Wisloe Green and Stroud Local Plan

Further to our previous correspondence, please find information below.

We appreciate that this may seem a long read but the intention is to make this easy for you to respond to the consultation. If you wish to do so, we suggest that you attempt to read and submit your response just in case there are issues with the council’s form.

The Examination was halted in June 2023 and additional work was carried out on the Plan. The reports are now available and are subject to a consultation from 5th September to 23^rd October 2024.

If you submitted a response to the consultation in July 2021 then SDC should have invited you to comment on this consultation. You should have received an invite but if you have not received one then please contact the Planning Strategy Team (local.plan@stroud.gov.uk).

This overview gives the key points to cover in your response.

The questions (Q1etc) refer to the questions on the online response section of the SDC website.

Q1a and b – M5 J1

• The plan will not overcome the capacity constraints on J12.
• Report EB133c identifies a delivery date for the upgrade as 2041.Secured Government funding is not identified.
• National Highways (NH) state J12 is near to capacity. Housing development would be post 2041.

Q2 a and b – M5 J14

• The plan will not overcome the capacity constraints on J14.
• Reports EB133a and EB133b do not identify Government funding, timescales, the likelihood of success or delivery date.
• National Highways (NH) state that J14 is at capacity now and would not permit any further significant level of housing development.
• Delivery is unlikely until 2041. Housing development would be post 2041.

Q3a and b – Housing delivery (EB134)

• Reports EB134 and Appendix 1 show the draft Local Plan is overly dependent upon strategic sites in the A38/M5 corridor to achieve the housing target.
• This table duplicates tab 1 in EB135, apart from missing 173 dwellings in PS37.

Q4a and b – Housing trajectory – M5 J12 and J14 scenarios (EB135)

• Strategic sites will overload J14 and will not be permitted by National Highways (NH).
• Removing Strategic sites affected by J12/J14 shows that the draft Local Plan cannot deliver sufficient houses.

For PS37 (Wisloe), the option B interim proposal to share the 1000 housing allocations between multiple sites ignores the significant up-front costs that would be incurred e.g. gas pipeline move and footbridge etc to be shared by a smaller number of houses. Option B would also result in a 10-year pause to building, waiting for the roundabout to be built.

Q5a and b – Sharpness (PS36)

• The proposal for achieving 1000 dwellings by modifications to J14 requires additional modelling and costings to incorporate additional Charfield traffic, which have not been provided.

For PS37 (Wisloe), the option B proposal to share the 1000 housing allocations between multiple sites ignores the significant up-front costs that would be incurred e.g. gas pipeline move and footbridge etc to be shared by a smaller number of houses and that it would result in a 10-year pause.

Q6a and b – Wisloe (PS37)

• The cost estimate for the footbridge was not updated but merely reissued 15 months later.
• The promoter’s total cost was £6.285m and the additional cost of £2.5m to be borne elsewhere by the developer. There remains no lead developer who has undertaken due diligence for the proposal.
• The Savills viability document made significant changes to the baseline assumptions contained in SDC’s viability assessment report (EB111) without supporting evidence.
• Correcting the Savills viability report results in PS37 becoming not viable.

The conclusion is that the Draft Local Plan is not deliverable and is unsound for all the questions above

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Additional information is contained in the following notes

Background.
In July 2021 the Regulation 19 submissions for the Stroud District Council (SDC) Draft Local Plan (LP) closed. This was followed by further focussed consultations which ultimately led to an Examination Hearing commencing in early 2023. The two planning Inspectors who are assigned to run the Hearing decided to ‘halt’ the Hearing process part way through in June 2023. They suggested that SDC should withdraw the LP on the grounds that too many major issues had been identified during the Hearing process which would make it unlikely the LP could be found to be ‘sound’. After much correspondence between SDC and the Inspectors it was agreed in Feb 2024 that the Hearing process should be ‘paused’ for a further 10-months and would recommence in Dec 2024. Between June 2023 and Sep 2024 SDC has been coordinating responses to address the major issues identified by the Inspectors. These submissions are the subject of a further consultation, one which commenced on 5/9/24 and will close on 23/10/24. If you submitted a response to the original Reg19 LP consultation in July 2021 then you should have been contacted by SDC inviting you to contribute to this latest focussed consultation also. If you feel you should have received an invite but have not received one, then please contact the Planning Strategy Team (local.plan@stroud.gov.uk).

Advice
The current consultation relates only to the new documents which have been submitted and which can be found at https://www.stroud.gov.uk/technicalevidenceconsultation.
Comments will not be accepted relating to any other aspect of the LP.
The subjects cover; Strategic Road Network, Housing Delivery, P36 Sharpness and PS37 Wisloe.
Submissions via the SDC website request feedback to a question (unlimited word count) followed by a 250-word summary for the Inspectors. If you have fewer than 250-words to say on a subject, then simply put the same thing in twice.
Other methods of responding are available by contacting the Planning Strategy Team at SDC. It is recommended that residents able and willing to submit responses should do so in their own words. However, WAG has reviewed the new documents and provides the following guidance regarding the ones relevant to Wisloe (PS37):

Strategic Road Network
Background – This mainly relates to the need for the existing single lane road crossings at M5 junctions 14 and 12 to be replaced with roundabouts. The costs have spiralled, no funding is in place (or applied for) and probably won’t be available for around 15 years. Without the roundabout at J14, which is already at capacity, no further significant housing developments and therefore traffic load contributing to J14 will be permitted by National Highways.

Q1a and b – M5 J12

• No, the proposed plan will not overcome the capacity constraints to Local Plan (LP) growth.
• Report EB133c identifies a realistic future delivery date for the change to be 2041, as there is no secured Government funding in place.
• National Highways state J12 is near to capacity, therefore the existing LP which schedules strategic housing deliveries to increase load significantly at J12, should not be included within the LP until after the J12 development is completed, which could be 2041.
• It is likely therefore that the increase in traffic load will be restricted until circa 2041, which will therefore constrain the LP housing growth significantly until it is completed.
• The LP is therefore not deliverable and is unsound. 

