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					Tewkesbury Borough Local Plan to 2011: Inspector's Report




TRP          Transport Policies - General

Objections

See Appendix D for the list of objections on this matter


Main Issues
 clarity of overall strategy
 order of policies
 transport objective five
 reliance on private cars in rural areas
 responsibility for implementation


Inspector's Considerations and Conclusions

1.6.1.1     PPG12, paragraph 5.5 states that the most appropriate development plan for the
            transport and land use strategy underpinning a local transport plan (LTP) will
            generally be the structure plan. Gloucestershire County Council is the highway
            authority for the Borough and is responsible for the preparation of the local
            transport plan (LTP). The local plan should translate the strategic approach of the
            County into development control policies that are consistent with the overall
            objectives and policies of the structure plan and the LTP. More detailed area
            strategies are also included in the LTP that provide a focused approach to
            transport matters in identified sub-areas such as the Severn Vale and the
            Tewkesbury/Ashchurch area. In accordance with my recommendations on
            specific policies, the finally adopted plan would accord more closely with the
            over-arching strategy of the structure plan and LTP, which is generally to
            encourage the use of public transport and non-car transport modes and to reduce
            reliance on private motor cars where practicable. Subject to that, I do not consider
            that there is any lack of clarity about the overall strategy of the Plan in respect of
            the interrelationships between transport and land use.

1.6.1.2     I agree with another objection that the rationale for the order in which the
            transport policies appear is not readily apparent. This does not aid understanding
            of the policies or the usability of the Plan. Subject to my recommendations on
            specific policies, a general re-ordering in accordance with the thematic pattern in
            the GSPSR Transport Chapter would be appropriate.

1.6.1.3     The fifth objective of the Transport policies, as set out in the introduction to the
            chapter, is to encourage the implementation of a high quality public transport
            system to link the centres and suburbs of Cheltenham and Gloucester and their
            surrounding areas. Policy TRP11 and the reasoned justification provide more
            detail in conjunction with the Proposals Map. The objective is clear and consistent
            with GSPSR policy and the LTP strategy and in my view the suggested re-
            wording by the objector is unnecessary.
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1.6.1.4       The reliance of the rural population on cars should be balanced with the need to
              encourage a more sustainable approach to transport in the Borough. PPG13 states
              in paragraph 40 that while opportunities for public transport and non-recreational
              walking will be more limited in rural areas, the overall policy approach that
              applies to urban areas should be applied in rural areas. Access to employment,
              shops and services in the Borough’s main population centres for those who live in
              the rural areas is the significant issue. Realistically, those who live in remote
              areas will be reliant on the car to serve their day-to-day transport needs, and
              parking standards in the Plan should reflect this. However, the need to provide
              adequate parking for rural dwellers should not compromise the primary aim of the
              Plan in encouraging those who can to use more sustainable forms of transport,
              other than the car. The LTP has taken this into consideration in setting down
              maximum car parking standards which reflect the circumstances in the more
              highly urbanised Central Severn Vale and the remaining rural areas of the County.
              In accordance with my recommendations on Policy TRP16 and Appendix 5, the
              Borough’s parking standards would also reflect these differences. There is no
              other policy or proposal in the chapter that would affect rural dwellers in a
              disadvantageous way due to their reliance on motor cars. I therefore see no need
              to explicitly take this into account in relation to other policies in the chapter.

1.6.1.5       The implementation section of the introductory text is a statement of fact. The
              local planning authority is not responsible for motorways and trunk roads. The
              County Council is the highway authority and is responsible for other roads in the
              Borough. The private sector also has a role, as acknowledged in the text. No
              modification to this section is required.

Recommendations

1.6.1.6 (i)       Subject to my recommendations on specific policies, the Plan be modified by
                  the re-ordering of the policies within the Transport Chapter in accordance
                  with the thematic pattern in the GSPSR.
          (ii)    No other modification be made to the Plan in response to these objections.




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TRP1           Access for Development

Objections

See Appendix D for the list of objections to this policy


Main Issues
 scope and detail of policy
 consultation with infrastructure providers

Inspector's Considerations and Conclusions

1.6.2.1       Policy TRP1 requires that development proposals should include arrangements for
              safe access to and from the highway, and that access proposals should not cause
              an unacceptable loss of amenity to users of adjacent land.

1.6.2.2       With regard to the first issue, I support the comments made by the County Council
              concerning the need for a more coherent approach to accessibility at the start of
              the Chapter and recommend their proposed policy. This accords with guidance in
              PPG13, paragraph 19, which discusses accessibility standards in respect of all
              modes of transport, beyond the rather limited scope of Policy TRP1 that lacks
              depth and clarity. The resulting set of access policies is presented in such a way as
              to make the Chapter seem fragmented and ill-defined in its scope and intent. A
              single policy to deal with accessibility across all modes of transport would aid the
              production of a more concise Plan.

1.6.2.3       PPG13, paragraph 19, states that authorities should give emphasis to access
              arrangements in new developments so that they will offer realistic, safe and easy
              access by a range of modes of transport. The issue of safety should be tackled in
              the policy as well as in the reasoned justification because it is an intrinsically
              important factor in determining standards of access in new developments. In
              response to another objection, I do not recommend that the modified policy
              should include the term `significant adverse effect on amenity’. An unacceptable
              loss of amenity is by definition unacceptable and the suggested re-wording would
              not improve the clarity of the policy.

1.6.2.3       In respect of the second issue, major service providers such as gas and water
              suppliers are statutory undertakers and as such they will be consulted as part of
              any major development, including transport schemes. There is no need to
              duplicate these provisions in the Plan.

Recommendations

1.6.2.4 (i)        Policy TRP1 be replaced as follows:-


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                Development will be permitted where:
                (a) provision is made for safe and convenient access to the development by
                     pedestrians and cyclists;
                (b) an appropriate level of public transport service and infrastructure is
                    available, or can be made available;
                (c) the traffic generated by and/or attracted to the development, together with
                    that arising from other existing or planned development, would not impair
                    the safety or satisfactory operation of the highway network, and
                (d) highway access can be provided to an appropriate standard which would
                    not adversely affect the safety or satisfactory operation of the highway
                    network, nor cause an unacceptable loss of amenity to users of adjacent
                    land.

        (ii)    The reasoned justification for Policy TRP1 be modified accordingly.

        (iii)   No other modification be made to the Plan in response to these objections.




