) and this is supported by the landowner. When the Charnwood 2021 Core Strategy was being considered Prestwold Estates submitted a proposal to develop a Science Park at Wymeswold airfield together with expansion of the Wymeswold Industrial Estate and supporting housing development. They also provided for bypasses for the Wolds villages. So both east and west of Loughborough can be viably developed. g) The suitability of sites for mixed use development: Both sites are suitable for mixed use development but the Wymeswold site more so than Garendon because, with the former, there is already the Wymeswold Industrial Estate. The Garendon Estate is solely farmland. Mixed housing would be a clear asset to the Wolds settlements where affordable housing is a real issue. h) The HLAA Report states that ‘in sustainability terms, Wymeswold airfield is relatively isolated from facilities and services compared to the borough’s service centres. The site is not considered a sustainable location: This is totally misleading. Once a town the size of Mountsorrel has been built on the airfield then facilities and services will be available, including to surrounding villages where residents would no longer have to go into Loughborough. That is, the new town would become a Service Centre! The HLAA report suggests that CBC should conduct ‘a thorough review of sites located adjoining main urban areas, in other settlements or other locations before any recommendation is made regarding Wymeswold airfield’. It seems to us that no such review has been undertaken. We think this should be done so as to determine whether Wymeswold should (as an ‘other settlement’) be considered relatively more sustainable than it has been assessed at present because of its size and potential ability to accommodate a large mixed use development with appropriate facilities and public transport provision. Stakeholder Workshops September 2007 Workshop participants showed a clear preference for Alternative Strategy 3: A Priority for Safeguarding Environmental Features and ‘Green Development’. This emphasises the need to build on brownfield rather than greenfield sites. The preferred locations for housing developments identified by Workshop participants confirms this. The top four preferred locations were as follows:
CBC put a great deal of effort and resources into organising the Workshops ( which were held all over Charnwood) and these were successful. But the outcomes, which clearly identified the priorities of Charnwood Residents, have largely been ignored. A strategy of safeguarding environmental features and ‘Green Development’ has not been prioritised with most of the housing designated on greenfield farming land. Preferred locations for housing in the north of the Borough is east of Loughborough. But the preferred option put forward is west of Loughborough. It is very difficult to see how the Borough Council can justify asking Charnwood residents what they want in terms of the future development and then fail to include these priorities in the Core Strategy. Charnwood 2026 − Prosperity Matters (page 25) SO20: to encourage thriving and diverse sustainable rural enterprise and farming and the promotion of local foods and local energy sources. Charnwood 2026 − Renewables/Low Carbon Energy Generation (pages 66, 94) 4.118 evidence indicates that there is significant potential for wet biomass (residue from livestock farming), dry biomass (energy crops) across Charnwood. 5.65 A Renewable Energy and Low Carbon Feasibility Study has been conducted for Charnwood and identified West of Loughborough as an appropriate location for micro−wind energy generation and is close to significant areas of woodland to the West of the Borough. Wet biomass and dry biomass are also two forms of low carbon energy generation with potential in this location. EMRP − Protecting and Enhancing the Region’s Natural Heritage Policy 26 (p 72) The Region’s best and most versatile agricultural land should be protected from permanent loss or damage By building on productive farmland on the Garendon Estate there will be no potential for production of wet or dry biomass. Neither will west of Loughborough be available as a location for micro−wind energy generation. Once again CBC have completely ignored their own strategy and objectives. The preferred option fails to take into account future needs for food production and energy crops. Farmland around Shepshed and Hathern is productive and has a vital role to play in providing the UK with food and fuel. It is short sighted to destroy farmland that can never be replaced, particularly since it is clear that we will need these resources in the future as food and oil scarcities increase. Charnwood 2026 − Alternative Location C: West of Loughborough (p 121) This option includes some grade II agricultural land, however it would be less damaging to soil resources than the east of Loughborough option. This statement is entirely misleading. This option would mean building almost totally on grade II agricultural land, not just ‘some’. With the east of Loughborough option on Wymeswold airfield there would be virtually no damage to soil resources because most of the area is brownfield. It is clear from the above that the Wymeswold airfield brownfield site east of Loughborough should be the preferred option Ð not the Garendon Estate greenfield (and farming) site west of Loughborough. 2. Green Infrastructure/Landscapes/Woodlands EMRP − Spatial Strategy Policy 12 (p 42) Provision is made for the protection, development and enhancement of green infrastructure to contribute to the development of sustainable communities. Building on the Garendon Estate would be inconsistent with this policy since green infrastructure would not be protected, developed or enhanced. Indeed a greenfield area and farmland would be destroyed. On the other hand, building on the Wymeswold airfield brownfield site would complement the policy. A sustainable community would be created giving residents access to the Prestwold Estate and surrounding Wolds countryside EMRP − Regional Priorities for Green Infrastructure Policy 28 (p 76) Local Authorities, statutory environmental bodies and developers should work with the voluntary sector, landowners and local communities to ensure the delivery, protection and enhancement of Environmental Infrastructure across the Region. Such infrastructure should contribute to a high quality natural and built environment and to the delivery of sustainable communities. Within Local Development Frameworks Local Authorities, other agencies and voluntary bodies should work together to develop ‘green infrastructure plans’ based on character assessments of existing natural, cultural and landscape assets and the identification of new assets required to meet the needs of existing and expanding communities. Increase access to green space that can be used for formal and informal recreation, educational