Q2 a and b – M5 J14  

• No, the proposed plan will not overcome the capacity constraints to Local Plan (LP) growth.
• There is no mention in report EB133a or EB133b regarding the timescales to secure the Government funding required, the likelihood of success or delivery date (ref Inspectors’ letter ID15, 4, iii).
• National Highways, state J14 is at capacity now and would not permit any further significant housing development which would impact J14.
• As there is no secured Government funding and delivery is unlikely until 2041, it is likely therefore that the increase in traffic load will be restricted until circa 2041 which will therefore constrain the LP housing growth significantly until it is completed.
• The LP is therefore not deliverable and is unsound.

Housing Delivery
This is broken down into two sections, firstly a table showing the latest housing delivery forecasts contained in the LP, followed by a second table which shows some sensitivity scenarios based upon the M5 J12 and J14 constraints.

Q3 a and b – Housing delivery (EB134)

• Reports EB134 and Appendix 1 show the LP is overly dependent upon strategic sites in the A38/M5 corridor to achieve the housing target.
• As clarified in the Reg19 submissions, the Examination Hearing and now EB135, most of these strategic sites contribute significantly to the traffic load on the M5 at junction 12 and 14. Only strategic developments which utilise the existing J13 roundabout, which has excess capacity, (like PS19a at Stonehouse) should be included within the LP until NH deem it safe for additional strategic housing developments to progress. Including the strategic sites, affected by the J12 and J14 constraint, within the LP baseline housing trajectory makes the LP undeliverable and unsound.
• EB134 states G2 (land at Whaddon) has been excluded from the assessment. This is appropriate for calculating SDC’s own housing trajectory, but it is not appropriate to ignore the 3000-housing development when assessing the traffic load on J12! G2 is immediately next to J12 and should therefore be included within the sensitivity assessment EB135.

Q4 a and b – Housing trajectory – M5 J12 and J14 scenarios (EB135)

• Reports EB135 and Appendix 1 show the LP is overly dependent upon the strategic sites on the A38/M5 corridor to achieve the housing target numbers. As clarified in the Reg19 submissions, the Examination Hearing and now EB135, these strategic sites all contribute significantly to the traffic load on the M5 at J12 and J14.
• National Highways has stated J14 is at capacity already and further large-scale housing developments will not be permitted until after the J14 modifications have been implemented, which could be 2041.
• Removing the strategic sites, which contribute significantly to the J14 load, shows the LP cannot deliver sufficient housing numbers to fill the planning pipeline.
• The constraint at J14 which significantly limits housing development therefore makes the current LP undeliverable and unsound.
• Only strategic developments which utilise the existing J13 roundabout, which has excess capacity, (like PS19a at Stonehouse) should be included within the LP until NH deem it safe for additional strategic housing developments to progress.
• Development G2 (land at Whaddon), which represents a 3000-housing development, should be included within the traffic sensitivity assessment as the site is immediately next to J12.
• For PS37 (Wisloe), the option B interim proposal to share the 1000 housing allocations between multiple sites ignores the significant up-front costs that would be incurred e.g. gas pipeline move and footbridge etc to be shared by a smaller number of houses. Option B would also result in a 10-year pause to building, waiting for the roundabout to be built, which is not practical.

Q5 a and b – Sharpness (PS36)
WAG has remained silent to-date on issues affecting the Sharpness proposal, however SDC has included a proposal and some analysis within this submission which affects Wisloe (PS37). SDC plans to widen the B4509 at J14, as an interim measure, and estimates it will permit 1000 additional houses to be built before the roundabout needs to be completed.

• EB136 includes a proposal to introduce an interim modification to the B4509, where it joins the A38 at J14, to permit a further 1000 dwellings’ worth of car journeys at J14, despite NH stating they did not support the proposal. Further modelling and costing work is required, and this has not been included within the consultation material.
• For PS37 (Wisloe), the option B proposal to share the 1000 housing allocations between multiple sites ignores the reality that significant up-front costs would be incurred associated with incorporating mandatory infrastructure, e.g. gas pipeline move and footbridge etc.
• Option B shows a 10-year pause before building recommences following completion of the J14 roundabout. Under such circumstances the PS37 proposal becomes unviable.
• The proposal to include the Option B scenario within the LP would therefore make the LP undeliverable and unsound.

Q6 a and b – Wisloe (PS37)
The only action on the promoters was to update their cost estimates for the footbridge (originally £1m and revised up to £3.77m) and then to re-run the viability report. Unfortunately for us, the Inspectors previously accepted a completely new viability report submitted by Savills the day before the Hearing. The Savills document seriously misrepresents the economics for the proposed site.

• The cost estimate for the footbridge has not been refreshed but merely reissued 15 months later.
• The promoter’s own contractor’s assessment estimated a total cost of £6.285m for the bridge, the difference of £2.5m being an additional cost to be borne elsewhere by the developer. There remains no lead developer who has undertaken due diligence for the proposal.
• The Savills viability document made significant changes to the baseline assumptions contained in SDC’s viability assessment report (EB111) which is the only viability document to have been subjected to consultation.
• Unlike EB111, the Savills document provides no supporting evidence to substantiate the assumption changes beyond Savills own opinion, which were not supported by any independent third-party opinion. If they are to be accepted, to compare sites fairly these assumption changes should be applied equally to other strategic sites subject to assessment, this has not been undertaken.
• Correcting the Savills viability report results in PS37 becoming not viable.

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Regards
Wisloe Action Group