Appendix 1 OBJECTIONS BY THE GONERBY HILL FOOT RESIDENTS GROUP REGARDING SITE REFERENCE GRAH3 FOR DEVELOPMENT.

(1) Why we consider greenfield land (Site ref GRAH3) north of Peachwood Close to be unsuitable for the development of 400 houses. The key area of concern to residents of Gonerby Hill Foot and surrounding areas is the increased traffic that will result from this development and the impact of this on an area of the town that is already frequently gridlocked. (1.1) Highways (1.1.1) The addition of multiple cars from 400 homes will place intolerable strain on Stephenson Avenue, Cliffe Road and Hazelwood Drive.

(1.1.2) The projected entrance and exit routes to the estate Beaumont Drive, Applewood
Drive and Hazelwood Drive would result in a change in use of side or access roads into main roads. These roads are not suitable to cope with a large increase in traffic.

(1.1.3) On many occasions Cliffe Road is blocked with traffic and buses are unable to pass. (1.1.4) It is projected that the new development would dramatically increase the flow rate of
traffic, impacting on safety and increasing the necessity for regular and improved road maintenance.

(1.1.5) Beaumont Drive is on a steep incline and is dangerous in freezing weather.

(1.1.6) Applewood Drive, Beaumont Drive and the north end of Hazelwood Drive are all culde-sac developments and not set up to be through roads.

(1.1.7) Hazelwood Drive is not wide at the point where it will go onto the new estate and so
could not safely provide access to it.

(1.1.8) We have been informed that Arnold Avenue may be used as through run for entry to
the estate from Lynden Avenue and Vernon Avenue. This would inevitably bring significant additional traffic onto a very steep hill and an estate that is inhabited by a large number of families with children. There are also concerns about the ability of emergency services to access the area.

(1.1.9) The roads and pavements become seriously dangerous in cold weather with sheet ice
that takes a long time to go away. This is particularly bad on Orangewood Close, where there is only single vehicle access, and also on Cherrywood and Hazelwood Roads. No council clearing takes place on these roads and there is no salt/grit bin.

(1.1.10) Parking on both sides of the road in Hazelwood at the point where it narrows prior to
Cherrywood Road at present hinders access by ambulance or fire engine, and on occasions is only just passable by car.

(1.1.11) Visibility on the corner of Cherrywood Road into Hazelwood Road is currently a
safety issue due to the angle of the road, bushes and parked cars.

(1.1.12) The additional traffic from 400 new houses in this area will make Gonerby Road even
more of a pinchpoint for traffic entering Grantham. At present whenever there is an accident or roadworks on the A1 the traffic is diverted to Gonerby Road, making the town completely gridlocked. These traffic problems already significantly impact on local businesses as people decide to shop elsewhere and visit more accessible out of town restaurants and pubs. It is not

clear from the GAAP whether a relief road bypass will be in place prior to the building of a new estate.

(1.1.13) Planning policy guidance 13 point 5.3 states that local authorities should
accommodate housing principally within existing urban areas, planning for increased intensity of development for both housing and other uses at locations which are highly accessible by public transport, walking and cycling. In addition, point 6.6 states that: Local authorities should ensure that strategies in the development and local transport plan complement each other and that consideration of development plan allocations and local transport investment and priorities are closely linked. In the Gonerby Hill Foot area all public transport ends at 5.30pm and is not available on Sundays.

(1.1.14) Planning policy guidance 13 point 5.10 states that: Local authorities should
protect sites and routes which could be critical in developing infrastructure to widen choices for both passenger and freight movements. Clearly the impact of traffic from 400 new houses would not protect the main route into and out of the town via Gonerby Road.

(1.1.15) Planning policy guidance 13 Linking Planning and Transport point 20.4 states
that local authorities should: Locate day to day facilities which need to be near their clients in local and rural service centres, and adopt measures to ensure safe and easy access, particularly by walking and cycling. Clearly the loss of informal open space and the burden of additional traffic from 400 new houses would not fall within this guidance. There is no planning for improving infrastructure and access to the site through highway development. The only plan is to build a cycle path, although it is unclear where this could be legally and physically sited. (2) Use of Greenfield Site (2.1) Greenfield sites should not be used for building when Grantham and other towns in the East Midlands have numerous brownfield sites that are available for development.