purposes and promote healthy lifestyles, without increasing pressures on sensitive sites. Building on the Garendon Green Wedge would curtail access to green space that is currently being used for formal and informal recreation, educational purposes and promoting healthy lifestyles. Residents in a new town on Wymeswold airfield would have access to the Prestwold Estate and the surrounding rural areas for all these activities. CBC have certainly not worked with Shepshed and Hathern communities to ensure delivery, protection and enhancement of Environmental Infrastructure. Identify delivery and funding mechanisms for the creation and future management of Green Infrastructure, including from the planning system and other funding sources such as EU funded Environmental Stewardship Schemes. The GPCPG Vision (published in Spring 2008) for the future of the Green Wedge (including Garendon Park) provides an opportunity to create and manage an exciting addition to Charnwood’s Green Infrastructure. EMRP − Green Wedge policies (p 143) Some parts of the Sub−area have established Green Wedge policies. Green Wedges serve useful strategic planning functions in preventing the merging of settlements, guiding development form, and providing a ‘green lung’ into urban areas, and act as a recreational resource. Although not supported by government policy in the same way as Green Belts, they can serve to identify smaller areas of separation between settlements. Provision will be made in Green Wedges for the retention or creation of green infrastructure and green links between urban open spaces and the countryside, and for the retention and enhancement of public access facilities, particularly for recreation. Charnwood 2026 − Green Infrastructure (p 49) 4.72 Green wedges are areas of open land which influence the form and direction of urban development, preventing coalescence and maintaining the physical identity of settlements adjoining Leicester and Loughborough. Green wedges have a positive role to play providing access from built up areas to the open countryside and creating links to the wider green infrastructure network. Building on the Garendon Estate would completely destroy the Green Wedge removing all the benefits of a ‘green lung’ and as a recreational resource as well as other advantages noted above. It would cause the loss of the physical identity of Shepshed and Hathern incorporating them into an urbanised greater Loughborough. This again contradicts stated policies in both the East Midlands Regional Plan and Charnwood 2026 Core Strategy. EMRP − Green Infrastructure and National Forest (p 155) In considering major development proposals, ...... , Local Authorities will coordinate the provision of enhanced and new green infrastructure. Strategic priorities include:
The preferred option of developing west of Loughborough would go directly against this policy since green infrastructure, and a Green Wedge, would be destroyed. On the other hand, developing Wymeswold airfield brownfield site would provide the opportunity to enhance the green infrastructure in the surrounding countryside. In the National Forest, Local Authorities should work with other agencies to promote the development of the National Forest in ways that generate environmental, economic and social benefits of both local and national significance by:
The National Forest is already committed to working with BIFFA at the Newhurst Quarry landfill site adjacent to Shepshed to regenerate the area both now and when landfill is complete. There are also discussions taking place to extend the current boundary of the NF to include Garendon Park and the Garendon Estate. This would enhance the distinctive landscape, natural, cultural and historic assets of the area. Building a sizeable town and a major road across Garendon Green Wedge would undermine this environmental vision. Charnwood 2026 − Green Infrastructure (p 49) 4.58 In Charnwood the strategic network of green infrastructure includes Green Wedges 4.60 The overall aim is to develop a comprehensive network of multi−functional green space across Charnwood to ensure a hierarchy of green spaces for people and for wildlife. To achieve this there needs to be a net increase in green infrastructure across the borough, targeted to those areas that are deficient. 4.62 There is also a need to provide recreational open space to contribute towards the health and well−being of the population. Evidence suggests that:
4.63 Evidence has identified needs for open spaces across the Borough ranging from district park provision of 20 hectares to local park provision of 3 hectares Destroying the Garendon Green Wedge would undermine the policy of developing a comprehensive network of multi−functional green space across the north of the Borough and would mean a net decrease in green infrastructure. 4.64 The Borough has a large network of public rights of way, including the Leicestershire Round long−distance footpath and parts of the National Cycle network. Opportunities to enhance the rights of way and local cycle network occur when significant new developments are being considered. There are well−used footpaths through the Garendon Estate that can be, and are, used for walking between Shepshed and Loughborough, as well as Hathern. These are used both for recreational activities as well as walking to and from work and for shopping trips. Being traffic−free the area is particularly suitable for children and dog walking and includes a rare bridleway. The area is part of the National Cycle network, which is also suitable for disability scooters. Building on the Garendon Estate will eliminate opportunities to enhance the rights of way and local cycle network. 4.65 There is a need to ensure that the landscape character is safeguarded and enhanced and that new development allows a continuity of character with the surrounding landscape. The landscape around Garendon Park and Estate is second to none. Rolling fields, many trees and woodland areas as well as a brook and ponds provide a resource that must be safeguarded and enhanced. This fits in well with the character of the surrounding landscape which includes the National Forest and the start of Charnwood Forest. To build a town and a major road at the centre of this wonderful landscape would destroy it completely. To adhere to policies and strategies in respect of Green Infrastructure it is essential the preferred option should be east of Loughborough on Wymeswold airfield not west of Loughborough on the Garendon Green Wedge. 