Protect Rural Peterborough
41 Peterborough Rd
8th February 2017
Peterborough Local Plan Consultation
Sustainable Growth Strategy
Peterborough City Council,
cc Shailesh Vara MP, John Holdich OBE, Peter Hiller
Peterborough City Council Draft Local Plan December 2016
Site AIL002Uii. Land North of Ailsworth and Castor (Great Kyne) East
Response to the Draft Local plan by: Protect Rural Peterborough (PRP) campaign
Dear Sir/ Madam,
The campaign group was formed after a village meeting in November 2016, where 300 people rejected the City Council’s Draft local plan proposal to locate 2,500 houses + commercial /Industrial usage, a cemetery and considered University facilities, on a greenfield site, comprising pristine rural landscape, and adjacent to a National nature reserve and SSSI site.
The land is in the parishes of Ailsworth & Castor and at its closest point is 100m from the Ailsworth Conservation area. It is also within 200m of the small village of Upton and a similar distance from Castor Hanglands. The site is on prominent rising land in the Nene Valley and on the limestone Nassaburgh plateau on the western “best landscape” approaches to Peterborough along the A47. The proposed large settlement would lie within the parishes of Ailsworth and Castor and would overshadow the villages and conservation areas of Castor & Ailsworth and the Nene Park Trust rural estate beyond. The site is 4 times the size of Castor & Ailsworth combined and is a staggering 100 times the size of the small Village of Upton.
In addition to the backing of residents, the campaign group also has the support of the Ailsworth Parish Council, Castor Parish Council, Sutton Parish Council, the people of Upton, our local Ward Councillors and Shailesh Vara our MP. PRP also works closely with the Castor & Ailsworth Neighbourhood Plan team and has their full support.
During the campaign, we have established relationships with local, regional and national organisations, who share our concerns with the inevitable negative impact that a large single development would have on the landscape, its wildlife and biodiversity and nearby villages. Many of whom will be responding to the consultation directly.
The PCC Sites Evidence report, one of the Local Plan’s supporting documents, states “this is the most sensitive area within Peterborough Unitary Authority in terms of both scheduled and unscheduled remains”. The site and surrounding area is rich in archaeological and historical remains, with significant evidence of major Roman, Saxon and prehistoric settlements. The site also features ancient trackways and Medieval lanes for passage and droving, both within and immediately adjacent to the proposed site. The distinctive rural character, has direct links to the fact that the Parishes were some of the last to be enclosed in the late-19th century, under the Enclosure Act. One of the nation’s finest Norman churches has been visible from the surrounding countryside for nearly 1000 years.
Indeed, PCC’s own LDP site assessments suggest that “In addition to impacts of CWS, there are several SSSI’s that may potentially be affected” and “This is the most sensitive area within the Peterborough Unitary Authority in terms of both scheduled and unscheduled remains”. PCC’s own Hierarchy Study (2007) says “substantial development would be incompatible with the character and scale of the villages and its setting in the landscape”
This response is written on behalf of the Protect Rural Peterborough campaign group, which objects to the Local plan published in December 2016, on the following basis:
The Plan’s own strategy is unclear
1) PRP challenges PCC’s OAN, originally assessed at 25,125, and increased by 2,500 to 27,625, following a memorandum of understanding from Cambridgeshire County Council. Surely this understanding is only appropriate if housing can be delivered on sustainable brownfield sites. To sacrifice a pristine piece of rural countryside rich in wildlife and heritage for the sake of houses needed elsewhere must be questioned by Peterborough City Council.
2) The Growth Strategy Evidence report, despite being referred to as the evidence base on which this and other site allocations were made, does in fact not exist. The reason given is that it had insufficient evidence to warrant publication and will be published later in the consultation process. Potentially in the Autumn of 2017.
As the evidence is deemed by PCC Planning as insufficient, it is unclear on what basis the sites were allocated, although on examination of the Sites Evidence report it shows that sites were allocated in many cases, and particularly this one, without due consideration to the facts of the assessment.
3) The Plan itself sets out policies relating to Urban areas, Village envelopes and Rural areas. The proposed large settlement is NOT within an Urban area. It is also NOT within a Village envelope. Therefore, by process of elimination, it must be in a rural area. So therefore, policy LP2 applies, which states that any building in the Rural area, should only be considered for the provision of housing for agricultural workers for required proximity to their employment.
4) The City Council and its Local Plan Vision refers to a ‘Characterful network of villages in an attractive rural landscape’. And yet, the proposal is to locate a large urban settlement, in attractive rural landscape, in the middle of the characterful villages of Sutton, Upton, Ailsworth and Castor. It directly contradicts its own vision and seems at odds with the city’s ambition to be the Environment Capital of the UK.
