RESPONSE TO CONSULTA TION: WEST OF LOUGHBOROUGH SUSTAINABLE URBAN EX TENSION

DECLARATION OF INTEREST:
I am a resident of Loughborough, for over 27 years, living within a few hundred metres from the edge of the Garendon Estate/Park, and will be potentially directly and/or indirectly affected by this development.

BACKGROUND:

The West of Loughborough Sustainable Urban Extension will henceforth be referred to as WOLSUE. Proposed development of this site (Garendon Estate/Park) has been rumbling on for many years indeed decades. It has become increasingly apparent in recent times that the local authority, Charnwood Borough Council (CBC), is pursuing this development in preference to other more viable and environmentally-friendly alternatives. Development on this land is of prime importance to CBC, and based upon their published documents there would appear to be a well-defined agenda. This is aptly summarised by the fact that CBC have stated that if this area is not developed under WOLSUE, it will be pursued piecewise under a different provision/s. Strategic Housing Land Availability Assessment 2009 published by CBC comprises many of the same development areas as WOLSUE but in smaller packets which state: The site has been excluded from consideration at this stage because it is being assessed as a potential Sustainable Urban Extension (SUE) through the Borough Councils Core Strategy. Once the Core Strategy is published and if this site is not taken forward as an SUE, we will then consider it for a smaller scale housing allocation. Therefore, the site will remain in the 'housing pot' until this stage. It can therefore be concluded that even is the WOLSUE is prevented by local public objection it will not be the end of the issue, and it is highly likely that development of the Loughborough/Shepshed and/or Loughborough/Hathern Green Wedges will proceed irrespective of the outcome of this consultation.

PERSPECTIVE:

It is always advisable to put any planned development into perspective, in order to get a feel for the impact. Thus, taking a typical figure of 2.5 persons per household over the 3000 new homes suggests approximately 7500 residents. Assuming that the present population of Loughborough is 59900 then this represents a population increase of about 12.5%. Compared to Hathern which has a population of about 1900, this represents 395%, and relative to Shepshed (population of 13500) it is 55.6%. Taken relative to the number of students at Loughborough University (11700), this increase equates to 64%. Evidently, this is a very substantial development that will have not only an impact in the immediate vicinity but across much of the local area.

GREEN WEDGE:

According to CBC Green Wedge Review of 2011, the site of WOLSUE is largely coincident with the Loughborough/Shepshed Green Wedge. Thus, WOLSUE will essentially eliminate the Green Wedge, with just the M1 and a narrow green strip preventing the convergence of the two towns. In addition, on the Shepshed side of the M1, there are plans via the CBC Strategic Housing Land Availability Assessment 2009 to build on a fair proportion of the green strip between the town and the M1 (PSH24). Should this happen as planned, then at the nearest point, Loughborough and Shepshed will be separated by little more than the width of the M1. Furthermore it would give precedence for expansion across the rest of the strip between Shepshed and the M1. Similar erosion of the Loughborough/Hathern Green Wedge is also planned through development from both Hathern and Loughborough (Dishley). This will likewise result in loss of community identities and a homogenised urban sprawl. It will destroy the aesthetics and quality of the region; attributes that attracted people here in the first place.

Figure 1: CBC Green Wedge Review of 2011 showing Loughborough/Shepshed Green Wedge.

FLOODING RISK ASSOCIATED WITH THE DEVELOPMENT:

It is apparent from the limited information provided by CBC that there are lightly some significant issues with regard flooding in the proposed development area. It is also apparent that any flooding may not be constrained within the development area but may manifest upstream or downstream. Prima facie, there are substantial holes in the hydrological assessments of the area, in particular the Oxley Gutter. For example, Charnwood Borough Council Charnwood Strategic Flood Risk Assessment Final Report 21 April 2008, (Entec UK Limited 2008), states that the Oxley gutter has not been thoroughly assessed; as illustrated by the following extract from pages 48/49: 5.2.1 Flood Risk Potential West of Loughborough SUE (see Figure 2.1)

This SUE [Sustainable Urban Extension] would be situated west of Loughborough, approximately between urban limit of Loughborough and the M1 motorway. Elevations range from approximately 70 to 50 m AOD [Above Ordnance Datum]. The area drains from the south towards the Black Brook and its tributary the Oxley Gutter which runs through the centre of the area under consideration. Both of these water courses are Main River, maintained by the Environment Agency [EA]. Detailed modelling of the Black Brook has been carried out to better define the extent of the flood zones shown in the EA Flood Map, whilst only a short section of the Oxley Gutter is featured on the EAs Flood Map. Historically, the Black Brook has been associated with flooding further downstream in the Thorpe Acre area. Potential flood risks to consider with respect to development in this area include: Fluvial flooding from the two Main River watercourses (known to be associated with downstream flooding) at present and under future climate change scenarios Flood Zone only defined for the Black Brook. but not the Oxley Gutter; Overland flow from higher land to the south of the potential development areas; Blockages/insufficient capacity of bridges/culverts on the two watercourses (including existing structures and any proposed in association with new development); Providing upstream balancing capacity to attenuate flood flows on the Wood Brook; Need to manage runoff in view of downstream flooding and backing-up of the Black Brook when the River Soar is in flood - SuDS [Sustainable Drainage Systems] important to attenuate increases in runoff; and Key issue: appropriate runoff management and flood flow balancing along the Wood Brook especially with regards of flood risk to existing development downstream. NB: My annotations are in square brackets. The report concentrates on the main moving watercourses but fails to address numerous smaller ones and the various static (permanent and transient) watercourses. Some assessment appears to have been made of the Black Brook, but the Oxley Gutter, catchment, and smaller watercourses appear not to have been evaluated. Without comprehensive assessment of the Oxley Gutter, the remainder of the WOLSUE area, and adjacent regions, along with full 3D modelling of the interactions between the various watercourses, and any proposed drainage and flood-prevention schemes, there is an enhanced risk of significant flooding within the development site, as well as upstream and downstream of it.