3. Roads and Transport 3.1. Congestion 3.4.34 Address the immediate problems of congestion and safety in line with Government targets Proposals for Sustainable Urban Extensions (extending suburbs further out from the town centre) will generate considerable additional traffic. A key concern with the Preferred Option of building on the Garendon Estate is that this is probably the worst option when the impact of extra traffic on road congestion is considered. The A512 is already heavily congested at peak times and current plans will aggravate this. The new Science Park will bring more cars and business traffic onto the road as will the landfill site at Newhurst Quarry. Many vehicles from the landfill site will be heavy waste lorries and an expanded truck stop opposite Newhurst will add to the problem. Widening the M1 between J24 and J23 will bring more traffic and the decision to use the hard shoulder as extra lanes will inevitable mean more motorway closures, diverted traffic accessing the A512. The proposal in the Core Strategy to improve J23 to allow better access would actively encourage rather than discourage car use thus exacerbating the problem. There are similar concerns for the A6 through Hathern as well as other local B roads. The A6 is heavily congested at peak times and additional vehicles from the proposed Garendon development will aggravate the situation. No doubt heavy lorries to and from the landfill site will use the A6 as well as the proposed new road through Garendon Park. The A6 would also be affected in the event of closure of the M1 with vehicles exiting at J24. The new Dishley Grange industrial development will add significantly to traffic on the A6 including employee, delivery and heavy goods vehicles. Congestion in Loughborough is most severe when people living in the south and west of the town commute to work in offices and shops in the centre and to the industrial areas in the centre and north. Much of this traffic either crosses or traverses Epinal Way from the A6 or A512. Developing a major residential area to the west on the Garendon Estate will obviously exacerbate this problem, probably to the point of daily gridlock. The addition of perhaps 25,000 extra car journeys per day from a new town of 3500 houses, plus commercial, service and delivery vehicles, would be unsustainable. These problems would be avoided if housing development were directed to east of the town ie to Wymeswold airfield and the Cotes development (alternative locations 5 and 6 in the Core Strategy). An eastern distributor road could be built as recommended by Leicestershire County Council. Residents in the new housing developments would; have an alternative route to Leicester via the A46; be able to travel north to Nottingham on the A60; or come into Loughborough on an improved A60. Most through traffic would not enter Loughborough since the new inner ring road could be used. Problems of congestion in Loughborough would thus be resolved. 3.2. Financing Charnwood Borough Council argues against the eastern distributor road on the grounds of cost of building in the Soar floodplain and that a river crossing would destroy riverbank biodiversity. But a number of points need to be considered. 1. The A6 between Loughborough and Birstall is on the Soar floodplain and does not flood. Modern building techniques using fold culverts, sections of the road on piles etc avoid any flooding risk and ameliorate ongoing environmental considerations with an eastern distributor road and the link to the A60. 2. The proposed link road between the A512 and A6 (as proposed in the Garendon preferred option) goes through an area prone to flooding so would also be costly but without offering wider benefits. 3. CBC contends that the cost of building any new road would have to be met by developers through 106 agreements (though there are some doubts whether this would be the case because of restrictions on use of 106 funds). If allowed, the amount of finance available is based on the number of houses built. Only 3500 houses are planned for Garendon compared with some 9700 houses on the Wymeswold airfield and Cotes options. Almost three times the finance would be available for east of Loughborough compared with west of Loughborough. 4. Although costly to build an eastern distributor road it would provide access from any developments to the east of the town and mitigate existing congestion problems in Loughborough. A joint bid for funding from central government with a strong case argued by both County and Borough would stand a very good chance of success. Other Transport considerations Government policy is to move away from private cars to public bus and rail transport Ð as well as cycling and walking. It does not make sense to rank the alternative sites on the basis of present bus services. Bus operators would provide services to any large new residential development. It is difficult to see how sensible cycle routes could be built through a new town on the Garendon estate. On the other hand it would be possible and highly desirable to have a good cycle route alongside an upgraded A60 leading to the station, the town centre and the major employment areas to the north of the town centre. Residents in the east of Loughborough options would have easy access to Loughborough railway station currently being improved through the Eastern Gateway project. They would also be able to access the new Parkway railway station at Ratcliffe on Soar by travelling North towards Nottingham. On the other hand residents on a Garendon development would have to travel through Loughborough to reach the station. Building on the Garendon Estate would compromise cycle routes between Shepshed and Loughborough as well as destroying an area for walking in a traffic-#8722;free environment. Government policy of providing for more cycling and walking routes would therefore be negated. 3.4 Air Quality Air quality within a two−mile radius of J23 of the M1 is already poor and proposed developments will cause serious deterioration. Traffic generated by thousands of cars joining the A512 from the proposed Garendon development will increase air pollution Ð particularly as vehicles will often be caught in traffic jams. The new landfill site situated close to J23 will have air quality impacts as will heavy vehicles using the site. More lorry fumes will be generated from the expanded truck stop Ð located near J23. Widening the M1 will generate more traffic and plans to vastly increase the number of freight and passenger flights from East Midlands Airport will significantly worsen air quality over Shepshed and adjoining areas. Do we really want to develop a major housing estate in an area that will have such severe air pollution? 