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TRP2         Traffic Calming

Objections
See Appendix D for the list of objections to this policy


Main Issues
 pollution, vibration and noise impacts
 needs of wide-bodied agricultural vehicles
 emphasis on Tewkesbury Town Centre

Inspector's Considerations and Conclusions

1.6.3.1     Traffic calming is generally a matter for the County Council as the highway
            authority. There is a limit to how far the Plan can influence the implementation
            and design of traffic calming schemes. However, it is important that the Plan
            deals effectively with transport proposals that inevitably affect the quality and
            appearance of the built and natural environment. PPG13, paragraph 64, clearly
            states that development plans should include any policies which are directly
            related to the management of traffic. Policy TRP2 complements section 4.7 of the
            Tewkesbury and Ashchurch Area Strategy of the LTP, which covers these matters
            in more detail. The policy states that traffic calming schemes should be
            sympathetic to the surrounding built environment.

1.6.3.2     In respect of the first issue, the policy sets down guidelines to ensure that traffic
            calming schemes are appropriate to their location and setting. It will encourage
            developers and the County Council as highway authority to work in conjunction
            with the local planning authority to ensure that schemes are implemented to meet
            the needs of residents and motorists. There is no evidence to suggest that traffic
            calming schemes detrimentally affect the environment due to increased pollution
            and vibration.

1.6.3.3     In rural areas the safe and convenient operation of farm machinery is important to
            the economy and therefore a reference to the needs of agricultural traffic is
            appropriate. The additional policy wording in the RDDLP appears to resolve the
            objection made to the Deposit Draft in this regard.

1.6.3.4     The addition of the word `towns’ in the reasoned justification has clearly
            established that the scope of the policy covers all of the urban areas in the
            Borough. Policy TRP24 deals specifically with traffic management measures to be
            implemented in Tewkesbury town centre. Therefore, no modification of the Plan
            is required in respect of the final issue.

Recommendation

1.6.3.5     No modification be made to the Plan in response to these objections.

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TRP3            Footpaths and Bridleways Protection in the Implementation
of              Highway Schemes


Objections

See Appendix D for the list of objections to this policy


Main Issues
 adequate sign-posting
 reference to agricultural occupiers

Inspector's Considerations and Conclusions

1.6.4.1     The policy requires that the integrity of the footpath and bridleway network be
            safeguarded in the design and implementation of highway projects.

1.6.4.2     With regard to the first issue, signposting is a matter for the County Council as
            the highway authority and therefore it would not be appropriate to include
            reference to this in a policy in the Plan.

1.6.4.3     The rights of way of agricultural occupiers is a matter for separate legislation as
            the Council has suggested in its response. The implementation of highway
            projects is solely a matter for the County Council, although the protection of the
            existing footpath and bridleway network is an important local matter that is
            rightly addressed in the Plan.

Recommendation

1.6.4.4     No modification be made to the Plan in response to this objection.




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TRP4             Provision and Enhancement of Pedestrian Facilities

Objections

See Appendix D for the list of objections to this policy

Main Issues
 incorporation into Policy TRP1
 advance notice to major infrastructure providers
 pedestrian/vehicle separation

Inspector's Considerations and Conclusions

1.6.5.1       The policy seeks to ensure that safe and convenient pedestrian access is achieved
              in new development.

1.6.5.2       With regard to the first issue, my recommended modification of Policy TRP1
              makes this policy redundant. There is no specific reason why pedestrian access
              should be afforded separate treatment to other modes of transport when the issues
              of safety and convenience are the same. A combined access policy would not
              weaken the integration of pedestrian facilities in the design of new developments.
              Rather, it would provide clearer guidance to developers and encourage them to
              consider how all modes of transport can be integrated together.

1.6.5.3       Reference to timely notice for infrastructure providers is not an appropriate matter
              for inclusion in the Plan.

1.6.5.4       In respect of the third issue, it is not necessarily desirable to separate footpaths
              from vehicular routes. Activity in streets and informal surveillance from buildings
              provide a significant degree of safety to pedestrians. The design of new
              development and traffic management schemes create the best opportunities for
              increasing safety and amenity for pedestrians.

Recommendations

1.6.5.5 (i)        The Plan be modified by the deletion of Policy TRP4.

          (ii)     No other modification be made to the Plan in response to these objections.




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TRP5         Cycle Facilities

Objections
See Appendix D for the list of objections to this policy

Main Issues
   need for Borough-wide map of the full cycle network
   requirement for positive proposals for cycle routes or their safeguarding
   dangers from piecemeal development
   segregation of cycle routes from vehicular routes

Inspector's Considerations and Conclusions

1.6.6.1     The policy encourages the increased use of cycles in the Borough and sets down three ways in
            which this will be achieved. They include the identification of an integrated network of routes, the
            implementation of the National Cycle Network and the introduction of cycle-friendly junctions
            and other measures in conjunction with new highway schemes.

1.6.6.2     The Tewkesbury/Ashchurch Area Strategy (CD29) and the Severn Vale Area
            Strategy (CD28) both contain detailed maps of proposed cycle routes in the main
            urban areas of the County and the Borough. These documents, together with other
            elements of the Local Transport Plan (LTP), set down a comprehensive cycling
            strategy for the County. It would be useful to show the national and local cycle
            route network on a Borough-wide map. This would help developers and local
            residents to understand the extent of the cycle route network and enable them to
            link new development to it. The Council has set down the national routes that are
            being investigated and implemented in the Borough in the reasoned justification
            to the policy in the RDDLP.

1.6.6.3     I agree that the Plan should take forward the proposed cycle route network in the
            LTP in a more pro-active way by including firm proposals and safeguarded routes
            where appropriate. The LTP was published in July 2000 and it is unfortunate that
            the Council has not grasped the opportunity to introduce its key elements into the
            RDDLP. The Council should re-assess Policy TRP5 in the light of the LTP and
            decide how the Plan can implement and improve the existing and planned cycle
            routes in the Borough through specific proposals. For example, Figure 4.2 of the
            Tewkesbury and Ashchurch Area Strategy shows a recommended cycle network
            for Tewkesbury Town that the Plan should seek to implement.

1.6.6.4     While the Council can and should introduce practical proposals to improve and
            consolidate the cycle route network in the Borough as detailed above, the
            piecemeal development of the network is unavoidable because it relies upon
            contributions from new development and the level of funding available. The
            development of the cycle route network is an on-going project, but the Council
            should target problem areas where safety is a concern and bring forward proposals
            to remedy the safety issues. The Tewkesbury and Ashchurch Area Strategy
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             acknowledges in paragraph 3.6 that the cycle network in the area lacks coherence,
             but goes on to state that it should be possible to overcome the current limitations
             of the cycle routes in and around Tewkesbury. Clearly the Plan should be seeking
             to do this and the recommendation above incorporates this aspect.