(2.2) In the GAAP document Figure 10 denotes that the land designated for planning is
informal open space. Later in the same document Point 3.1.5.7 states that: All existing open space including, parks, equipped play space, sport pitches and informal natural open space, route ways and corridors will be protected. The document says that development proposals on existing open spaces will only be permitted where it is demonstrated that: (i) The proposal will provide increased or improved open space and /or recreational facilities, or (ii) The site is not required to meet the local standard set out in Policy OSS1 or, (iii) Equivalent (or better) replacement provision is to be made within the same catchment area. We do not believe that there are any plans in place to rectify this and therefore the loss of this land would deprive Grantham of an informal open space and go against the GAAP itself. (3) Use of Brownfield sites (3.1) Vacu-Lug Traction Tyres, Gonerby Hill Foot, which was originally identified within GAAP as a preferred housing allocation site, is a brownfield site that we believe represents an infinitely more sensible option for redevelopment. It would also greatly improve the air quality in an area that is in extremely close proximity to two primary schools and thousands of domestic residences. Although funding was given as an issue for not relocating Vacu-Lug, it is not one that we accept.

(3.2) It would appear that the new location to the north of Peachwood Close has been selected
for its proximity to Vacu-Lug Traction Tyres rather than being the best available site. (4) Schools (4.1) According to our research the two primary schools in the area (Gonerby Hill Foot School

& St. Sebastians) are already at capacity, particularly for Key Stage 1.

(4.2) Children being forced to travel further afield to schools would lead to additional traffic
on the roads at peak times. These roads are already struggling to cope with the current levels of traffic.

(4.3) A new Academy is to be developed on the Central Technology College site, and it is
expected that the number of pupils on this site will double, resulting in double the school traffic and more burden on roads that are unable to cope. (5) Infrastructure

(5.1) The current version of the Grantham Growth Strategy selected other areas of the town in
preference to Grantham North because of the difficulty of providing improved infrastructure to the north of the town. There is currently no traffic relief proposed for this area at all.

(5.2) During winter the estate already experiences significant problems with road safety.
Beaumont Drive and Arnold Avenue are barely passable at times of snow and severe frost.

(5.3) At times of heavy rain the drainage system on the estate is unable to cope, meaning that
some of the roads are flooded and some houses are threatened by water damage including houses on Stephenson Avenue which have had garages flooded by rainwater.

(5.4) When the estate was built residents were informed that the sewerage system put in place
did not have capacity for any further development. There are no plans in place to develop sewerage other than a development of the Marston works, which will not impact on the potential problems on this new development

Points 5.3 and 5.4 above are reinforced in the GAAP Document where, in the Summary of
Assessment it states that Anglian Water have given the overall rating of the site as being amber, where infrastructure and treatment upgrades may be required.

(5.5) The fields for proposed development are heavily clay based, with many natural springs
and are not suitable, in our opinion, for house building. Nearby houses have required underpinning due to subsidence.

(5.6) Belton Lane (Gonerby) is a fairly narrow road, which currently has no housing near to it
except within the village of Great Gonerby. There are no footpaths for most of its length. The bridge across the railway is barely wide enough for two cars and includes a high-speed chicane. There are considerable safety issues for pedestrians crossing the bridge. The presence of housing near this road is likely to promote an increase in both vehicular and pedestrian traffic, giving rise to a significant increase in the risk of serious accidents. (6) Loss of agricultural land (6.1) The two fields are Grade 3 agricultural quality land of good to moderate quality, currently used for production of wheat, and we are concerned that GAAP, unchallenged, would have a massive impact on the amount of agricultural land being used around Grantham. It appears wrong that, at a time of rising food prices and widescale predictions of global food shortages, the District Council is planning to reduce the amount of agricultural land available in the area instead of using the brownfield sites that are currently available in the vicinity.