3.5 LCC and CBC Transport Studies LCC (which is the authority responsible for road building and maintenance) commissioned two key transport studies in 2006 and 2007. The 2006 study found that the only acceptable solution for a SUE would be located to the east of Loughborough with the construction of an Eastern Distributor road likely to deliver the required degree of mitigation. Given uncertainties concerning whether this distributor road could be funded, the option was considered again in LCC‘s subsequent 2007 report. However, the 2007 study similarly recommended that a SUE should be constructed to the east of Loughborough and found that this development could, notwithstanding higher costs, fund the proposed eastern distributor road. In any case funding was not necessarily restricted to contributions by developers and could be sought from other sources. Despite these earlier findings, however, the 2008 Transport Assessment commissioned by CBC concludes that the eastern distributor road would not be financially viable and instead recommends SUE developments to the West of Loughborough. But the 2008 report insufficiently explains why different transport models are used in this study. The earlier LCC studies (based on the Leicester or Loughborough to inform LCC‘s input into the draft Regional Plan. Accordingly, the 2008 report should go into much more detail than it does do in departing from this otherwise reliable transport model. That is, there is insufficient detail − either in the 2008 report or the Core Strategy report that relies upon it − as to why the earlier studies were ‘inequitable’ and ‘inconsistent’. At paragraph 2.1.72 − 2.1.73, the 2008 report attempts to distinguish itself from the earlier LCC reports on the basis that the latter were primarily focused on ‘addressing the existing issues of the town’ rather than ‘the implications of the development’. However, given that the earlier studies were specifically designed to examine the viability of SUE extensions and that the East Midlands 6C’s Congestion Report (discussed at paragraphs 4.1.12 − 4.1.16) had found that Loughborough was the town worst affected’ by traffic congestion in Leicestershire, this distinction is, without further detail, difficult to maintain. The 2008 report also discounts the viability of the eastern distributor road on the basis of cost (see for example, 2.1.41; 2.1.62). CBC also explicitly rely on this submission in the Core Strategy report (paragraph 4.48, p. 46) when they state ‘there is insufficient certainty about the deliverability of on eastern distributor road’. Again, neither the 2008 Transport Assessment Report or the Core Strategy report go into sufficient detail as to the foundation of this claim. This is significant because the earlier 2007 LCC report specifically found that the eastern distributor could be funded largely through the development of a SUE to the east of Loughborough. The 2008 report does not provide any detailed explanation as to why this proposal ought to be considered cost ineffective or ‘insufficiently certain’. Furthermore, whilst the earlier LCC studies had found that the eastern distributor road was the best solution for resolving traffic congestion in Loughborough, the 2008 report concludes otherwise, stating (at paragraph 2.1.55); MVA Consultancy have considered the model outputs identified in the 2006 LCC study and do not believe that the package of measures presented in the 2006 study fully mitigates the effects of the development east of Loughborough and provides the level of relief suggested in the LCC report. There appears to be, however, very little information provided in the 2008 report as to the foundation of this belief. One of the primary reasons provided for this departure (at paragraphs 8.1.55 and 10.1.40) is that any eastern distributor would be disproportionately prone to flood risk as it would need to cross the Soar floodplain. Accordingly, the 2008 report assumes that any eastern distributor would likely be ‘unavailable due to flooding’ and therefore ‘likely to result in only a small amount of development traffic being removed from the town centre’ (10.1.40). The 2008 report finds that ‘any new distributor road would need to be designed so as to not impede flood conveyance and to remain operational at times of flooding’ (SFRA, paragraph 5.2.3, p.50). That is, so long as the road is appropriately designed there is no necessary reason to assume that the road will be unavailable due to flooding. Consequently, CBC cannot readily discount (as they do) the congestion benefits of an eastern distributor on the basis of flooding. The 2008 transport assessment concludes by recommending that further studies be undertaken in order to consistently appraise each of the development options. The recommendations (at 10.1.57) include, inter alia, ‘an assessment of the implications of joining Option6 to Options 7 & 8 to the west of the town’ and ‘a detailed appraisal of the congestion effects of the North Leicester options on Leicester’. CBC does not seem to have pursued these recommendations. Further study on the implications of joining sites to the east and west of Loughborough is of some significance given the cost and mitigation benefits that the 2008 report accords to the option as against the east Loughborough development options. Furthermore, given the marked departure of the 2008 report from the findings of the earlier LCC studies, the proximity of the South Charnwood development options (Report, p.99 − aa3) to the urban area of Leicester and the conclusion of the 2008 report that ‘it is important that the impacts of each option on Leicester must be further weighted into the results obtained for the Charnwood area alone’ (paragraph 10.1.52) it would seem that CBC should undertake further assessment of the Leicester impacts prior to approving the Core Strategy. PPS 12 makes it very clear that in order for core strategies to be justifiable, they must be ‘founded on a robust and credible evidence base’ (PPS12, paragraph 4.36). As it stands, we question the credibility of the evidence base on which a decision is to be taken by CBC to adopt a core strategy. 4. Biodiversity EMRP − Regional Core Objectives Policy 1 (p 15) To achieve a ‘step change’ increase in the level of the Region’s biodiversity through: Garendon Estate and Park as well as the surrounding area have abundant biodiversity and wildlife habitats. Section 74 habitats include wet woodland, lowland neutral grassland, ponds and hedgerows. Blackbrook Local Wildlife Site, woodland belts such as Hathern Drive and the disused railway line and hedgerows such as Pear Tree Lane are other features. The SSSI at Oakley Wood (SK485217), which is also ancient woodland, is in the area as are two Local Wildlife Sites. Another four Local Wildlife Sites are in close proximity. Building a town on the Garendon Estate would decrease the level of the Region’s biodiversity and mean a net loss of priority habitats and species. Biodiversity is not as big an issue on the Wymeswold airfield brownfield site. Being on previously developed land wildlife and flora have not been established long term as they have on Garendon. Most of the hedgerow habitat cited in the evidence base for Wymeswold is, in fact, situated in the Melton Road area, well away from the proposed development site. Developing this area would provide funding for biodiversity projects in the surrounding Wolds countryside as well as in the Soar Valley. EMRP − Regional Priorities for Natural Resources (p 70) The area of statutory sites important for biodiversity in the Region is well below the national level. Overall there has been a significant decline in biodiversity and to compensate for past losses, regional habitat restoration and creation targets through the delivery of ‘green infrastructure’ needs to be proportionally greater than in other Regions. The particularly low regional proportion of woodland cover offers a specific opportunity for habitat creation. EMRP − Regional Priorities for Biodiversity (p 77) 3.3.15 Only 2% of the Region’s surface is covered by legally designated nature conservation sites, compared to the national average of 7.5%. This is one of the lowest of any Region in England. The East Midlands has probably lost more wildlife than any other Region in England, with and average of one species per year becoming extinct at the regional level over the last century. Given the major declines in regional biodiversity, action is required to:
