Richborough Estates have appealed against the refusal of plans for 137 homes off Foldgate Lane (15/02340/REF). This scheme is not in SAMDev, our plan for housing sites, but the developers are hoping that approval of 215 homes off Bromfield Road outside of SAMDev has set a precedent and a planning inspector will approve the Foldgate Lane scheme.
I am not a fan of the Bromfield Meadows development. It is barely sustainable. The Foldgate Lane scheme is much worse and completely unsustainable. It would be madness to build housing on a site that has such awful and dangerous access arrangements. Foldgate Lane cannot be accessed by buses and there is no safe pedestrian route to the Co-op. I cannot think of a more unsustainable site for development in Ludlow.
I submitted my statement opposing the development at the end of last year. Delays at the planning inspectorate mean that it has not yet gone online.
Viv has objected too and, again, her statement is not yet published. The planning inspectorate tell me that they have now forwarded all paperwork to Shropshire Council for publication on the planning portal.
This is my statement in full.
Councillor Andy Boddington submission to Foldgate Lane housing appeal
31 December 2015.
1. Introduction
1.1. This statement forms my submission to the appeal on an application for outline planning permission for housing at Foldgate Lane, Ludlow (APP/L3245/W/15/3137161).
1.2. I am unitary councillor for Ludlow North, an electoral division that covers Ludlow town centre and suburbs and hamlets to the north and west of Ludlow. The proposed development is in Ludlow South and my colleague, councillor Vivienne Parry, has submitted a separate statement objecting to the scheme. I have not previously commented on this scheme in a formal way. This was because there was a possibility the application would come before the South Planning Committee of which I am a member.
1.3. I’d like to thank Turley and Richborough Estates for the dignified and considerate way that they conducted local consultations and provided information. They were honest enough to say they would press ahead regardless of public opinion. And public opinion was whole-heartedly against this scheme. There were 105 objections and just one expression of support.
1.4. I have not had the opportunity to read the Statement of Case (SoC) from Shropshire Council, which is not yet online. I concur with the council’s reasons for refusal.
2. Design
2.1. With the exception of concerns about access to the site (see below), the scheme is well designed and in keeping with its suburban location. It has good green infrastructure, community space and a LEAP.
2.2. We must be cautious in welcoming the design of the scheme because this is an outline proposal and most aspects of the scheme the developers have presented are not currently subject to approval. There is a sense of being distracted, even wooed, by the details of the scheme when the only matter at hand is whether the site is suitable for housing that is primarily accessed off the A49. Every detail, even the number of houses, could be scrapped when a full application is submitted, with the exception of the T-junction off the A49. Turley and Richborough have said as much. They have also announced that it is their intention to gain planning permission and sell the site on to a developer, not to develop it themselves. We must recognise that the site layout and design submitted with the planning application is solely for the purposes of gaining permission. Because this design might never be built, I regard it as a distraction from the real discussion of the merits and demerits of this site.
3. Access – A49
3.1. I find it very difficult to understand why Highways England has given its approval to a T-junction on the A49 at this location. The agency’s decision seems to have been made in the absence of local knowledge.
3.2. The A49 is a fast road and a rather dangerous one. The lack of accidents on the stretch of carriageway immediately south of the Sheet Road roundabout is because this stretch of the road is well designed and free of junctions. The broad sweep of the road between the Ashford Carbonel and Sheet Road junctions encourages fast driving. A vehicle exiting the proposed T-junction onto the A49 will place a slow vehicle in a fast traffic stream. That cannot be safe.
3.3. This area is also prone to morning mists in autumn and spring. The mists rise around dawn. They usually disperse by mid-morning but in periods of rising temperatures the mists can persist much of the day. The stretch of A49 alongside the Foldgate site is particularly prone to mists. This will increase the risk of accidents when slow moving vehicles move into fast flowing traffic.
3.4. If this development is to be built then it should have a roundabout off the A49 from the outset.
4. Access – Foldgate Lane
4.1. The applicants have put forward a curious plan for vehicle crossover of Foldgate Lane. It will not be possible, they say, for vehicles to drive along Foldgate Lane and turn into the area of the site adjacent to Greenacres. Demountable bollards will prevent this while allowing access for emergency vehicles.
4.2. This is a detail of the scheme and not part of the outline application. But the whole concept doesn’t stack up. Foldgate Lane is very narrow and it is already difficult to accommodate pedestrian and cycle traffic alongside vehicles. If 137 homes are built here, pedestrian traffic will increase along the lane. I cannot see how this can be accommodated safely without total reconstruction of the roadway.
4.3. A reconstruction of the lane will have a major impact on the landscape of this area, its wildlife and its attractiveness. This one point could well be sufficient to reject the scheme if a full planning application had been submitted.
5. Sustainability – public and pedestrian transport
5.1. The 2011 census revealed that over a quarter of households in Ludlow parish (25.1%) have no car or van. This is considerably greater than the Shropshire average (15.8%).
5.2. Buses are important in Ludlow and both town routes are heavily used. The Foldgate Lane site is not currently served by buses. There is no practical possibility of bringing buses to the site via the A49 to serve a community of just 137 households. To extend the current 722 service would reduce the frequency of its operation and would increase subsidy costs. A special service for such a small community as Foldgate Lane could only be provided as a community transport service and that would be available just once or twice a week.
5.3. It is not possible to run buses down Foldgate Lane. It is too narrow and without turning points. Measuring from Foldgate Farm, the nearest bus stop is 640 metres away on Sheet Road. This is a route down a narrow lane that is unsuitable for combined pedestrian and vehicle traffic. The route is unlit and has no pavements.
