The individual comments were sorted into key topic groups.
For Matson almost 60% of the comments received were focussed on ‘homes’, ‘community’ and ‘open space’. For Podsmead this was 50% of comments. All comments were considered equally regardless of the total numbers in each topic area.
Comments were wide ranging and included concerns over accessibility of flats for older people, the loss of open space, the tenure of future properties, antisocial behaviour, uncertainty over what would happen to residents and their homes (both for tenants and owner occupiers), parking, community facilities, shops and services.
Full details of all the comments received are available here.
In accordance with the Town and Country Planning (Local Planning) (England) Regulations (as amended) 2012 Part 5, Section 12 all comments received have been carefully considered by the City Council and a detailed response has been provided.
After going to the City Council’s Overview and Scrutiny Committee on Monday 4th November, it was considered by the City Councils Cabinet on 6th November and finally approved by the full Council on 21st November 2019.
In summary here are the main changes proposed by consultees, approved by the City Council and GCH’s response:
More positive language
Respondents asked for more information to be included around the positive aspects of the estates as both neighbourhoods have many positive attributes that residents did not feel were fully represented in the SPDs. GCH and the City Council agree.
Community assets
Respondents wanted to see the assets within the community mapped and fully understood. There are a lot of skills and assets within the existing communities. The SPDs will now include reference to a community audit to be produced which will map these assets and capture the culture of the areas. Such a strategy will enable City Council planners to assess if the requirements in planning policy INF4 Social and Community Infrastructure of the Joint Core Strategy are met in any future planning applications.
GCH is happy to provide this in partnership with both communities and regeneration partners.
Removal of the Framework Plans
The proposed framework plans submitted in the original SPDs show where GCH would like development to be concentrated. These plans, particularly for Podsmead, show a significant loss of open space which City Council planners now feel has not been subject to proper consideration or assessment by the Council despite their involvement in the production of the SPDs. They now feel that it is premature to show development areas at this stage as it may prejudice their future decision making.
They also now feel that Framework plans provide uncertainty to residents some of whom are concerned that they are in an identified area, whilst others think that no redevelopment will happen near them. At this stage the City Council feel it is simply not known whether this is an accurate portrayal of future development as no planning applications have yet been made.
As the development is being led by GCH and not by the City Council they feel it would be more appropriate to see such information in a masterplan submitted with a planning application by GCH/the developer. The County Council Highways Authority have also now objected to the inclusion of the Framework Plans.
GCH are happy to provide these as part of any planning application.
Additional detail around what the Local Planning Authority requires
This covers issues such as the rehousing strategy, phasing strategy, community facilities strategy, economic strategy and local housing needs assessment for each phase.
The SPDs already referred to the provision of a phasing strategy, rehousing strategy and a community facilities strategy. This has been expanded to include an economic action plan and local housing needs assessment with each phase. More details have been included explaining what each of the strategies should contain.
This information is required to enable City Council planners to appropriately assess any future planning applications.
GCH have already been working on these supporting documents and are happy to provide as part of any planning application.
Removal of the ‘one move only’ approach
The City Council believe that GCH have an inflexible ‘one move only’ approach for residents impacted by any proposed regeneration. In fact the one move approach was agreed by all regeneration partners including the City Council early in the partnership to avoid making people move more than once if they did not want to and it was always intended to be flexible dependent on the individual needs of displaced residents).
However the Council feel and GCH agree that whilst one move may be appropriate for some residents, others may be happy to move twice if the first move was temporary and it meant that they were going to be able to move into a new property on the second move, or back into their refurbished home, or back into the area of their old home next to their original neighbours who may have been unaffected by the regeneration.
The City Council also feel that the one move approach has the potential to restrict creativity around the phasing and delivery of the overall project. They believe it creates a situation where the only options available to the developer are to build on open space or move people out of the area. Removing the approach from the SPD would in their opinion allow more options for the developer such as moving residents from a block of flats into vacant properties whilst a block is redeveloped. Those that wish to return could then move back in. An inflexible one move approach, the City Council believes, does not give residents the option to return to where they lived before. This, the City Council feels, poses a risk for residents if a developer proposes moving people from the estate.
In fact evidence from other regeneration schemes around the country shows that temporary moves are rarely that as households do not normally want double the upheaval, particularly when they have put down roots in their new area or new home. This can result in the original communities being scattered across the City. GCH also believes that moving people into relets, which are in high demand would also mean people on the housing register waiting even longer to be rehoused throughout the 20-30 year regeneration process.
So GCH will work closely with the City Council and affected residents to find them the most appropriate suitable alternative accommodation and give people the option to either move once, hopefully within the estate or elsewhere, if that is what they prefer or move back to their original area if they wish to, when work is completed.
Clarity over the approach to Public Open Space.
The draft SPDs contained figures detailing the amount of Public Open Space to be lost on each estate. This was 2.17 hectares for Matson and 3.71 hectares for Podsmead. Following comments received and after further consideration the City Council now feel that it is inappropriate to predetermine a set amount. Despite City Council officers’ involvement in the production of the SPDs the City Council feel they have not agreed in principle to this approach, nor do they feel that it has been demonstrated to be policy compliant.
The SPD had used the City Council’s own Open Space Strategy to justify this approach in that both wards have in excess of the minimum quantity standards for open space set by the City Council. However, the Fields in Trust guidance states ‘Quantity guidelines should not be interpreted as maximum levels of provision…’ Therefore, this in itself, the City Council feel, cannot be used as a justification to reduce the amount of open space. More consideration needs to be given to the role open space plays in defining the character of each area and in terms of the health and wellbeing of residents.