It is difficult to see how destroying a long established area protecting biodiversity and wildlife would reverse the decline in nature conservation in the Region. The East Midlands has lost more wildlife than any other Region − and the preferred option of building on the Garendon Green Wedge will accelerate this trend causing a net loss of Biodiversity Action Plan habitats and species. Developing the Wymeswold airfield brownfield site would provide
the opportunity and funding to deliver large−scale habitat
creation at a landscape scale in the surrounding Wolds countryside as
well as the Soar River Valley. Compared to other parts of the East Midlands the Borough contains significant areas of ecological interest mainly focussed on the Charnwood Forest and the river valleys of the Soar and Wreake. Some of these areas are in a poor state and face continued pressures from future development. Regionally significant biodiversity corridors along the river valleys pass through the Borough. There are issues associated with the decline and fragmentation of key biodiversity corridors. Charnwood 2026 − Spatial Objectives, Places & Environment Matter (p 23) SO12: To maintain and enhance the range of ecological sites, habitats and species found in Charnwood and seek to deliver biodiversity gain and reverse habitat fragmentation Charnwood 2026 − Green Infrastructure (p 49) 4.61 Compared to other parts of the East Midlands, the Borough contains significant areas of ecological interest. These are mainly focused in the west of the Borough, around Charnwood Forest, and along the strategic river corridors. It is important to ensure that this ecology is protected and where possible there is a net increase in biodiversity particularly in the east of the district where biodiversity is poor. This will mean ensuring existing wildlife sites are adequately protected; improving connectivity between habitats within areas of strong biodiversity and ensuring weaker areas of biodiversity are better connected with the wider biodiversity network. A major weakness of the Charnwood 2026 Report on biodiversity is its concentration on Charnwood Forest and the strategic river corridors. Little mention is made of the important Garendon Park & Estate biodiversity and wildlife site. This area is a major environmental asset to Charnwood Ð and has been in existence for many years. The Leicestershire and Rutland Wildlife Trust Biodiversity Action Plan identifies local and national priority habitats and species and sets targets for their conservation. Some of these priorities are field ponds, hedgerows, bats, broadleaf and ancient woodlands, neutral grassland and barn owls, all of which are present in the Garendon Green Wedge and surrounding countryside. Building a town on the Estate would destroy biodiversity on this important site as well as surrounding areas. Although there are no plans to build on Garendon Park there will still be major impacts on wildlife habitats and biodiversity in the Park. A major road will traverse the Park. To the West the M1 motorway, which is scheduled to be widened, impinges on the Green Wedge. South of Garendon Park the heavily congested A512 would be even more congested if the option to build west of Loughborough is chosen. A new landfill site across the road from the Park will emit smells and increase HGV traffic. But worst of all will be a new town of 3,500 houses to the north of the Park causing thousands of extra car journeys through the Park as well as increasing vandalism to the heritage buildings there. All these planned developments will have serious detrimental effects on biodiversity and wildlife habitats. Building east of Loughborough on Wymeswold airfield would avoid most of these menaces to biodiversity and wildlife. There would be some negative impact on riverbank biodiversity, particularly by an eastern distributor road. But using modern techniques of road building that protects wildlife could mitigate these problems. In any case similar impacts would be felt from the west of Loughborough option by a road through the Garendon Estate and Park. At present there is an exemplary and effective biodiversity corridor from Charnwood Forest in the south, through the National Forest across to Garendon Park and Estate and stretching to countryside in the north, including the wildlife sanctuary of Whatton House Estate. A town in the middle of this corridor would destroy its effectiveness and seriously weaken the connections with the wider biodiversity network. Charnwood 2026 − Green Infrastructure, Creating linkages (p 51) 4.68 Habitat creation and enhancement will be prioritised to those areas where it would maximise biodiversity benefits and reverse habitat fragmentation. Building west of Loughborough on the Garendon Green Wedge would be a complete reversal to this promise to prioritise habitat creation and enhancement. 