(6.2) Westbury Homes is already registered as having an agreement with the landowners and
there are concerns as to why they sought to landbank fields before planning has been passed. (7) Landscape Sensitivity (7.1) The Final Report of South Kestevens Landscape Sensitivity and Capacity Studywas completed by David Tyldesley and Associates in January 2011. Section 6 of that

document relates to the Site Assessment & Analysis of the Grantham area and Site G1A contains the GAAP Housing Allocation GRAH3, which is the subject of these representations. Pages 93 to 97 of that document are specific to Site G1A. On page 96 the sensitivity of the site to development is assessed and, in accordance with the Assessment Criteria as set out in Tables 4, 5, 6 and 7 of the Landscape Sensitivity and Capacity Study (pages 19 and 20) both the Landscape and Settlement Character Sensitivity and the Visual Sensitivity of the area are classed as High. It grades area G1A with the following criteria: Lies wholly within a designated landscape where localized character and scenic value is distinctive Important to the setting of a registered historic park and garden Presents locally important landscape characteristics and scenic value Presents important public amenity value by way of views, access, biodiversity interest and opportunity for quiet enjoyment (relative tranquility)

(7.2) The conclusion to the above is that the area has a High Landscape Sensitivity and High Landscape Value and, as a result, has a Low Capacity to accommodate development (in accordance with Table 8 on page 22). The penultimate paragraph on page 96 states that Key landscape characteristics and features, and visual amenity would be significantly affected which could not be successfully mitigated. We are mindful that the part of the site where it adjoins the existing development at Gonerby Hill Foot has a slightly lower landscape sensitivity and thus a slightly higher capacity to accommodate residential development, but the general advice conludes that new development is unlikely to alter the balance of features or elements within the existing view. For these reasons we believe that, in terms of landscape sensitivity and character,the site has a low capacity for development and to promote this site would go against the Councils own documentation to this effect. (8) Heritage (8.1) Objective 9 of GAAP is to conserve and enhance Granthams heritage, respecting historic buildings and their settings, links and views.

(8.2) In January 2010 South Kesteven District Council and National Trust published: Belton
House and Park Setting Study and Policy Development by Atkins. On page 27 of this document reference 3.6.6 Table 2 summarised the sensitivity to development of the different aspects of Belton House and the Parks setting. This table states that: Land visible from the roof of Belton House or from Belmont Tower is unlikely to be suited for this form of development, except on flat ground 2-5km from the park, where it would have to be 2 storeys or less and in excess of 5km where development should not be tall. We refer you to Figure 10 showing the location of the land in relation to views from the house and tower and Point 4.8.2, which states that applications for development will normally be refused if they:

Intrude on key historical and designated views, Degrade the open nature of key views, Require the loss of important woodland areas, Breach important ridgelines, Visually dominate the setting, or Significantly degrade the rural character of adjacent areas.

(7.3) On 31/10/11 the Gonerby Hill Residents Group received the following email from Alan Hubbard, planning officer at the National Trust: Looking at the study document, site GRAH3 is outside the 2km zone, albeit at its north-eastern extremity it almost touches the 2km boundary. The Trust has therefore assessed it on the basis of land

between 2 and 5 kilometres of Belton. The site is identified as part of the area referred to as Element 1 being ground that is visible from a key location(s) within the property such as the roof of the Hall or Belmont Tower. The related assessment of sensitivity is split up between different types of development as set out in the summary table below. (As you will see sites within 2 5km were determined not to be sensitive to small-scale development, but to be exceptionally sensitive to tall structures.) The scale of development being considered on Site GRAH3 (around 400 units) would constitute a Medium or Major Development i.e. the site is, in terms of the potential impact upon the setting of Belton, exceptionally sensitive to such scales of development, with the likely impact of development depending upon both the landform and the height of development. This confirms that the National Trust also believes that the land lies in an area exceptionally sensitive to development. We therefore believe that the development of this part of GAAP by South Kesteven District Council goes against a document that it had commissioned and already published. (9) Biodiversity (9.1) Objective 10 of GAAP aims to provide a network of multi-functional green spaces, which secures a net gain in biodiversity, provides for the sporting and recreational needs of the population, promotes healthy lifestyles and enhances the quality of the natural and built environment. The two fields vulnerable to development total 40 acres, which are home to a wide range of flora and fauna. The impact of this plan on biodiversity would involve: Removal of trees Removal of hedgerow Loss of natural habitat for roosting Pipistrelle bats currently protected under Schedules 5 and 6 of the Wildlife and. Countryside Act 1981. Loss of natural habitat for a variety of prey birds including, owls, hawks and kestrels. Loss of natural habitat for a variety of garden birds including goldfinch, chaffinch and woodpeckers. Loss of migration routes for migrating birds. Loss of natural habitat for wildlife including deer, foxes, muntjack, voles and many other species. Loss of natural habitat for rare plants such as varieties of wild orchids see appendix 4.