1.6.6.5      Segregated cycle routes are generally desirable for safety reasons but are not
             always achievable, particularly in urban areas where there is greater competition
             for space. Therefore I do not consider that any specific modification of the policy
             or reasoned justification is appropriate in response to the final issue.

Recommendations

1.6.6.6 (i) The Plan be modified by a re-assessment of Policy TRP5 to bring forward
       specific proposals for the improvement or implementation of the existing or planned
       cycle routes in the Borough as set out in the LTP, and the Proposals Map be modified
       accordingly.

          (ii)   No other modification be made to the Plan in response to these objections.




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TRP6         Cycle Parking

Objections
See Appendix D for the list of objections to this policy

Main Issues
 appropriate standards for cycle parking
 standards for flats and maisonettes
 standards for supermarkets
 need for a clear cycle strategy
 need for a Borough-wide map of cycle routes

Inspector's Considerations and Conclusions

1.6.7.1     Policy TRP6 seeks the provision of cycle parking spaces in relation to non-
            residential development and it links cycle parking standards to car parking
            provision.

1.6.7.2     With regard to the first issue, the inclusion of cycle parking standards in the reasoned justification
            is too detailed and the policy could be improved by expressing them in the form of a table. It is
            not appropriate to link cycle parking standards to maximum parking standards. PPG13 does not
            contain any specific guidelines for cycle parking standards. However it states clearly that
            development plans should contain policies that accord with the local cycling strategy, which
            should be produced in conjunction with the local transport plan. The LTP sets down a schedule of
            County-wide minimum cycle parking standards in Section 5.12.5 (Table C). The standards in the
            LTP should be regarded as the base level, and local authorities should seek to increase the amount
            of cycle parking. This is in accordance with the expectation of the LTP that the Council would
            adopt a cycle parking standard that would at least satisfy the minimum levels set out in the
            County-wide framework.

1.6.7.3     In respect of the standards for flats and maisonettes, residential cycle parking
            provision is dealt with under Policies HSG5 and HSG9. This is the most
            appropriate context in which to deal with this matter.

1.6.7.4     So far as supermarkets are concerned, there is no reason why they should be
            subject to a lower standard, given that they are generally one of the largest
            generators of car trips.

1.6.7.5     In respect of the penultimate and final issues, I refer to my recommendations
            under Policy TRP5.




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Recommendations

1.6.7.6 (i)     Policy TRP6 be modified by setting out standards for non-residential cycle
                parking that would at least satisfy the minimum levels of provision
                recommended in Section 5.12.5 (Table C) of the LTP.

        (ii)    The reasoned justification for Policy TRP6 be modified accordingly.

        (iii)   No other modification be made to the Plan in response to these objections.




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TRP7             Promotion of Integrated Transport Network

Objections

See Appendix D for the list of objections to this policy


Main Issues
 definition of `large new developments’
 generality of policy
 need for improved bus priority measures and quicker journey times

Inspector's Considerations and Conclusions

1.6.8.1       The policy sets out the Council’s intention to work with other agencies,
              authorities and service providers to encourage an integrated approach to a
              public/private transport network. It also states that in the case of large new
              developments, the Council will seek contributions from developers toward the
              provision of public transport access where appropriate.

1.6.8.2       Objectors are correct when they say that the term `large new developments’ is
              open to interpretation. Circular 1/97 requires that contributions are proportionate
              to the scale and nature of the development proposed, and therefore it is not
              necessary to have a policy that relates specifically to large developments. A more
              sensible approach is to negotiate contributions on an individual basis, having
              regard to the specific proposals set out in the Plan.

1.6.8.3       In respect of the second issue, the objections are justified. The policy is framed as
              a statement of intent and serves no useful development control function, nor does
              it contain specific proposals for development. The Council considers that the
              policy is needed to co-ordinate the Borough’s private/public transport strategy
              with that of the County. However, this function is fulfilled by the LTP, and the
              policies in the Plan should complement these from a development control
              perspective, rather than duplicate them.

1.6.8.4       On the final issue, measures to improve the efficiency of public transport in the
              Borough are dealt with under Policy TRP11.



Recommendations

1.6.8.5 (i)        The Plan be modified by the deletion of Policy TRP7 and the supporting text.

          (ii)     No other modification be made to the Plan in response to these objections.


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TRP8             Bus Priority

Objections

See Appendix D for the list of objections to this policy

Main Issues
 relevance of policy
 need for more bus shelters
 access to new housing development

Inspector's Considerations and Conclusions

1.6.9.1       In accordance with Policy TRP8 the Council will identify bus priority routes and
              other priority measures in conjunction with new development.

1.6.9.2       PPG13, paragraph 74, advises that local authorities should identify the key routes
              for bus improvements and priority measures in their local plans. The policy is well
              intentioned, but it does not relate to any specific proposal or identified route.
              General statements of intent that relate to the implementation of highway
              improvements and public transport related matters should be included in the LTP.

1.6.9.3       In respect of the second issue, Policy TRP11 provides a more appropriate context
              for considering improved public transport facilities.

1.6.9.4       Policy TRP1, if modified in accordance with my recommendation, would deal
              with access to public transport from new developments under criterion (b). This is
              a more appropriate context for considering this matter in a way that is concise,
              clear and avoids duplication.

Recommendations

1.6.9.5 (i)        The Plan be modified by the deletion of Policy TRP8 and the reasoned
                   justification.

          (ii)     No other modification be made to the Plan in response to these objections.




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TRP10            Park and Ride Provision

Objections
See Appendix D for the list of objections to this policy


Main Issues
 inappropriate development in the Green Belt
 need to identify sites or set down appropriate criteria for proposals
 appropriateness of urban sites
 effect on public transport usage
 consultation with the Highways Agency
 site at Brockworth/Hucclecote

Inspector's Considerations and Conclusions

1.6.10.1    The policy sets out the Council’s intention to investigate and promote Park and
            Ride (P&R) sites in conjunction with the County Council and neighboring
            districts. The reasoned justification makes clear that brownfield or undeveloped
            land within urban areas would be the preferred locations for sites, but the policy
            sets out two criteria that would have to be satisfied to demonstrate `very special
            circumstances’ before any proposal for a P&R site in the Green Belt would be
            considered.