5. Flooding Issues Government legislation covering flooding matters (PPS25 2007) says that local authorities, through an SFRA (Strategic Flood Risk Assessment), should inform the sustainability appraisal process so that flood risk is taken fully into account. The current Sustainability Appraisal summary doesn’t adequately address flood avoidance. PPS25 goes on to say that a site specific Flood Risk Assessment must be produced if a development may increase flood risk elsewhere. This is definitely the case with the Garendon Estate Option, where a sizeable new development would cause additional flood risk at existing communities in Thorpe Acre. It should be noted that if a new road is planned through a flood plain then the Exception Test procedure must be applied to prove the proposal as "essential infrastructure". Site−specific references in the Consultation Report are as follows: The Garendon Estate (Option 4) Despite the area being categorised as Flood Zone 1 with "no flooding issues and no access constraints" summarised in the Option C table, any large development will inevitably lead to increased risk of flooding to Thorpe Acre, an area with existing flooding issues. The Black Brook itself, in climate change modelling, is categorised as Flood Risk 3B. There are several references throughout the SFRA Report to the flooding risks and a recommendation to undertake flood−breaching models for the embanked sections of the Black Brook in that area. The SFRA states that, so far, there has been no evidence base prepared for the Oxley Gutter. Wymeswold Airfield (Option 6) The proposed site itself, as an elevated site, must be truly categorised as Flood Risk1 to be consistent with the Garendon rating. The actual current rating emanates solely from perceived access issues. The "significant concerns raised about flooding" revolve solely around the pretext that an eastern relief road "would be severely limited in a flood event if the road is liable to flood". This is arrant nonsense; no new road would be conceived in this manner. The Council only has to look at the Quorn Bypass, built through the Soar Valley in the early 90’s, with its elevated sections in relevant areas. Indeed, this road would link with the new eastern relief road whose presence would not significantly impact on the River Soar and its environment, once constructed. The Consultation Report is unreasonably selective in applying flooding considerations, referring to an SFRA report which itself needs a lot more work to be applied appropriately at candidate development site level. The 2008 CBC Transport Study suggests that any eastern distributor road would be disproportionately prone to flood risk, as it would need to cross the Soar floodplain. Accordingly, the 2008 report assumes that any eastern distributor would likely be ‘unavailable due to flooding’ and therefore ‘likely to result in only a small amount of development traffic being removed from the town centre’ (10.1.40). The SFA finding is that &8216;any new distributor road would need to be designed so as to not impede flood conveyance and to remain operational at times of flooding‘ (SFRA, paragraph 5.2.3 p.50). That is, so long as the road is appropriately designed there is no necessary reason to assume that the road will be unavailable due to flooding. The example of the adjacent Quorn Bypass mentioned above shows that flooding need not be a problem. CBC cannot readily discount (as they do) the congestion benefits of an eastern distributor road on the basis of flooding. Furthermore, in assessing the disadvantages of the Wymeswold option in the Core Strategy report (p 133), CBC state that ‘significant concerns have been raised about flooding due to the road infrastructure that would be require to cross the floodplain to reach the town centre’. Whilst this is not incorrect, it does imply that the Wymeswold development site itself has ‘significant flood risk concerns’. However, the alternative Wymeswold site and the preferred west Loughborough site are both found in the SPRA to be situated within Flood Zone 1 and therefore directly comparable in terms of flood risk, but for the sequential assessment of the proposed eastern distributor road (p 87 − 88). Further PPS25 assessment of road infrastructure required in the preferred and alternative options is necessary in order for CBC to justifiably differentiate the sites on the basis of flood risk. 7. Heritage EMRP − Regional Priorities for the Historic Environment Policy 27 (p 73) Recognise the opportunities for enhancing existing tourism attractions and for developing the potential of other areas and sites of historic interest as part of Green Infrastructure, having regard to potential impacts on biodiversity EMRP − Protecting and Enhancing the Regional Cultural Heritage Policy 26 (p 72) EMRP − Regional Priorities for the Historic Environment Policy 27 (p 72/73)
EMRP − Sub−Regional Core Strategy (p 138) 4.2.10 A development Objective is to protect, enhance and increase the Three Cities Sub−area’s stock of strategic environmental and cultural assets Charnwood 2026 − A Spatial Strategy for Charnwood (p 17) With over 1,000 listed buildings, 36 conservation areas, 21 scheduled ancient monuments and 3 historic parks and gardens, the Borough has a rich built heritage. There are, however, problems resulting from development pressures and neglect. There are some long−standing issues with a number of historic structures and buildings that have been placed on the ‘at risk’ register. Charnwood 2026 − Directions for Growth (p 36) 4.24 Loughborough and Shepshed sit within an environmentally sensitive area, with Charnwood Forest to the south and the Soar River corridor to the east. These sensitive environmental areas have been a key consideration in the appraisal of the alternative locations for growth in north Charnwood. It is proposed to secure public access to the Garendon Park & Historic Gardens. Charnwood 2026 − Alternative Location C: West of Loughborough (p 121/122) This option would have an impact on the setting of Garendon Historic Park and Garden and thus has the worst impact on historic or archaeological interests. Building a 3,500 house new town on the Garendon Estate would seriously damage the setting and viability of Garendon Park & Gardens. To the south of the Park is the A512, a major route in and out of Loughborough, which is already congested at peak times. The additional cars from the new town would make this road a logjam of traffic. To the west of the Park is the M1, which is to be widened in the future with one side impacting even more on the Garendon Green Wedge. The main impact, however, would be a road through Garendon Park to service the new town. All this extra traffic will clearly have a significant negative effect on local wildlife as well as bringing a great deal of pollution to the Historic Park. To the north of Garendon Park would be the new town with a population of perhaps 10,000 residents most of whom would use their cars to go through the Park. At present this area (the Garendon Estate) provides an appropriate setting for the Park with open fields, historic woods, hedgerows and ponds. The attached map shows how this setting would be destroyed by the proposed development. How does this comply with the above stated policies and strategies to protect and enhance the Regions historic assets? The Core Strategy fully recognises that this development ‘has the worst impact on historic or archaeological interests’ but then fails to take this into account when choosing the preferred option. English Heritage recognise the importance of Garendon Historic Park & Gardens. CBC is not following the guidance from English Heritage, which is summarised in paragraph 3.3.8 of the East Midlands Regional Plan. This Core Strategy proposal threatens the Listed Status of Garendon Park. Charnwood Borough should be proud to have this National Heritage site in the Borough. It is a valuable asset and