Fairford needs your voice

In the Council’s form, choose this from the dropdown:
Fairford North East site 7

Soundness test: Effective, Justified

I am commenting on Chapter 13, Core Policy 64 Water Management Infrastructure, printed page 265 (PDF page 275).

Wastewater capacity and the River Coln. Thames Water's committed upgrade to Fairford sewage treatment works delivers an approximate 50% uprating of treatment capacity, due for completion between April and June 2027. The allocation of 1,141 homes represents a 63% increase on the 1,811 households recorded in Fairford at the 2021 Census, rising to approximately 77% at the 1,400-home total the Council has itself published for the same site. A 50% increase in capacity cannot accommodate a 63% increase in demand. Fairford Town Council has reported that the works has twice passed 1,000 hours of continuous storm discharging into the River Coln. The Plan does not demonstrate that adequate wastewater capacity will be available at the point the homes are occupied, and is therefore not effective.

Insert a phased delivery mechanism preventing occupation of dwellings on the Fairford strategic site until verified wastewater treatment capacity is available, evidenced by a written capacity statement from Thames Water and the Environment Agency.

In the Council’s form, choose this from the dropdown:
Fairford North East site 7

Soundness test: Justified

I am commenting on Appendix B, Site 7 Fairford, Site Context and Design Principles, printed pages 30 and 32 (PDF pages 34 and 36).

Scale of the allocation relative to the settlement. The 1,141-home strategic allocation alone is equivalent to approximately 63% of the 1,811 households recorded in Fairford at the 2021 Census. Development on this scale would represent a very substantial change to a single historic settlement. The Plan should therefore demonstrate clearly why this scale and distribution of growth represents the most appropriate strategy when considered against reasonable alternatives, including lower levels of growth at Fairford and alternative distributions across the district. I do not consider the evidence sufficiently explains why development on this particular scale at Fairford is the most appropriate strategy.

Reduce the Fairford strategic allocation to a level that the evidence demonstrates can be sustainably accommodated, or provide clear evidence demonstrating why this scale of growth at Fairford was selected over reasonable alternatives, including lower-growth and alternative distribution scenarios.

In the Council’s form, choose this from the dropdown:
Fairford North East site 7

Soundness test: Effective

I am commenting on Chapter 6, Core Policy 13 South Cotswold Strategic Infrastructure Delivery, printed page 101 (PDF page 111).

Infrastructure deliverability is not sufficiently demonstrated. The Council's Infrastructure Delivery Plan and Schedule identify substantial infrastructure required to support growth, including transport, education, community and other improvements at Fairford. However, a number of the measures on which sustainable development at Fairford depends identify potential funding mechanisms rather than confirmed funding and remain subject to further development and agreement. The effectiveness of the allocation therefore depends on whether this infrastructure can be funded and delivered at the time it is needed, rather than simply being identified as a future requirement.

Strengthen the Fairford site policy to identify the infrastructure necessary to support the strategic allocation, its delivery bodies and funding mechanisms, and include clear and enforceable phasing or occupation triggers so that development cannot progress beyond defined stages until the infrastructure necessary to support it has been secured and delivered.

In the Council’s form, choose this from the dropdown:
Fairford North East site 7

Soundness test: Justified, Consistent with national policy

I am commenting on Appendix B, Site 7 Fairford, Site Context and Design Principles, printed pages 30 and 32 (PDF pages 34 and 36).

Relationship with the made Fairford Neighbourhood Development Plan. The Fairford Neighbourhood Development Plan was approved at referendum on 4 May 2023 with 89.8% of votes cast in favour and was made by Cotswold District Council on 5 June 2023. It forms part of the statutory development plan and contains recent community-led evidence and policies concerning development, infrastructure, landscape, flooding and the character of Fairford. The new Local Plan proposes a scale and pattern of growth very substantially different from that envisaged when the Neighbourhood Plan was made only three years ago. The evidence should clearly explain what has changed since 2023 and how the Neighbourhood Plan and its supporting evidence have informed the proposed strategy for Fairford.

Provide a clear assessment of the relationship between the Fairford strategic allocation and the made Fairford Neighbourhood Development Plan, including the material changes in evidence or circumstances since 2023 that justify the substantially different scale and pattern of growth now proposed.