1.6.10.2    In accordance with PPG2, park and ride development is not inappropriate in the
            Green Belt, subject to certain conditions, and therefore I do not consider that the
            advice in paragraph 3.3 of PPG2 applies in this instance. However, the wording
            of the policy should be modified to reflect PPG2’s advice more closely, by setting
            out the conditions on which such development would not be inappropriate.

1.6.10.3    In the absence of any specific proposals for P&R sites in the Borough, the policy
            sets out appropriate provisions for dealing with applications. These include such
            matters as landscaping and siting and criteria that would be applied in relation to
            proposals in the Green Belt. This is a comprehensive approach that complies with
            national guidance in paragraph 61 of PPG13, which states that schemes should
            take into consideration alternative sites, the impact on local amenity and traffic
            impacts. The policy complies with all of these requirements.

1.6.10.4    Given the rural nature of the County, access to public transport is restricted in
            some areas. Park and Ride schemes offer a practical way to reduce traffic in the
            County’s urban areas by encouraging people not to take their cars into town
            centres and to use public transport instead. This does not mean that P&R facilities
            have to be located on greenfield sites in the Green Belt. The space requirements
            of P&R sites allow limited opportunities to locate them within the built-up areas
            of the Borough or elsewhere, but the preference must still be to develop
            brownfield sites before any greenfield sites are considered. In accordance with

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           PPG2, non-Green Belt locations must be considered before Green Belt sites. And
           PPG13 states that schemes should be well designed and must promote the
           potential for walking or cycling. Therefore, the proximity of P&R sites to the
           urban areas they serve should be as close as reasonably practicable, without
           causing detriment to the amenity of the areas in which they are located. The
           policy reflects this intent and no modification is required in respect of this issue.

1.6.10.5   There is no evidence before me to suggest that P&R sites discourage the use of
           public transport. And it is relevant that the policy requires that proposals should
           not cause harm to the local highway network, which includes the public transport
           network.

1.6.10.6   The Highways Agency is a statutory consultee when determining applications for
           development that affect trunk roads or motorways, and so it is not necessary to
           add any reference to the Agency in the policy or reasoned justification.

1.6.10.7   With regard to the final issue, the site-specific case at Brockworth/Hucclecote is
           linked with objections to other transport policies, and the reader is referred to
           Policies TRP15 and TRP23. However, I find nothing in the evidence to support
           the advancement of the site for P&R. In accordance with the Gloucester Park and
           Ride Strategy, other sites should be brought forward in preference to this one, and
           I consider that the allocation of the site at this stage would be in conflict with
           national and local policies to protect the Green Belt.

Recommendations

1.6.10.8       (i)     The third sentence of Policy TRP10 be modified by setting out the
                       circumstances in which park and ride development would not be
                       inappropriate in the Green Belt and the reasoned justification be
                       modified accordingly.

               (ii)    No other modification be made to the Plan in response to these
                       objections.




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TRP11            Public Transport Corridor

Objections
See Appendix D for the list of objections to this policy

Main Issues
 relevance to planning
 need to identify key transport routes
 need for a light rail route in the Central Severn Vale
 policy title
 sustainability and opportunity for modal transfer
 use of word `must’
 Park and Ride sites as improvements to public transport corridors

Inspector's Considerations and Conclusions
1.6.11.1    Policy TRP11 identifies the main public transport corridors in the Borough and
            requires all new developments that have an impact on them to contribute towards
            sustainable transport measures.

1.6.11.2    The policy relates specifically to the identified main transport corridors. It
            effectively links the improvement and provision of public transport with new
            development along these corridors, and as such its relevance to planning is not in
            question. I consider that it accords with paragraph 74 of PPG13 which advises
            that development plans should identify key bus routes and priority measures.

1.6.11.3    The main transport routes are identified on the Proposals Map and are annotated
            in an appropriate way. Therefore, no modification to the Plan is required in this
            particular regard.

1.6.11.4    Turning to the third issue, the reasoned justification explains the outcome of
            studies into the viability of a light rail link between Cheltenham and Gloucester.
            It concluded that a light rail route would not be financially viable. I have no
            reason to conclude that this proposal has not been adequately researched and
            dismissed for sound reasons.

1.6.11.5    The title of the policy should be modified to `Public Transport Corridors’ so that it
            reflects the network of transport corridors in the Borough and not one in
            particular. I note that this modification was accepted by the Council at the
            Deposit Draft stage, but was not subsequently carried through to the RDDLP.

1.6.11.6    One of the objections points out that not all locations on public transport corridors
            are necessarily sustainable and that the emphasis should be placed on the
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              opportunities they provide for modal choice and modal transfer. However, in my
              view the specific characteristics of sites is a matter best considered on an
              individual basis, and the policies in the Plan as a whole would deal adequately
              with modal choice and transfer issues.


1.6.11.7      I agree that the word `must’ does not reflect the need for negotiation in
              accordance with Circular 1/97 and therefore it should be deleted and replaced by
              the words `may be required to contribute…’.


1.6.11.8      There is no need for a specific addition to the policy to deal with potential park
              and ride sites. The Plan should be read as a whole, and Policies TRP10 and
              TRP11 together would address park and ride sites along public transport corridors.


Recommendations

1.6.11.9(i)       Policy TRP11 be modified by:

                  a) changing its title to `Public Transport Corridors’, and

                  b) deleting the words `must contribute..’ and replacing them by the words
                     `may be required to contribute..’.

           (ii)   No other modification be made to the Plan in response to these objections.




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TRP12        Gloucestershire Airport

Objections

See Appendix D for the list of objections to this policy

Main Issue
 inappropriate development in the Green Belt

Inspector's Considerations and Conclusions

1.6.12.1    The policy has been deleted in favour of Local Policies CH1 and CH2. While this
            resolves the objection to Policy TRP12, the outstanding objections in respect of
            Policies CH1 and CH2, including the issue of inappropriate development in the
            Green Belt, are considered in Volume Two of the report.

Recommendation

1.6.12.2    No modification be made to the Plan in response to this objection.




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TRP13             New Petrol Filling Stations

Objections
See Appendix D for the list of objections to this policy

Main Issues
 preclusion of Green Belt sites
 definition of appropriate intervals
 provision for a new Motorway/Trunk Road Service Area at Junction 11A of the M5

Inspector's Considerations and Conclusions

1.6.13.1      The policy seeks to control the development of new petrol filling stations and
              other roadside service facilities in the interests of road safety and so that they do
              not have an adverse visual impact, particularly in the AONB. It precludes new
              petrol filling stations and services from the Green Belt, encourages new
              developments to group together to form key sites, and requires new facilities to be
              spaced at appropriate intervals.