should be protected at all cost. Charnwood 2026 − Regeneration (p 89) 5.49 The proposal to develop land to the west of Loughborough for a sustainable urban extension provides an opportunity for communities in west Loughborough to access Garendon Historic Park & Gardens and other green infrastructure networks that will assist with health and well−being. Charnwood 2026 − Sustainable Urban Extension to Loughborough (p 94) 5.64 It is proposed that the urban extension will include provision for comprehensively planned green infrastructure to provide a network of multi−functional green spaces including parks and recreation areas, informal areas, natural and semi−natural habitats and green corridors. Green infrastructure will be an integral part of the development, and development west of Loughborough would secure the provision of a new country park to meet identified deficit in open space in the north of Charnwood. This park would provide full public access to Garendon Historic Park and Garden and the retention and restoration of the park and the listed building within it, for the benefit of new and existing residents. There will also be improved links to existing green infrastructure, such as Charnwood Forest. There is a deficit in open space in the north of Charnwood yet CBC is proposing a huge building development on what open space there is. The idea that opening up Garendon Park will create more open space is of course ludicrous Ð the open space is already there − and some people use it. The Garendon Estate already provides a traffic−free rural area for communities in west Loughborough, Shepshed and Hathern to improve their health and well being, but if Option 4 goes ahead, this will be destroyed. Opening up Garendon Park as it stands to the general public would be a disaster. Many of the historic monuments in the Park have already been vandalised and would be destroyed altogether if a town the size of Mountsorrel were to be built adjacent to it. Wildlife habitats would also be disturbed and no doubt many of the trees damaged. Car Parks would need to be built on the Park for use of outside visitors bringing even more cars to the area. We would question the health benefits to be gained from a Park with so much air pollution all around it. This does not mean that Garendon Park should not be open to the public at some stage. An area like this should not be the sole preserve of a private owner. But opening the Park should be done in a controlled way with park wardens based there and regular maintenance of the historical assets. The relatively small size of the Park itself would not support such resource inputs Ð but if it were integrated with the remainder of the Garendon Estate then it might become a viable proposition. The visionary and independent report "Securing Garendon Estate & Listed Park for Future Generations͂ provides a feasible strategy for assuring the long−term viability of the area. Charnwood 2026 − Alternative Location F: East of Loughborough (p 133) There would be an impact on Prestwold Hall and registered historic park and garden. Building on Wymeswold airfield would have similar impacts on Prestwold Hall and the registered park and garden − but not to the same extent. Prestwold Park would have open countryside to the south, west and east with the new built up area being only to the north. Traffic problems would be nowhere as bad as at Garendon and there is already a car−testing track on the park. Developers could provide 106 funds to support maintenance of Prestwold Hall and Park and help it to become a positive asset to the new town and the villages in the area. Building on the Garendon Estate would undermine many of the ‘heritage’ policies and strategies contained in both the East Midlands Regional Plan as well as the Charnwood Core Strategy. The preferred option should be Wymeswold airfield or Cotes/Hoton, not the Garendon Estate. 7. Settlement Identity EMRP −Sub−Regional Core Strategy (p 138) 4.2.10 To minimise the impact of development on the coalescence of settlements and on the more sensitive parts of the fringes of the Principle Urban Areas Charnwood 2026 − Places and Environment Matter (p 23) SO9: to protect the historic environment and identity of the Borough‘s locally distinctive towns, villages and neighbourhoods Charnwood 2026 − Development Strategy for Charnwood (p 25) 4.5 This consultation has informed the proposed development strategy which is based on a priority to safeguard environmental features and the identity of individual settlements. Charnwood 2026 − New Housing and Employment Development (p 86) 5.38 This scale of development could be accommodated within the landscape without compromising the settlement identity of Shepshed and Hathern. It is clear that in both the East Midlands Regional Plan and the Charnwood 2026 Core Strategy preservation of settlement identity has high priority. Building on the Garendon Estate will totally contravene these policies and objectives. Loughborough, Shepshed and Hathern would be swallowed up into an urbanised Greater Loughborough. To suggest that the development ‘would not compromise the settlement identity of Shepshed and Hathern’ is arrant nonsense and the statement should be deleted from the Core Strategy. When assessing the impact of any option against the objective of maintaining settlement identity it appears that CBC have used the indicator "does the proposed development increase the vibrancy and viability of existing settlements? ". This is rather odd in that in the Sustainability Appraisal Framework this indicator is a primary objective, and that maintaining settlement identity is one sub−objective of this primary objective together with 4 other sub−objectives. However in the Appraisal itself, under this primary objective, comment is only made about settlement identity. Settlement identity should be considered very important in analysis of options. The Alternative Strategies for the Future Development of the Borough, the consultation exercise held in 2007, indicated that the proposed development strategy should be based upon a "priority to safeguard environmental features and the identity of individual settlements" Clearly such a large development on the doorsteps of either Hathern, Shepshed or Wymeswold will impact on settlement identity. However the Sustainability Appraisal is inconsistent and biased in its treatment of the two options. For example the Appraisal says: For Option F: Wymeswold Airfield
Option − Garendon
The Appraisal comments solely on the potential negative aspects of development for Option F but deals exclusively with possible mitigation measures for Option C. Similar comments to those used for Option F should have been applied to Option C but were not. This commentary suggests pre−determination of Option C as the preferred option. The Appraisal Performance indicator shows two "negative" arrows for Option C but only one for Option F. However this is not reflected in the commentary or subsequently in the Further Consultation document. In the Further Consultation document itself the summary of Key Advantages and Disadvantages says: For Option F − Wymeswold Airfield