(9.2) Point 3.2.3 of the GAAP states that: The current national planning policy framework for the natural environment, countryside and landscape is set out in PPS 1 (Delivering Sustainable Development), PPS7 (Sustainable Development in Rural Areas) and PPS 9 (Biodiversity and Geological Conservation). The policies are aimed at sustainable development, which protects and enhances biodiversity, and provides for access to the countryside. We cannot understand how building on this greenfield land, which is designated as informal open space and is used by so many locals for their leisure can meet this intention. (9.3) Point 3.2.4 of the GAAP states that: Investment in green infrastructure provision for Grantham will help to tackle existing deficits in the provision of accessible green space, and help provide and protect wildlife corridors, open space and accessible land. We do not believe that changing the use of the land to the north of Peachwood Close, from that of an informal open space which is the home to such a diverse range of flora and fauna, can possibly meet this intention. (10) Review of the GAAP documents (10.1) The evidence document that accompanies the GAAP states on Page 10 of Site Assessments about the development to the North of Peachwood Close that: Due to the existing tree belt, the new development is unlikely to have any significant landscape impacts. It is our view that the proposed development would cross an important ridgeline at the top of the site, and building would remove the mature trees across the middle of the two fields. The tree line referred to within GAAP consists of immature trees, and this would not screen a medium to large-scale development. (10.2) The evidence goes onto state that: The site lies within the 5km buffer identified in the Belton House and Park Setting (Jan 2010) but fails to recognise that within the same document, which

SKDC commissioned and accepted, it is clearly stated that the land is exceptionally sensitive to development. (10.3) Other than a paper-based exercise there does not appear to have been any assessment of the transport infrastructure and therefore the evidence does not properly take into account the significant impact on existing roads that would be caused by adding to the estate. In fact, it is clear that only a paper-based exercise was carried out as the proposed Housing Allocation area does not even correspond to the established field boundaries and landscaping that borders the site, especially where the site is simply drawn almost at a right angle in its north western corner. (9.4) In the sustainability appraisal on Page 61 the Planning Policy officers have made several significant omissions from their evidence. They have failed to note that under biodiversity there would be a negative impact on the districts natural assets and biodiversity, and that the development would not protect and enhance the districts flora when the proposed development site includes rare orchids and a vast range of natural fauna. (10.5) Figure 4 on Page 26 of the GAAP Submissions document clearly shows that site GRAH3 is within Area M1 on that plan, identified to be the Great Gonerby Greenway and included as a Proposed Area of Search for Accessible Green Spaces (Community Parklands). We would argue that a development of 400 houses would be entirely contrary to such a proposal and would do nothing for the promotion of an accessible, green, community parkland. (10.6) We believe that by placing a question mark in the column for Cultural Heritage To Protect And Enhance the Districts Cultural, Built and Archaeological Heritage the evidence document ignores the evidence from the Belton House study as referred to earlier. (10.7) We strongly agree with the point that access through narrow estate roads is an issue. END OF COMMENTS

Appendix Appendix Appendix Appendix

1 2 3 4

Reasons for objections to the development Site Ref: GRAH3 Email from Woodland Trust dated 31/10/11 Photographic evidence (Impact on wildlife & biodiversity) Photographic evidence (Highway problems)