It may be possible to justify the loss of some open space if it can be done in a policy compliant way through the planning application process. However, the City Council feel there is no evidence at this stage to demonstrate that this can be achieved. They feel they must be mindful of setting a city-wide precedent on this issue.
GCH will work with the City Council to minimise the impact on public open space but where this threatens the regeneration of the neighbourhoods, GCH will bring forward proposals that justify the loss of some public open space and enhance the remaining public open spaces if this is supported by the local communities and will lead to wider benefits for those communities.
Phasing
Planning permission has been granted for 420 homes on Winnycroft Farm, with a further 250 homes also being considered. Given the scale of the permitted development next to Matson, and the fact that there is no local centre on the Winnycroft development, it would make sense to improve the linkages between Winnycroft and the Matson local neighbourhood centre at the earliest opportunity. This would provide an opportunity to create community cohesion and increased economic support for the existing shops and services in Matson. The SPD has been amended to recommend that this area of Matson is considered as a first phase of development.
GCH have already included this work in their revised Phase 1 proposals but need to build first on City Council owned land to generate the income to help pay for this work and provide decant homes for the displaced tenants and leaseholders.
Clarity over the purpose of the Blackbridge Sports Hub, adjacent to the Podsmead Estate
This is to ensure that the community facilities and services required to serve the estate of Podsmead are appropriately located within the red line boundary of the SPD area. The Podsmead Road is considered a barrier between the estate and Blackbridge. The City Council now feel that the proposed Blackbridge hub is an additional city-wide facility and should not be considered a site for the replacement of Podsmead’s local community facilities.
This would make it difficult for GCH to re-provide lost open space and community facilities for Podsmead, on the neighbouring Blackbridge site in order to meet open space planning and community infrastructure policy requirements. GCHs revised phase 1 plans for Podsmead already include the provision of new shops, a community centre and enhancements to the remaining open space within the Podsmead estate. GCH would also hope to improve footpath links between Podsmead and Blackbridge to provide Podsmead residents with improved access to the improved Blackbridge sports facilities.
Reference to materials in Matson changed from ‘red brick’ to render
Although locally distinctive across much of Gloucester, red brick is not distinctive to Matson. The City Council believe the positive elements of the character of Matson are important to preserve. Respondents in general want to see Matson improved but also to still look like Matson.
In fact the wording in the draft SPD only referred to brick not red brick which GCH agree would be inappropriate on Matson whose homes are predominantly rendered. GCH does however believe there are opportunities for using a variety of finishes including render, brick and stone to pay homage to the current character of the estate, recognise the closeness of the estate to the Cotswolds Area of Outstanding Natural Beauty and bring in finishes that would reduce future maintenance.
Inclusion of City Plan policies
The policy section has been updated to reflect the recently approved pre-submission version of the Gloucester City Local Plan. As with all developments across the city, planning applications in Matson and Podsmead must be policy compliant in order to receive planning permission. Particular reference is now made to A1 – Effective and efficient use of land and buildings, A2- Affordable housing, A3 – Estate regeneration, A6 – Accessible and adaptable homes, C1 – Active design and accessibility, C3 – Public open space, playing fields and sport facilities, C7 – Fall prevention from taller buildings, F3 – Community safety and F6 – Nationally described space standards.
These generally increase planning requirements making it more difficult to achieve policy compliant planning applications and will add to the cost of regeneration. GCH are currently assessing likely additional costs and the effect that this has on the overall financial viability of the regeneration proposals.
Power of Three Community Economic Strategy covering the Matson neighbourhood
Details of this document have now been included. Disappointment was expressed through the consultation that GCH, a partner organisation in the Power of Three, have not used the process so far to empower the community by training residents to be part of the consultation process, nor power sharing the process with residents. It was suggested that stakeholder events have been held by GCH at the Kingsholm Rugby stadium rather than in local community facilities.
GCH believe this may reflect some residents’ views who have not been as involved as others in the extensive consultation so far carried out. GCH has in fact held a very large variety of consultation events in local venues on both estates, carried out door knocking exercises, held local events and meetings and provided weekly drop in sessions on both estates. GCH have also attended a variety of different community initiated events on both estates to answer questions on regeneration.
GCH have also helped to set up Community Action Groups (CAGs) for both neighbourhoods made up of home owners, leaseholders and tenants of different ages, abilities and ethnicities. GCH pay for them to be supported by TPAS, a resident consultation consultancy, to provide independent community training and support. TPAS independently help the CAGs to fully understand and respond to proposals, (including documents and plans) and to participate in key decisions during the regeneration process, which includes challenging GCH, the City Council and other partners on their proposals. The CAGs are represented on the Matson & Podsmead Regeneration Partnership, alongside other statutory, charitable and community partners involved in both communities.
These wider regeneration partnership meetings have so far been held off site but only to allow representatives a chance to look back at the estates from a wider perspective. None of the residents or other partners had asked GCH to depart from this, although GCH are happy to move to more local venues if partners and the communities themselves would prefer this.
Ownership plans
These are to be updated to reflect 2019 data and include different house types such as the location of maisonettes and bungalows, as well as houses and flats. The ownership plans are considered useful as they demonstrate the mix of house types and the complexities of land ownership which will be beneficial to the future master planning process.
GCH have already updated these ownership plans to reflect GCH’s current ownership and types of homes and the City Council, and County Council are looking at adding their ownership information, where this is publicly available.
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