5) Despite the Site Evidence Report Selection Criteria showing that the Great Kyne site has many ‘red and amber WARNING lights it has still been assessed as a ‘preferred’ site when many other ‘rejected’ sites have indeed scored considerably better. Great Kyne has an understandable 9 Reds and 10 Ambers which is significantly more than most 'rejected' sites in our sample. (see Appendix Three).
How can you say in your comments on that report and site that there are only "minor constraints"? That should be applied to very many of the rejected sites, some of which are in our table as more relevant examples.
Rather than take into account the plans Visions and objectives has this proposed allocation been graded as preferred due to the landowner being HCA? Has PCC succumbed to Government pressure despite the fact that this greenfield site does not comply with many of your local planning policies as evidenced in our letter and many residents' letters and from local, regional and national organisations.
We do not consider that PCC is justified in releasing a greenfield site to meet the needs of another Local Authority (Cambridgeshire County Council). We know that Peterborough has alternative brownfield sites and other, more suitable sites that were proved more appropriate in many respects in your Sites Evidence report, let alone other neighbouring councils
6) The Objectively assessed housing need has been based on pre-Brexit population growth trends and outdated employment figures. Indeed, the latest Employment rates (January 2017) show a downward trend since the LDP was issued. Other Councils have taken the view, that with this level of uncertainty, it would be prudent to put on hold their local planning, with a view to adjusting those plans, when a clearer picture of inward migration is available. Surely this should apply to Peterborough, with its previously high levels of external migration over the past decade or so.
We also object from a site perspective
7) Wildlife and Biodiversity will be seriously impacted and destroyed
a. Castor Hanglands is a National nature reserve and SSSI site managed by Natural England and hosts ponds with the richest biodiversity anywhere in the UK (Freshwater Habitats Trust). Wildlife organisations advise that any development within 500m of these type of sensitive areas, would have a serious impact on small mammals, Amphibians and Birds, due to disruption from dog walking and domestic Cat predation. Mitigation measures at Hampton Nature reserve are reported by both City Council Officer and a Wildlife charity, as having been a ‘compete failure’
b. The site and surrounding area is home to 121 animal species, which are listed under Section 412 of the NERC Act (2006) and are UK BAP Priority Species.
8) Archaeology and the ancient and fragile landscape will be significantly impacted
a. Multiple archaeological sites with evidence from Bronze and Iron age people, Roman occupation and Saxon farmsteads through to Medieval farming
b. A detailed report by Dr Stephen Upex, a national authority on the Archaeology of the Nene Valley, highlights 28 sites on the proposed development land. Many of which would be regarded as archaeologically significant with large scale open area excavation being required should there be any change to the land use. These requirements would further question the overall viability of the site and would lead to protracted and costly survey work, which would also lead to a slower pace of development and deliverability
9) Flood risk and infrastructure – it is not enough to plan for ‘no unacceptable increase in flood risk’ it should ensure NO increased flood risk
a. The Plateau and its Limestone is highly permeable, therefore any development will significantly reduce rainfall soaking to ground and would significantly increase the amount and velocity of surface water run-off, increasing the risk of flooding downstream
b. Despite the flood alleviation scheme which has existed to protect Castor & Ailsworth, there is often flash surface water egress at the north end of Ailsworth and in parts of Peterborough Road, Castor
10) Overall rural and landscape character – the proposed site is in some of the area’s best open countryside, and is shown as “High” in your Selection Criteria for Sites Evidence report, however
a. PCC’s own policy on ‘Landscape character LP26’ states that any development should “enhance the character and qualities of the local landscape”
b. It is scarcely credible to suggest that a 2500 dwelling development with light industrial and logistics areas would be consistent with Policy LP26
c. It will therefore remove rather than “enhance important views” of the Nene Valley, including the Hanglands and St Kyneburgha Church specifically, both from within the area, the villages, Nene park Trust rural estate and the western approaches to Peterborough along the A47.
The villages of Castor and Ailsworth are not averse to growth and development as evidenced by absorbing 75 homes over the last 10 years and with Neighbourhood Plans proposing a further 50 homes. This represents a total of 125 homes a 25% growth over 30 years.
The Great Kyne site makes up an area used by residents of Peterborough for walking, cycling and other outdoor pursuits and its ecology, biodiversity and historic remains should not be overlooked. Peterborough’s immediate countryside should be enjoyed by the people of Peterborough and protected for future generations and not traded for gain to ease housing issues elsewhere in the country.