For Option C − Garendon
The village of Hathern sits in a rural setting as much as Wymeswold does, surrounded on all sides by farmed agricultural land. To suggest, as this summary does by omission, that the character and setting of Hathern would be less affected than Wymeswold is simply incorrect. Similarly, Shepshed is surrounded on all sides by farmland and countryside − including the Garendon Estate, Charnwood Forest and the National Forest. Again to comment on the degree of impact in Option C but not in Option F, to which the same comment is applicable, is inconsistent. In summary when looking at the issue of Settlement Identity it is apparent that these two Options have been treated differently, there is inconsistency and bias, and there is evidence of pre−determination of Option C as the preferred Option. Charnwood 2026 − Settlement Hierarchy (p 27) 4.10 The Sub−Regional Centre of Loughborough is also identified in the draft Regional Plan. The Council considered defining Shepshed as a service centre, however Shepshed is one of the main towns in Leicestershire and has a long established, functional and interdependent link with Loughborough. These towns are closely linked with good transport links for journeys to work, shopping, education and services. In planning terms, the two towns effectively function as part of a wider urban system straddling the M1 Motorway corridor in the vicinity of J23. It is important for the future success of both settlements that Shepshed is included as part of the Sub−Regional Centre and that these settlements continue to complement and support each other. Charnwood 2026 − New Housing and Employment Development (p 86) 5.35 This approach will help strengthen the role of Loughborough and Shepshed as mutually supportive urban systems and as the largest Sub−Regional Centre at the centre of the Three Cities Sub−Region. As detailed in section 8 below Shepshed and Loughborough are not mutually supportive urban systems. Journeys to work, shopping, education and services are all from Shepshed to Loughborough. Virtually nobody comes into Shepshed from Loughborough since all services are much better in Loughborough. In fact Shepshed is a dying town and if a new shopping centre and other modern services are built on the Garendon Estate, then Shepshed will continue to decline and not only lose its identity but would not be a viable community Ð becoming simply a dormitory town. Shepshed should be a Service Centre like Mountsorrel, Quorn or Syston. Only then would it receive the investment necessary for regeneration. 8. Settlement Hierarchy The Settlement Hierarchy is a key material consideration in the Core Strategy proposals since it has been used to priorities CBC’s preferred and alternative sites for development. By including Shepshed in the Sub Regional Centre together with Loughborough apparently strengthens their case for building on the Garendon Estate. However, there has never been a case for including Shepshed as part of a Sub Regional Centre. In the draft Regional Plan Loughborough on its own was the Sub Regional Centre. CBC insisted that Shepshed be included but without any evidence base or justification for this. Charnwood 2026 − Settlement Hierarchy (p 26) 4.6 The Council is proposing to include Shepshed as part of the Sub −Regional Centre as evidence suggests that these settlements function as mutually supportive urban settlements. This is not the case. The support is unidirectional. Many Shepshed residents travel to Loughborough to do their shopping but no Loughborough residents come to Shepshed. This has led to a decline in shopping facilities in Shepshed. Many Shepshed residents work in Loughborough but virtually no Loughborough residents work in Shepshed partly because much of the industry has closed down in Shepshed, employment sites now being housing estates (encouraged by the Borough Council). Many Shepshed residents go to Loughborough for leisure pursuits but nobody comes to Shepshed from Loughborough because there are very few facilities. Hardly any Loughborough children attend schools in Shepshed. Loughborough and Shepshed are not ‘mutually supportive urban settlements’ Ð it is all one−way traffic. Neither would the position change if a new town was built on the Garendon Estate. Residents exiting the new town would turn left onto the A512 heading for Loughborough or right on the A6. Why would anyone come into Shepshed? In fact the likelihood is that a new town with modern facilities would attract even more Shepshed residents to go there. For instance, there is only one highly priced supermarket in Shepshed. If a bigger supermarket and a modern shopping centre were to be built in the new town then even more people would be attracted out of Shepshed causing further decline. It is essential that Shepshed be designated as a Service Centre similar to Mountsorrel or Quorn rather than as part of the Sub Regional Centre. Otherwise there will be no regeneration of Shepshed since resources would be directed to the new town or retained in Loughborough. Conclusions The above analysis clearly shows that the Preferred Option for housing development in North Charnwood should be Option F (6): East of Loughborough, on and around Wymeswold Airfield Ð not Option C (4): West of Loughborough (on the Garendon Estate). The main reasons for this are: 1. Option C is a greenfield site including productive agricultural land whilst Option F is mainly a brownfield, previously developed site. National, Regional and Borough policy is to build on previously developed land where possible. 2. Option C would cause huge congestion on the A512, A6 as well as within Loughborough itself (particularly Epinal Way). The situation would be unsustainable. This would not be the case with Option F since the County Council is proposing to build a distributor road east of Loughborough and residents would be able to use the A46 to travel to Leicester. 3. Option C would have a major negative impact on the Green Infrastructure of Charnwood by causing a loss of open countryside and compromising the status and setting of the Garendon Park heritage site 4. Option C would result in loss of identity of Shepshed and Hathern submerging them into a large urban sprawl of Greater Loughborough. 5. Option C would have a major negative impact on biodiversity and wildlife habitats causing irreplaceable loss. 6. Building East of Loughborough would allow more houses to be built in the future on the Cotes/Hoton site. This would be more difficult on the Garendon Estate since expansion outwards from there would impinge on North West Leicestershire District Council land.
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