Representation by St. Modwen and Midlands Land Portfolio Ltd (SM&MLPL) (St. Modwen and Midlands Land Portfolio Ltd (SM&MLPL))
- Date submitted
- 22 March 2024
- Submitted by
- Members of the public/businesses
Background 1.1.1 This representation is submitted on behalf of St. Modwen and Midlands Land Portfolio Ltd (SM&MLPL). Savills act as planning adviser to SM&MLPL and are authorised to submit these representations on SM&MLPL’s behalf. 1.1.2 St. Modwen and Midlands Land Portfolio Limited are the joint applicants for the outline planning application (refs: 22/01817/OUT and 22/01107/OUT) at land at West Cheltenham, to the south of Old Gloucester Road. The proposed development has been prepared with regard to the adopted planning policy, the Golden Valley SPD and the emerging proposals of the other principal landowners within the wider A7 West Cheltenham allocation. We have been in regular dialogue with the Junction 10 team for a number of years and we set out our key interests as they currently stand under the following subheadings. Funding Statement The Junction 10 Improvement Scheme is a key piece of infrastructure for the area, which will allow its future residential and economic growth to be fully realised. Given its significance to the West of Cheltenham development and the expectation that we contribute to the scheme we wish to consider the funding statement and the supporting calculations in more detail. This is to ensure we understand the basis of this and the mechanism through which contributions would be implemented, including phasing. Scope of Works 1.1.3 The Scheme comprises the following elements: ? Improvements to M5 Junction 10 ? A new road linking Junction 10 to West Cheltenham ? The widening of the A4019 Tewkesbury Road 1.1.4 We are aware of the extensive option testing that has been carried out to arrive at the proposed Scheme package. It is our understanding from the wider documentation that when funding was being sought in 2020, the core scenario was based on 8,914 homes coming forward up to 2041, and this informed the deselection of other scheme options due to potential traffic capacity issues. We request clarification on the assumptions made in respect of the number of future dwellings, the amount of employment space and the delivery timescales which have informed the selection of the proposed package of works, and what proportion of these figures have been derived from the three major developments set out below, and what relates to additional future needs. Contribution Methodology 1.1.5 The application indicates that the contribution methodology is based on contributions from three major developments, which are: ? Northwest Cheltenham (safeguarded) ? Northwest Cheltenham ? West Cheltenham 1.1.6 We are concerned to ensure that this approach does not place a disproportionate weight on these three developments. In our view, all developments that will increase traffic at Junction 10 and Junction 11 should be included in order to ensure fair and proportionate contributions. 1.1.7 Future developments within the Cheltenham, Tewkesbury and Gloucester area in the period up to 2042 should also be contributing towards the works, through either CIL or Section 106 contributions, and the mechanism should be sufficiently flexible to enable these to be captured. We request that a geographical area and development thresholds should be considered, and provided by GCC. Developer Contributions and CIL 1.1.8 The contribution per dwelling figure could impact upon the viability of the strategic allocations which could affect contributions for other items. The engagement document makes reference to viability in the context of Policy INF7. While tests under Paragraph 57 of the NPPF are referenced within the application, it is important for GCC to clearly set out how the requested contribution accords with the three tests. Transport Modelling 1.1.9 In respect of transport modelling, it is important to assess the percentage impact of each development’s proportion of dependant trips to attribute the level of contributions which has been requested. We note that the assessment of transport impact has been based on the proportion of dependent development trips on both Junction 10 and Junction 11. Our transport modelling work has indicated that a proportion of dwellings at West Cheltenham can come forward prior to the implementation and operation of the Scheme and we note that GCC accept this. We would like to ensure that this quantum is agreed and that the methodology used to attribute these contributions is fair and proportionate. Strategic Local Plan Review 1.1.10 A Regulation 18 Consultation on Spatial options and Key Policy areas for the Cheltenham, Gloucester and Tewkesbury Strategic Local Plan ran from 16th January to 13th March 2024. Consultation on the Draft Site Assessment Methodology (Housing and Economic Land Assessment, 2023) ran over the same period. This provides the SLP Authorities with an opportunity to identify additional development sites that can contribute to the funding. We therefore request confirmation of whether GCC have considered the potential for additional sites to come forward as allocations within the CGTSLP and how these will contribute to the funding for the scheme. Access to West Cheltenham 1.1.11 We have an obvious interest in the link that provides access to West Cheltenham from Old Gloucester Road, including its geometry and land take. We will wish to be involved in discussions with GCC to ensure it is deliverable in accordance with our build-out programme and that this is captured appropriately in the DCO. Utilities, Open Space, Ground Conditions and Drainage 1.1.12 We are concerned to ensure that our development proposals are not adversely affected by utility (including overhead line) diversions, works within planned open space and areas designated for flood attenuation and surface water storage. We will wish to examine any potential permanent or temporary compulsory acquisition of land, the works plans, protective provisions, management plans and requirements. In summary we are concerned to understand the potential interaction of: ? Utilities ? Open Space ? Ground Conditions and Drainage with our development proposals. Summary 1.1.13 We recognise and support the importance of this infrastructure project for the region's growth, wish to ensure it can be delivered efficiently and at the right time. Specifically, we wish to examine the following information: 1. The funding statement, to better understand its basis. 2. Confirmation of the total available funding dedicated to the Scheme from the HIF and GCC. 3. Clarification on the assumptions regarding the number of future dwellings, the amount of employment space, and delivery timescales that informed the selection of the proposed package of works. 4. Information on the comparative costs associated with each of the three main work items. 5. Information about the transport modelling used to assess the percentage impact of each development's proportion of dependent trips. 6. Confirmation on how the requested contribution accords with the three tests under Paragraph 57 of the NPPF. 7. Request for confirmation of whether GCC has considered the potential for additional development sites to come forward as allocations within the CGTSLP, and the implication of this. 8. The access to West Cheltenham from Old Gloucester Road, its programme of delivery, geometry and land take. 9. The potential interaction of utilities and works with open space, ground conditions and drainage associated with our development proposals. 1.1.14 We look forward to further discussions with the Junction 10 team to address these concerns.