A draft local plan was published a week before Christmas with an initial closing date of the 26th of January 2017. Under challenge from the PRP team it was acknowledged by PCC planning that holding a public consultation over the festive season thereby resulting in only three weeks in review and comments was unsatisfactory for proper consultation. We welcomed the fact that PCC planning then extended the consultation period to the 9th February.
However, we subsequently identified the absence of the Growth Strategy Evidence Report and challenged both its omission, and requesting a delay to the consultation, until it has been provided, to enable proper review and comment. This request was rejected by PCC planning and it was indicated that the growth Strategy Evidence Report would be issued three days later on Friday the 13th of January. When that date arrived PCC planning advised that the report would now not be made public as it contained insufficient evidence.
In our view and to quote the views of our own MP, ‘this has made a mockery of the consultation process. More seriously he has criticised the PCC for moving the ‘’goalposts’’, and re-naming it as a less significant Growth Study. This will summarise the evidence towards the end of the plan process in Autumn 2017, rather than at the commencement of the consultation process when it would have been most useful to enable proper review and comment on the plan. We would concur with our MP’s assessment as we estimate the PRP team have collectively spent over 1000 hours reviewing the many documents as part of our response and likewise many residents have also wasted many hours trawling through the documents looking for the same evidence.
The PRP remains perplexed by the numerous inaccuracies, missing supporting evidence and contradictions that are contained, or indeed, not contained in PCC’s LDP. The absence of the critical Growth Strategy, which is referenced several times throughout the LDP, indicates that PCC embarked on the LDP in a state of disorganisation and questions the overall validity of the LDP as it stands.
We also note that the Further Draft Local Plan of December 16 shows in 7.3, that the site allocation named Great Kyne East had a Status which was live at 1 April 2016. How was it that this was not notified to the Parish Councils and communities until six months later? The cynical amongst us might think that this was a deliberate withholding of information to reduce the time available for the parties mentioned to respond! It could be argued that such a delay was in breach of the Plan Process.
The proposed Great Kyne development, which was also a late submission to the LDP, is not consistent with many of PCC’s local planning policies and objectives, and presents a serious threat to the character and natural environment to the west of the city. Our own scrutiny of the viability of
this site, would indicate that any developer intent on delivering large scale housing, would struggle to comply with PCC planning policy at every stage of delivery and would indeed face;
We also understand that The Drift, Castor, which bisects the proposed Great Kyne is Common Land protected by the Commons Act 2006, which is a significant constraint on the delivery of the site. Such challenges, in our view make this whole site unviable, unsuitable and undesirable on every level.
PRP’s Review of planning policy is attached to, and forms part of, our objection to the LDP.
Peterborough's countryside gone forever, wildlife decimated and the enjoyment of people of Peterborough, not just the Villages, abandoned. Is this the right way to create the Environment Capital of the UK.
Chair, Protect Rural Peterborough
Appendix 1 – Review of planning policies
Policy LP1: Sustainable Development and the Creation of the UK's Environment Capital.
The Great Kyne site will not “improve the environmental conditions of the area”. It will be within a stone’s throw of the Castor Hanglands, a designated site of special scientific interest and built directly on habitat that according to CPERC contains or supports locally over 121 species, including a number of ‘Red List’ bird species.
Creating a settlement of such size (2500 dwellings) would introduce around 500 or so domestic cats (Mammal Society ratio of pets / dwellings) with all of the carnivorous activity associated with those animals let loose on the unsuspecting fauna in the locale. This takes no account of some 6000 people and their other pets, particularly dogs.
Policy LP2: The Settlement Hierarchy and the Countryside.
Quoting directly from the plan: “A settlement hierarchy also helps to protect the character of the landscape, by maintaining and reinforcing the distinction between built-up areas and countryside, and placing a restriction on the forms of development that would be acceptable in the countryside.” In addition “It is Government policy that development in the countryside should be controlled, in order to conserve its character and natural resources. By identifying the settlement hierarchy and distinguishing between settlements and the countryside, the policy approach places a restriction on the types of development other than those where a rural location might be justified.”
The Great Kyne site is 2500 dwellings with 12 ha of employment land (LP35 and LP40). This is not a small, medium or large village. Neither is it an Urban Extension. The site is ‘countryside’ and therefore there must be compelling evidence to justify this location, Which PCC have not provided.
This evidence is conspicuous by its absence from the proposed draft plan. It should come from the Objectively Assessed Needs. This was meant to be updated in Dec 2016 but has not been made public. The most recent OAN, and the one presumably used to support the Draft Local Plan, is based on an update in 2015 prior to the UK’s historic decision to vote to leave the EU. The OAN is clearly predicated on high levels of net international migration by a ratio of over six to one (3010 to 530). See figure below from SHMAU (Oct 15).