1.6.13.2      As the Council has stated in its response to the related objections, the policies in
              the Green Belt Chapter would apply to any proposals to develop a petrol station or
              related services in the Green Belt. It therefore makes little sense to preclude such
              development from the Green Belt in this policy if it is to be considered against
              other Green Belt polices in the Plan. The reference to the Green Belt should be
              deleted. In response to the request that the policy should allow for Green Belt
              sites, I do not consider that there is any justification for making an exception for
              this type of development in general in the Green Belt.

1.6.13.3      There is nothing to indicate that restricting the number of petrol filling stations
              would automatically lead to a reduction in the number of people using cars. Each
              application for a petrol filling station would be considered on its own merits,
              including proximity to other similar facilities, need and any other relevant matters.

1.6.13.4      The site-specific case in respect of the Junction 11a site is considered together
              with other linked objections under Policy TRP15.

Recommendations

1.6.13.5(i)          Policy TRP13 be modified by the deletion of the words `...that they are not
                     within the Green Belt…’ from the policy.

           (ii)      No other modification be made to the Plan in response to these objections.




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TRP14           Refurbishment of Existing Petrol Filling Stations

Objections

See Appendix D for the list of objections to this policy


Main Issue
 need for additional criterion

Inspector's Considerations and Conclusions

1.6.14.1    As amended in the RDDLP, Policy TRP14 requires that proposals to refurbish
            and/or intensify the use of existing petrol stations should be appropriate to their
            setting and not have any adverse environmental, highway or safety impact. In my
            view the amended policy is a satisfactory response to the objection and a criteria-
            based approach would not enhance its clarity or conciseness.

Recommendation

1.6.14.2    No modification be made to the Plan in response to this objection.




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        TRP15             Motorway Service Areas

        Objections

        See Appendix D for the list of objections to this policy


        Main Issues
         appropriateness in the Green Belt
         impact on traffic, crime, noise and pollution levels in Brockworth/Hucclecote
         need for the proposal

        Inspector's Considerations and Conclusions

        1.6.15.1     Policies TRP15 and TRP23 of the Deposit Draft have been deleted from the
                     RDDLP. The former provided for a new motorway service area (MSA) at the
                     M5/A417 junction, while the latter stated that the Council would support
                     proposals to improve the junction to provide full access to and from the motorway
                     in both directions. Concurrently with the Inquiry, an appeal against the failure of
                     the Council to determine an application for an MSA and trunk road service area
                     (TRSA), park and ride (P&R) facility and an all-movements-junction (AMJ)1 on
                     the site was before the Secretary of State. His decision to refuse the application
                     was issued in August 2002 (ref: APP/G1630/A/00/1051926). The Secretary of
                     State’s decision, together with the proposed deletion of the policies in the
                     RDDLP, would effectively resolve the concerns raised under the first two issues.

        1.6.15.2     In respect of the need for an MSA/TRSA at this location, this matter has been
                     taken into account in the Secretary of State’s decision. He concluded that in terms
                     of environmental cost, this particular site was not bettered by any alternative sites
                     in the locality for servicing both motorway and trunk road traffic, but that this did
                     not outweigh the harm identified in the absence of a strong need argument. None
                     of the evidence, including some new material on sleep-related accidents, that has
                     been submitted in connection with the linked objections supporting the proposal
                     would lead me to conclude differently from the Secretary of State on this matter.
                     Nor has there been any material change in circumstances since the appeal was
                     determined. And as far as the linked case for a P&R development on the site is
                     concerned, nothing in the evidence before me leads me to a different conclusion
                     from the Secretary of State on this matter. I have concluded in respect of the
                     related Green Belt objection that there is insufficient justification for removing the
                     proposal site from the Green Belt. The objections to Policy TRP23 are considered
                     elsewhere in the report, but nothing in the MSA/TRSA case put forward in the
                     objections alters my conclusion that this is a matter that is not appropriately
                     included in the Plan. Any benefits that might flow from a developer-funded
                     improvement of the junction would not outweigh the harm that would be caused
                     to the Green Belt by the MSA/TRSA proposal.

1
    The AMJ proposal was withdrawn.
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1.6.15.3   Another objection seeks the replacement of the policy by a criterion-based one,
           but I do not find enough evidence of any need for such a policy in the Plan.

Recommendation

1.6.15.4   No modification be made to the Plan in response to these objections.




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TRP16        Parking Standards
Objections

See Appendix D for the list of objections to this policy


Main Issues
 compliance with PPG13
 residential parking standards
 standards for locations well served by public transport
 reduced standard for affordable housing


Inspector's Considerations and Conclusions

1.6.16.1    In accordance with Policy TRP16, the provision of vehicle parking spaces would
            be required for new developments on the basis of maximum standards for various
            use classes set out in Appendix 5 of the Plan.

1.6.16.2    These standards accord with guidance in PPG13 so far as they are maximum
            standards. However, they are not consistent with Annex D of PPG13. For
            example, PPG13 states that the maximum standard for Food Retail (over 1000sq
            m) is 1 space per 14sq m, whereas the maximum standard in Appendix 5 of the
            Plan is 1 space per 10sq m. The PPG13 standards should be applied as maxima
            throughout England for developments above the relevant size thresholds. Also,
            Appendix 5 does not accord with the parking standards and strategy in the LTP
            and in particular, with the standards set out in section 5.12.5. The RDDLP should
            be modified so that it is consistent with the LTP’s parking standards and strategy,
            and it should reflect the two distinct Strategy Areas of the Severn Vale and the
            remainder of the County in the LTP framework.

1.6.16.3    The proposed residential parking standards are too generous compared with the
            advice in paragraph 62 of PPG3. It states that standards that result, on average, in
            development with more than 1.5 off-street car parking spaces per dwelling are
            unlikely to reflect the Government’s emphasis on securing sustainable residential
            environments. This is further supported by the LTP, which sets a standard of 1.5
            spaces per dwelling, averaged out over a whole development. This standard
            should be reflected in the Plan.

1.6.16.4    The policy needs to reflect the rural nature of the Borough. But a more flexible
            approach to lower parking standards in areas well served by public transport, such
            as town centres, would accord with advice in PPG13 and should be included in
            the text of the policy. PPG13 allows authorities to use their discretion in setting
            levels of parking for small developments to reflect local circumstances. This
            would cover most development in the rural areas of the Borough.