5.4. The bus stops on Sheet Road are currently served by the 722 town service, which circulates via the market square, supermarkets, rail station and GP surgeries. Passengers can transfer to the 701 service to gain access to Ludlow Community Hospital.
5.3. The alternative pedestrian and bus route into town is via Steventon New Road and to a bus stop on Steventon Crescent. The first part of this route is a difficult walk down a steep narrow lane without pavements or lights. The distance to the bus stop is 820 metres. The stop is currently served by the 722 hourly.
5.4. The Foldgate Lane retail area, currently hosting Co-op and Pets at Home stores, is accessible on foot and that would be an advantage for the development if a safe pedestrian route was being proposed. The developers are not offering that and it is not clear how such a safe route might be provided.
5.5. This brief analysis shows that this development will be heavily car dependent. Households without access to a car will be at a considerable disadvantage in accessing health, community and town centre retail services.
Sustainability – elderly population
5.6. Ludlow tends to attract older people. Over a quarter of the population of Ludlow in 2011 was aged 65+ (26.0%), considerably larger than the county average (20.7%).
5.7. We have limited employment opportunities in Ludlow and no strong plans to grow employment. This town is poorly suited to a daily commuting routine by nature of its location. Shropshire Council’s core strategy planning policies aim to reduce commuting.
5.8. With the exception of the affordable housing, the proposed settlement at Foldgate Lane will attract retired and nearly retired people. There is no current planning policy that can restrict this and we might not wish to do so in any event. But there is no wisdom in creating car dependent settlements at such a great a distance from essential services if there is every likelihood they will be occupied by older people with their greater care needs.
6. Sustainability – location
6.1. On 17 December 2015, Shropshire Council adopted SAMDev, the county’s sites allocation and management development document. This stage of the local plan has been many years in the making in collaboration with local communities. It defines how much development is needed in Shropshire to meet assessed housing need up until 2026, and to a large extent where that development should go.
6.2. Policy S10 sets out the location for housing in and around Ludlow. The town benefits from a number of available brownfield sites, including windfalls. The main greenfield development will be in Ludford parish. The long term expectation is to create a continuous and sustainable suburb stretching from Rocks Green in the north to the Eco Park and Sheet village in the south. Prior to 2026, a development of 200 homes at Rocks Green (LUD017) and 80 homes between Sheet village and the Eco Park (LUD034) are expected to be approved as the first stages of the new suburb.[1] Provision will be made for a future link road between these developments and this will form the spine of the post-2026 suburb for vehicles and town buses. It is the view of Ludlow town council, Ludford parish council, along with the four unitary councillors for Ludlow and Clee, that this is the most sustainable location for longer term housing development in Ludlow.
6.3. The NPPF provides national guidance on defining sustainability. In Shropshire, the definition of sustainability relies on a joint interpretation of the NPPF and SAMDev.
6.4. The NPPF has a time free approach to sustainability. A development is either sustainable or not based on a planning balance of disparate criteria at one given point. This is a Schrodinger’s Cat interpretation of sustainability. A minor change in the planning balance can pitch a site in or out of sustainability. This, in my view, leads to planning decisions, especially at appeal, that at times seem random and have too often undermined sustainability as a stable concept. The problem with the NPPF approach is that it does not clearly recognise that sustainability has a temporal dimension. After all, if all the development specified in any local plan were to be built at once, services would be overstretched, if not overwhelmed, and there would be no concept of sustainability. That’s why it is necessary for sites to be brought on stream over a period of time and sometimes to be delivered in a required sequence. In this way, local services grow in capacity and new services and infrastructure are put in place to accommodate the additional population. These services include schools, medical services, public transport, roads and retail facilities. Phased development also allows time for established communities and newcomers to integrate.
6.5. For towns like Ludlow, SAMDev, and the accompanying analysis in the SHLAA, provide the temporal dimension needed to achieve genuine sustainability. In Ludlow, S10 provides for development of brownfield sites, including windfalls, within the town development boundary that was established for the South Shropshire Local Plan. This boundary has been extended by SAMDev to include the first phase of a new suburb east of the A49 bypass (LUD007, LUD034). Both sites are currently well served by the 722 town bus service. The intention that this service or a successor will run along the new spine road between Rocks Green and the Eco Park at some point in the future.
6.6. In terms of infrastructure, needs and services, SAMDev provides sufficient development for our town until 2026. That’s why the housing numbers we have in S10 have been agreed by all parties, including by the planning inspectorate during the examination of SAMDev.
6.7. The Bromfield Road development approved on appeal has already disrupted the sustainability model for Ludlow.[2] It will need to an excess over current housing projects of around 200 homes in a location that is less sustainable than the SAMDev sites beyond the bypass.
6.8. I cannot agree with the statement by Turley and Tesni that the Foldgate Lane development must be interpreted in the same way as the Bromfield Road development recently approved at appeal.[3] They are comparing two very different sites. If Shropshire Council has accepted this as a statement of common ground, then I don’t think that it fully understands its own policies.
7. Conclusion
7.1. The proposed Foldgate Lane development is in an unsustainable location. If this development is permitted, Ludlow will grow in an unsustainable manner. That is contrary to the principles and policies of the NPPF, core strategy and SAMDev.
Notes
[1]. The 80-home scheme is approved in principle by council planners but there have been delays on S106 agreements.
[2]. The Bromfield Road appeal was APP/L3245/W/15/3001117.
[3]. Draft SoCG, Turley October 2015, paragraph 5.19.