In the Council’s form, choose this from the dropdown:
Fairford North East site 7

Soundness test: Justified, Effective

I am commenting on Chapter 13, Core Policy 63: Managing Flood Risk.

Surface water, groundwater and flood risk. The Council's own Level 2 Strategic Flood Risk Assessment identifies potential risk from ordinary watercourses and surface water at the north-east Fairford strategic extension and states that these risks must be confirmed at Flood Risk Assessment stage. Fairford also has documented historic groundwater and drainage issues. Given the scale of the proposed development, the Plan should ensure that these identified risks are fully addressed and that development does not increase flood risk elsewhere in Fairford.

Strengthen the Fairford site policy to require site-specific assessment of surface water, groundwater and ordinary-watercourse flood risk, together with an integrated drainage strategy. Include clear requirements that development must not increase flood risk elsewhere and that necessary drainage and flood-mitigation infrastructure is delivered before the relevant phases of development are occupied.

In the Council’s form, choose this from the dropdown:
Fairford North East site 7

Soundness test: Justified, Effective

I am commenting on Appendix B, Site 7 Fairford, Design Principles, printed page 32 (PDF page 36).

Highways and transport evidence. The Council's Strategic Transport Assessment describes the proposed Fairford development as broadly comparable in scale to the existing town. It also identifies potential peak-period junction constraints, limited transport alternatives, no rail access and only moderate-frequency bus services. Yet the strategy relies partly on increased use of public transport, walking and cycling to accommodate growth, with Fairford showing one of the more notable assumed increases in bus mode share. I do not consider it has been sufficiently demonstrated that the interventions required to achieve this change in travel behaviour are secured, funded and deliverable, or that the residual impact on the A417 and Fairford's local road network will be acceptable if the assumed modal shift is not achieved.

Require the Fairford allocation to be supported by robust evidence demonstrating the effect of the full proposed growth on the A417 and local road network, including cumulative development and realistic modal-shift assumptions. The site policy should identify the necessary transport mitigation and include clear and enforceable phasing or occupation triggers ensuring that required highway, public transport and active-travel improvements are delivered before the relevant stages of development. If the evidence cannot demonstrate that the proposed scale can be accommodated, the allocation should be reduced accordingly.

In the Council’s form, choose this from the dropdown:
Fairford North East site 7

Soundness test: Effective

I am commenting on Chapter 14, Core Policy 72: Social and Community Infrastructure.

School and healthcare capacity. The Infrastructure Delivery Schedule identifies a new primary school and secondary-school contributions to support the Fairford strategic allocation. These provisions need to be delivered in step with housing growth rather than after additional demand has arisen. The position on primary healthcare is less clear at a Fairford-specific level. Development on this scale will create additional demand for GP and other health services, and the Plan should demonstrate how that demand will be accommodated and when any necessary additional capacity will be available.

Strengthen the Fairford site policy to include clear delivery and occupation triggers for the education provision already identified and to demonstrate how additional primary healthcare demand generated by the development will be accommodated. Necessary education and healthcare capacity should be secured and available in step with the relevant phases of housing growth.

In the Council’s form, choose this from the dropdown:
Fairford North East site 7

Soundness test: Justified, Consistent with national policy

I am commenting on Appendix B, Site 7 Fairford, Site Context and Design Principles, printed pages 30 and 32 (PDF pages 34 and 36).

Landscape, setting and heritage. The proposed strategic extension would represent a major expansion of a historic Cotswold town into its surrounding landscape. Given the scale and permanence of this change, the Plan should demonstrate that the landscape and heritage effects of the full allocation have been properly assessed and that the proposed scale, form and boundaries represent an appropriate response to the sensitivity of the site, the setting of Fairford and affected heritage assets. These considerations should inform the amount and disposition of development, rather than being left principally to detailed design at application stage.

Ensure the Fairford site policy reflects the findings of the Council's landscape and heritage evidence through specific requirements concerning development extent, sensitive edges, important views, landscape buffers and the setting of heritage assets. Where parts of the allocation cannot accommodate development without unacceptable landscape or heritage effects, reduce or amend the developable area accordingly.