1.6.16.5    In accordance with paragraph 14 of Circular 6/98 (Affordable Housing),
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               authorities should consider lower parking standards for affordable housing where
               car ownership rates are generally lower. However, this advice pre-dates PPG13
               and the shift to maximum rather than minimum standards of provision. In any
               event, the rural nature of the Borough and the importance of access to
               employment and services for those living in affordable housing leads me to
               conclude that in general the standards applicable to general market housing should
               also apply to affordable housing. This should not preclude a more restrictive
               approach to parking standards being taken in town centres and locations with
               good access to public transport.

Recommendations

1.6.16.6 (i)       Policy TRP16 and Appendix 5 of the Plan be modified so that:-

                          a) they accord with the advice in PPG13 and the parking standards and
                             parking strategy of the LTP. The standards in Appendix 5 of the Plan
                             should be based on those in the LTP, Section 5.12.5, Tables A and B,
                             in a way that is appropriate to the context of the Borough, and

                          b) the policy indicates that a more restrictive approach to parking
                             standards would be taken in areas well served by public transport.

                   (ii)      The reasoned justification for Policy TRP16 be modified accordingly.

                   (iii)     No other modification be made to the Plan in response to these
                             objections.




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TRP17               Commuted Sums for Parking

Objections

See Appendix D for the list of objections to this policy


Main Issue
 use of commuted sums for car parking provision

Inspector's Considerations and Conclusions

1.6.17.1       In accordance with paragraph 86 of PPG13, it is inappropriate for a local authority
               to seek commuted payments solely because of lack of parking on the site.
               Commuted sums could be used for provision of a park and ride facility, or to
               introduce parking controls in the vicinity of the site, but a policy is not required in
               this regard. Policy TRP17 should be deleted in favour of Policies GEN11 and
               TRP1, as proposed to be modified, which provide the policy framework for
               assessing proposals for new development, including the suitability of the proposed
               access arrangements.

Recommendation

1.6.17.2 (i)        Delete Policy TRP17 and the reasoned justification.

           (ii)     No other modification be made to the Plan in response to these objections.




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TRP19              Piffs Elm-M5 Junction 10 (A4019/Withybridge Lane Junction
                   Improvement Proposals)


Objections
See Appendix D for the list of objections to this policy

Main Issues
 need for consultation with the Highways Agency
 need to upgrade to a full interchange

Inspector's Considerations and Conclusions

1.6.18.1       The policy seeks to support the improvement of Junction 10 of the M5 and in the
               meantime advocates the improvement of the junction between the A4019 and the
               M5 and Withybridge Lane.

1.6.18.2       The Highways Agency is a statutory consultee and as such it would be consulted
               about any proposals affecting a trunk road or motorway. No modification is
               required in response to this issue.

1.6.18.3       Paragraph 5.21 of PPG12 states that local plans should elaborate the detail of
               transport proposals where a particular preferred proposal has been identified at the
               regional or strategic level. This is not the case here. Although the GSPSR
               includes a statement that the County Council will seek measures to overcome
               safety and other problems arising from the restricted access at Junction 10, the
               Highways Agency has no plans to upgrade this junction. The Council’s obvious
               desire to seek improvements here is a matter for discussion with the County
               Council, but it does not constitute an appropriate local plan policy that is capable
               of implementation. Therefore, the policy should be deleted.

Recommendations

1.6.18.4 (i)       Delete Policy TRP19 and the reasoned justification from the Plan.
                   (ii)   No other modification be made to the Plan in response to these
                          objections.




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TRP20              Pedestrian and Cycleway Networks

Objections

See Appendix D for the list of objections to this policy

Main Issues
 overlap with other policy
 means of implementation

Inspector's Considerations and Conclusions

1.6.19.1       The policy seeks contributions from developers in respect of access to new
               developments from cycle and pedestrian routes.

1.6.19.2       Policy TRP20 duplicates the provisions of Policy TRP1 (as recommended for
               modification), which deals with access to new developments by pedestrians and
               cyclists, and it overlaps with specific local policy requirements for improvements
               to pedestrian and cycleway networks. The Plan should be read as a whole and
               there is nothing that could be achieved by Policy TRP20 which could not be
               achieved by Policy TRP1 and specific local policies. In the interests of a more
               concise Plan, the policy should be deleted.

1.6.19.3       The means of achieving the policy’s objective has been questioned, given the
               absence from the Plan of identified pedestrian and cycleway networks. In
               accordance with my recommended modification to Policy TRP5, a clear set of
               proposals for the enhancement and development of cycleway networks in the
               Borough would be brought forward, thus addressing part of this concern.
               However, there remains a need to identify the main pedestrian networks in the
               Borough and to set out a policy for their protection and improvement. Without
               this, the development of the LTP strategy and the implementation of particular
               local policies could be frustrated, and the overall objective of encouraging
               walking would not be achieved. Accordingly, a new policy for the protection and
               enhancement of identified pedestrian networks is required.

Recommendations

1.6.19.4 (i)       Policy TRP20 and the reasoned justification be deleted.

                   (ii)    The Plan be modified by the addition of a new policy entitled
                           `Pedestrian Networks’ which safeguards the line of the main
                           pedestrian networks as shown on the Proposals Map, identifies any
                           areas of particular importance for protection or improvement (eg
                           routes within town centres, routes to schools or employment areas,
                           links into the countryside) and requires new development to respect
                           the networks and provide links into them where appropriate.

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               (iii)   The Proposals Map be modified accordingly.

               (iv)    A reasoned justification for the new policy be included in the Plan
                       which explains the role of the networks, including any differentiation
                       between primary and secondary routes, and explains the contribution
                       that can be made by new development to enhancing these facilities.

               (v)     No other modification be made to the Plan in response to these
                       objections.




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TRP22        Tewkesbury Northern Bypass Corridor Protection

Objections

See Appendix D for the list of objections to this policy

Main Issues
 need for the NRR
 environmental damage
 need to protect the route

Inspector's Considerations and Conclusions

1.6.20.1    The policy identifies the Northern Bypass Corridor (NRR) for protection against
            development that would prejudice any future development of the road scheme.

1.6.20.2    The majority of the objections are concerned with the first two issues. In my view
            these objections are satisfied by the amendment of the policy in the RDDLP,
            which recognises that the County Council has resolved not to proceed with
            construction of the by-pass. The outstanding matter therefore is whether there is a
            need to maintain the protection of the possible route.