The Environment Agency (EA) was asked the following questions on 21 July 2013, referring to the WOLSUE area: 1) Are there any historic records of flooding in this area? 2) A few years ago, Charnwood Borough Council commissioned a flood risk assessment Charnwood Strategic Flood Risk Assessment [CSFRA2008] Final Report 21 April 2008, (Entec UK Limited 2008). Is this the most recent flood risk assessment for this area? If not, please advise on the latest evaluation and how it can be obtained. 3) The aforementioned report [CSFRA2008] states that only a partial assessment has been made of the Oxley Gutter tributary. Has any further assessment been carried out since CSFRA2008? If not, is such planned? If one is in preparation or scheduled, when is it due to be published? 4) Has any of the farmland within the region been classified to a lower grade than would otherwise be the case as the result of known (recorded or inferred from scientific techniques), or modelling projected flooding or implied risk thereof? EA failed to respond to any of these questions in their response of 8 July 2013, and have been asked to reply with appropriate answers; however it is unlikely that any reply will be provided prior to the deadline of the consultation process. Despite the EA issue, it is evident that CBC has neglected to include many of the minor, yet important watercourses on their map. This is illustrated by a comparison of two maps in Figure 2. The top map is the original from CBC WOLSUE website whilst the lower map is identical but with some features included that have been omitted from the original. Clearly, a significant proportion of the watercourses have been left off the CBC map. Those omitted are mostly without hydrological assessments. Some significant, permanent, static watercourses bordering the development are also absent from the map. It is important to include all the necessary information in order to aspire to a constructive and impartial discussion, however, this map does not fulfil that criterion. Local knowledge indicates that much of the proposed WOLSUE site has historically flooded and it is believed that there are photographs of flooding over large parts of the area dating from the last couple of years. It is likely that suitable scientific surveying techniques would confirm prior undocumented flooding events.

Figure 2: Comparison of original CBC map of WOLSUE (top) and the same map including omitted detail (lower) which comprises watercourses (cyan), power-lines (amber), sewage works (yellow), and waste disposal site/Tip (magenta).

TRANSPORT INFRASTRUCTURE:

The main roads affected by this development are the M1 Junction 23, A512 and A6 are already unable to cope with present traffic flow at peak times and this situation is unlikely to improve, indeed will probably get worse over the coming years, even without the proposed development. An additional 3000 homes bounded by the M1, A512 and A6 can only increase the amount of traffic on these routes, regardless of the presence of the planned link road. According to RAC Foundation for Motoring the number of cars per household per adult is likely to be about 1.3 (linear trend projection to 2015). The number of cars is proportional to the number of adults rather than the number of households. Thus, assuming average property type distribution, the estimated number of cars owned by 3000 households is likely to be around 3900. Splitting this equally between the two main routes (A512 & A6) is 1950 cars. Obviously this is a maximum and assumes all the vehicles are on the road simultaneously. Taking a conservative 50% on the road at peak times (spread evenly over 1 hour), this equates to 975 cars per road per hour, or over 16 cars per road per minute above the present level. Alternatively, it can be thought of as more than 1 car every 4 seconds, per road, in excess of todays traffic magnitude. Not only is it necessary to take account of the increased traffic but the knock-on effects of this need to be considered. These will include, for example, increased difficulty/congestion on adjoining roads and greater and prolonged noise and air pollution, all of which impact the population. Highway studies commissioned by CBC and Leicestershire County Council (LCC) are not in agreement with each other; LCC suggesting that WOLSUE would add to the problems already encountered by drivers using the aforementioned roads.

OTHER INFRASTRUCTURE:

Are the local health care facilities capable of assimilating such a large increase in population? This is doubtful bearing in mind that the hospital parking is often already under strain and NHS-friendly dentists are few. Similarly, it is plausible that there will be increased requirement for other Social Services, and related facilities that will be at least partially dependent upon the new housing demographic. Presumably the present sewerage provision will need extending to support the increased population, and may require some additional defence from flooding and to prevent spillage. With the change in hydrology due to WOLSUE there will be an increased risk of accidental escapes due to large surges of flood water and elevated water levels.

ALTERNATIVE SITES:

There are numerous brown field sites across the town, and beyond, within the remit of CBC. In particular, there are old factory sites, former industrial premises, and similar locations that should be redeveloped in preference to green wedge sites. Atop this, there are regions of low-grade farmland and other rough ground that should be used before good agricultural land is built upon. An obvious alternative site for such a large development is the former Wymeswold Airfield. This is a brown-field site and has a newly installed solar-electricity plant. It was originally proposed for a similar housing development in the 1990s but to date there has been little progress. Developing it would provide a greater potential for sustainable growth and could be done without significant loss of either green wedges or community identity. It might potentially be used as a lever to improve

infrastructure to the East of Loughborough. Furthermore, it could be presented as ecologically sound project earning CBC a degree of environmental credibility.

CONCLUSION:

There is evidence that the CBC West of Loughborough Sustainable Urban Extension (WOLSUE) development proposal is ill-conceived or flawed depending upon ones perspective. This document raises a number of concerns that must be comprehensively and inclusively addressed, both separately and cumulatively before any credence can be given to the planned WOLSUE.

Submission Date: 21/7/2013

Jonathan Drake CPhys MInstP BSc 38 Clowbridge Drive Loughborough Leics. LE11 4SU

APPENDIX:

Figure 3: Google map showing watercourses.