1.6.20.3    It is clear from the Tewkesbury/Ashchurch Area Strategy of the LTP (CD29) that
            the public has been widely consulted about the NRR. The results of the
            consultation show that while there is support among some residents for all or part
            of the NRR scheme, significant reservations remain. The Council has decided to
            implement a traffic management scheme instead, to improve environmental
            conditions and safety in Tewkesbury Town Centre in the short to medium term.
            Policy TRP22 seeks to protect the route of Phases 1, 2 and 3 of the NRR in case
            they are needed in the long term to serve the future development needs of
            Tewkesbury and Ashchurch. This is a responsible approach that takes account of
            the potential economic, social and environmental needs of the town in the future.
            PPG13 Annex C, paragraph 4 requires that alternatives to new road schemes
            should be explored before any road scheme is considered. The protection of the
            road corridor, as provided for by the revised Policy TRP22, would not remove the
            need for suitable alternatives to be explored if and when required.

Recommendation

1.6.20.4    No modification be made to the Plan in response to these objections.




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TRP23        M5 Junction 11a Improvement

Objections

See Appendix D for the list of objections to this policy

Main Issue
 need to improve traffic flows on surrounding local roads

Inspector's Considerations and Conclusions

1.6.21.1    The RDDLP deletes Policy TRP23 of the Deposit Draft. While the Council recognises the
            advantages of an all-movements junction, it notes that there is also a perception that these would
            be outweighed by the detriment caused to the local environment by attracting additional traffic
            onto the local highway network.

1.6.21.2    The Highways Agency has indicated that there are no current plans to upgrade this
            motorway junction. In these circumstances I consider that it would not be
            justified to re-instate the policy. I refer also to my comments under Policy TR19
            about appropriate transport proposals in local plans, and to Policy TRP15 where
            linked objections in connection with a motorway service area, trunk road service
            area and park and ride proposal are considered. The deletion of Policy TRP23
            would not prevent traffic management issues being addressed in consultation with
            the County Council, Gloucester City Council and the Highways Agency. Also,
            the evaluation of travel patterns and the need for any highway works can be
            addressed in the future as the development of Gloucester Business Park and the
            new residential area at Brockworth advances.

Recommendation

1.6.21.3    No modification be made to the Plan in response to these objections.




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TRP24           Pedestrian Domination in Tewkesbury Main Streets

Objections
See Appendix D for the list of objections to this policy

Main Issue
 prematurity

Inspector's Considerations and Conclusions

1.6.22.1    The policy sets out the Council’s intention to implement a traffic management
            scheme in Tewkesbury town centre to secure a more pedestrian-friendly
            environment.

1.6.22.2    Both objections raise the need to await the outcome of the consultation exercise
            on the proposed Northern Bypass. Clearly these objections have been overtaken
            by events since they were lodged. The consultation exercise is now complete and
            the decision has been made not to proceed with by-pass and to implement traffic
            management measures in Tewkesbury town centre instead. The amended policy
            in the RDDLP reflects this outcome and no modification is required in response to
            the objections.

Recommendation

1.6.22.3    No modification be made to the Plan in response to these objections.




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TRP25           Traffic Management

Objections

See Appendix D for the list of objections to this policy

Main Issues
 relationship with specific proposals
 implementation of phase 1 of the NRR as a prerequisite
 effect on passing trade for retailers

Inspector's Considerations and Conclusions

1.6.23.1    The amended policy in the RDDLP sets out the Council’s intention to identify and
            implement traffic management schemes in the Borough in conjunction with the
            County Council.

1.6.23.2    The policy is a general statement of intent that relates solely to highways, not
            planning matters. The LTP, section 5.13, sets out the County Council’s objectives
            and strategy for traffic management in the County. This is a more appropriate
            context for dealing with generic Borough-wide issues concerning traffic
            management. The Plan should be read in conjunction with the GSPSR and the
            LTP and should include matters that relate to development control such as the
            extent, context and design of actual traffic management proposals. As advised by
            paragraph 5.7 of PPG12, local plans should contain precise details of
            implementation in a particular town centre. In the absence of a detailed traffic
            management proposal, the policy should be deleted.

1.6.23.3    The NRR proposal has been removed from the Plan and it has been decided to
            proceed with a traffic management scheme in Tewkesbury town centre. This
            accords with the broad intent of national transport policy to consider all plausible
            options before a new road is built. On this basis I do not consider that traffic
            management in the Borough can, or should be dependent upon the completion of
            phase 1 of the NRR. In any event, the deletion of the reference to the NRR in the
            reasoned justification in the RDDLP resolves this matter.

1.6.23.4    It is the stated policy of the County Council, as highway authority, to consult with
            all stakeholders in the design and implementation of traffic management schemes.
            This is detailed in Section 2.1 of the LTP. Retailers affected by proposed schemes
            would be consulted and would have the opportunity to raise their concerns at the
            appropriate time.

Recommendation

1.6.23.5    The Plan be modified by the deletion of Policy TRP25 and its reasoned
            justification.

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TRP26           A48(T) Minsterworth

Objections

See Appendix D for the list of objections to this policy

Main Issue
 relationship with specific proposals

Inspector's Considerations and Conclusions

1.6.24.1    The policy is deleted in the RDDLP as a result of the implementation of a traffic
            calming scheme on the A48(T). The objection has effectively been resolved.

Recommendation

1.6.24.2    No modification be made to the Plan in response to this objection.




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TRP27           Support for Restoration of Gloucestershire Warwickshire
                Railway (formerly TSM12 - amended)

Objections
See Appendix D, under TSM12, for the list of objections to this policy

Main Issue

 justification for reference to the establishment of a long-distance footpath/cycleway

Inspector's Considerations and Conclusions

1.6.25.1   The policy supports the restoration and safeguarding of the route of the
           Cheltenham to Stratford-upon-Avon railway line. It also states that the
           implementation of the scheme should not compromise the establishment of a long
           distance footpath/cycleway alongside the permanent way.

1.6.25.2   The Council considers that there is no compulsion in the policy for
           Gloucestershire Warwickshire Steam Railway PLC (GWSR) to co-operate with
           them in the implementation of a long-distance footpath/cycleway to run alongside
           the rail line. Nonetheless, the wording of the policy suggests that the Council
           might intervene to prevent development that could compromise the establishment
           of a footpath/cycleway, even though it has no power to control development along
           the route that is subject to the provisions of the 1983 Light Railway Order.

1.6.25.3   The likely proximity of the proposed footpath/cycleway to the rail line has not
           been established, but GWSR considers that it would be impractical to run it
           alongside the rail line and that it would compromise the operation of the railway.
           In accordance with paragraph 5.22 of PPG12, local authorities should consult with
           appropriate transport infrastructure authorities to ensure the feasibility of schemes
           commencing within the lifetime of the Plan. It is clear that GWSR as the operator
           and owner of the railway and route was not consulted about any plans for a
           footpath/cycleway prior to the Deposit Draft Plan. Also, there is no evidence that
           SUSTRANS has any definite proposal to use the route as part of the national cycle
           network. The fact remains that the GW Railway is a fully operational rail line and
           that opportunities to develop the footpath/cycleway alongside it are limited. The
           policy does not fully recognise this fact and the implications of such a scheme do
           not appear to have been properly explored.

1.6.25.4   Given that the Council has acknowledged that this element of the policy cannot be
           implemented through compulsion, I see little merit in retaining it in the Plan. I
           also refer to my recommendation on Policy TRP5 (Cycle Facilities) and
           recommend that any reference to the use of the route for a footpath/cycleway
           should be confined to the reasoned justification of Policy TRP5. The wording
           should explain that the Council, together with SUSTRANS, will explore
           opportunities to use the route for the development of a footpath/cycleway in a way

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               that would not compromise its operation as a rail line for through-running trains.

Recommendations

1.6.25.5 (i)       Policy TRP27 be modified by the deletion of the final sentence.

                   (ii)    The reasoned justification for Policy TRP27 be modified by the
                           deletion of the final two sentences.

                   (iii)   The reasoned justification for Policy TRP5 be modified to explain
                           that opportunities to develop a footpath/cycleway along the route of
                           the GW Railway in a way that would not compromise its operation
                           for through-running trains will be explored by the Council and
                           SUSTRANS in conjunction with the railway company.

                   (iv)    The Council should consider whether or not to include the proposed
                           footpath/cycleway route on any map given the uncertainties
                           surrounding its implementation and the fact that it is not able to
                           safeguard the line for this use.

                   (v)     No other modification be made to the Plan in response to the
                           objection.




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TRP          Traffic – New Policy

Objections
See Appendix D for the list of objections on this matter

Main Issues
 protection of public transport facilities and infrastructure from development that would
  impair their function
 protection of facilities for the transport of freight by rail, pipeline or waterway,
  particularly in the Ashchurch area
 need for policy linkage with the Gloucestershire Lorry Strategy
 need for traffic reduction measures on the A46, A38 and around Junction 10 of the M5

Inspector's Considerations and Conclusions

1.6.26.1   Policies T.4 and T.6 of the GSPSR already deal with the first issue. The Plan
           should include policies that relate to specific proposals or to specific measures.
           The new policy proposed by the County Council is strategic in nature and applies
           to all the districts generally, rather than relating specifically to the Borough.
           Following the advice in PPG12 I do not consider that it would be appropriate to
           include this proposed new policy in the Plan.

1.6.26.2   With regard to the need for a freight transport policy, Policy T.13 of the GSPSR
           seeks to encourage the development of facilities for freight carriage by rail,
           pipeline or waterway, while Policy T.6 requires the safeguarding of land for new
           or re-opened rail facilities, including those for freight handling. There is no need
           to repeat this broad policy framework in the local plan. However, the omission of
           a specific safeguarding policy for Ashchurch’s freight handling facilities is subject
           to an objection lodged at the Deposit Draft stage. In response to this a new Policy
           TRP29 was brought forward for consideration by the Council but was not
           included in the RDDLP. In my view there is a need for a specific policy for
           Ashchurch that identifies the importance of its current and potential future roles in
           rail freight handling and transfer. This would give effect to the GSPSR’s strategic
           policy framework, which reflects national policy to encourage the transfer of
           freight by sustainable modes, and it would help to ensure that future development
           proposals for the MoD site and adjacent lands take full account of rail freight
           matters. It would also accord with the County Council’s Rail Freight Strategy
           which identifies the potential of Ashchurch in this regard. There is no reason to
           expect that the local road traffic impact of new rail freight development at this
           location could not be properly managed. I consider that the suggested wording of
           the draft policy TRP29 would be appropriate.

1.6.26.3   A separate but complementary proposal for the allocation of land at Aston Fields
           for housing, community and employment uses, including a new rail freight
           terminal, is brought forward in one of the objections to the Plan. This is

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                       considered elsewhere2 where I recommend that it should not be included as an
                       allocation. But this is not to dismiss the potential for developing rail freight
                       facilities at Ashchurch, whether by expanding the use of the existing MoD depot
                       or in some other way.

         1.6.26.4      Turning to the third issue, this matter is already dealt with in Policies T.11 and
                       T.12 of the GSPSR and in my view these are sufficient to address the general
                       issues concerned. If the Council had identified a particular location where lorry
                       movements were a problem and tried to address this by specific measures, then it
                       would have been appropriate to include this as a proposal in the Plan, with
                       reference to the Gloucestershire Lorry Strategy. However this is not the case here.

         1.6.26.5      In respect of the fourth issue, unless there are specific proposals to reduce traffic
                       flows on these roads it would not be appropriate to include reference to them in
                       the Plan. Although improvement works are on-going on the A46 at Ashchurch,
                       no specific schemes for inclusion under this heading have been identified on these
                       parts of the network. Nonetheless, the reduction of traffic flows and the promotion
                       of alternative modes of travel to the car are County- and Borough-wide objectives
                       that are promoted in the LTP. The potential for improvements at Junction 10 of
                       the M5 is considered under Policy TRP19.

         Recommendations

         1.6.26.6(i)        The Plan be modified by the inclusion of a new policy entitled
                            `Protection of Potential Freight Railheads’ as follows:

                            `The railway siding at Ashchurch as identified on the Proposals Map will be
                            protected from development which would prejudice its future use as the
                            access for a road-rail interchange facility.’

                    (ii)    A reasoned justification for the new policy be added as follows:

                            `In furtherance of a sustainable transport network it is important to enable the
                            transfer of freight traffic between road and rail. Apart from the requirement
                            for rail access, potential sites must also be well located on the principal
                            highway network. The Gloucestershire Structure Plan Second Review has
                            indicated that there is one location within the Borough which could fulfill the
                            role of a railhead; this is at Ashchurch. Whilst the development of such a
                            facility is unlikely in the short term, it is important that the potential for such
                            a use is protected. Any such proposal would be subject to the provision of
                            appropriate highway and other infrastructure and environmental mitigation
                            measures’.

                    (iii)   The Proposals Map be modified accordingly.

                    (iv)    No other modification be made to the Plan in response to these objections.




2
    See LPOLNP Ashchurch - Aston Fields in Volume Three. .
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