30th March 2016

Dear Mr Baker & Hallam Land Management,

Application 16/00165/OUT Tuffley Farm/Grange Road site - 250 (or more)
dwelling application by Hallam Land Management (HLM) - 'developer'
As you are aware, we are a Tuffley community based action group, with almost 700 members
and a live change.org petition with 628 signatures and comments, as at todays date. The
response has been overwhelming and clearly shows the feeling of many local residents.
You will also be aware of the numerous comments that you have on the above planning
application.
We wish to object to this application on the basis that the local infrastructure, is not capable of
supporting a possible extra 500 vehicles and potentially up to another 965 persons in the area,
based on the mix of housing and will cover this objection and further objections below.
Many residents are still concerned with the risk of flooding, having previously experienced the
events of 2007 and 2012.
We list our comments and raise queries below and will highlight questions for GCC and HLM
throughout this document. And will also raise queries with the content of the developers plans.
We cannot understand why the land designation for this 1 field has been changed and that the
other 2 fields south of the proposed site are Landscape Conservation Areas, whilst all 3 are
within the Gloucester City boundaries? Without this change, there would be NO application!

Roads:
Grange Road (opposite the proposed site) is essentially a country lane on the edge of Gloucester,
with only a single pavement and no cycle path and no bus service because of the railway bridge.
The road is used as a short cut between Stroud Rd and Cole Av, then Bristol Rd.
There is confusion on turning right at T junction on Grange Rd/Stroud Rd - more traffic, greater
risk, longer queues (despite traffic counts. so say done on 8/9/15?)
Grange Rd automatic traffic count and speed analysis on 8/9/15 for 7 days by 2 cables to right of
site entrance.
How is this accurate as 1 cable broke within 2 days? (presumably, both cables are needed to
provide data?)
Have highways been out to monitor traffic at peak times, including St Peters start and finish?
Can HLM prove that actual traffic counts were done on 8/9/15 at Grange Road/Stroud Road
junction?
The local transport system is already stretched at peak times, in particular St Barnabas
roundabout.

How do Highways propose to alleviate the issue with over capacity of traffic? We have still not
seen the full effect of Kingsway and Huntsgrove, as still ongoing building projects?
At peak times Grange Rd > Stroud Rd traffic backs up from St Barnabas - made worse by St
Peters School buses and traffic.
Planning permission for a Convenience Store in the car park of the Fox & Elms Pub on Stroud Rd
(opp Tuffley Lane) will increase the problem (based on existing Tesco problem in Grange Rd).
Proposal of traffic lights at Stroud Rd/Tuffley Lane would be another traffic problem.
Can highways confirm the rumour of traffic lights being installed at the adjacent Tuffley Lane
junction, which will cause further delays?
Fatality in Stroud Rd on 9/14, car hit cyclist and drove off.
13-year-old school boy knocked off bike whilst using the pedestrian crossing approaching St
Barnabas roundabout in summer of 2014, leaving him unconscious with numerous injuries.
Over the past 5 years there has been 46 collisions and 58 casualties on Stroud Road, off St
Barnabas. (from HLM documents)
St Barnabas roundabout has excessive traffic demand from A38 Cole Av and A4173 Stroud Rd +
1 local road - 5-way busy junction!
We quote from HLM documents regarding St Barnabas 'is already running in excess of its saturation capacity with a significant delay of 100 vehicles
observed at Stroud Rd South'
'without improvements the current form of junction will result in increased delays and queues
with any form of traffic growth'
The Highways Agency has been allocated 1m (over 8 years ago) for improvements to signage,
slow markings on road, etc.
What is the current situation regarding this? Do highways have a fully funded plan to improve St
Barnabas?
There are no firm plans to improve St Barnabas due to extreme costs involved - Grade 2 Church
with memorial garden at front and many house gardens fronting roundabout - a lot more then
1m?
Tuffley Farm (proposed) site leads onto Grange Road West which is a single lane, traffic light
controlled road/bridge (other nearby bridges are single carriageway too) this is a pinch point.
How is this going to be suitable for increased levels of vehicular and pedestrian traffic?
Tesco in Grange Rd is another pinch point due to on-road parking, near to bridge.
Epney Rd/Grange Rd/Tuffley Lane roundabout and nearby Epney Rd/Cole Av traffic lights suffers
from heavy peak time traffic and like St Barnabas struggle with extra vehicles.
Kingsway/Hunts Grove housing still being built, where will this traffic go?
A38 slip road from Tuffley suffers from long queues every weekday morning.
A4173 Stroud Rd south connects to Haresfield Lane already suffering from Kingsway traffic using
as a short cut; also the adjacent Upton Lane is used to avoid St Barnabas (Winneycroft Lane,
along Upton Lane is a proposed 450 home development)
There will potentially be 500 vehicles from the 250+ homes proposed. GCC/HLM are proposing
only 1 parking space per house.
Do the council intend HLM to design the site on a 1 house/1 car space basis and how is this
practical with the poor local infrastructure?

Where will extra cars and visitors parking?

Will it spill out onto Grange Road, causing further congestion and difficulty in passing?
Copeland Park is an Example of the 1 car park space rule, as is Kingsway the result is obvious
to see, with cars parked along kerbs and verges. People are using their cars, instead of the bus
service, readily available, on site.
Local roads suffer from potholes - heavy construction traffic will worsen these roads and edges.
GCC have marked numerous pot holes on Stroud Road but there are no current plans to repair
these? These potholes make it unsafe for cyclists and cars swerve to avoid them too?
Can HLM/Highways explain how new residents would walk to school with the local primary
schools almost at full capacity now, making in necessary to use cars?
Can HLM show that new residents will not need to travel by car for a doctors appointment?
Are highways using 2011 Traffic Census data as HLM are? If so, this data was collected before
Kingsway and Huntsgrove were built/building?
Are Highways conducting counts that show peak patterns and not counting during school
holidays etc?
HLM state that their travel plan will be activated after 75% home occupancy has taken place.
How is this sustainable with no bus route and no cycle path in Grange Road?
How will this discourage car use?
Have Highways/HLM completed a risk assessment on the restricted railway bridge access, taking
extra pedestrian, cycle and vehicle movements into account?
How will Grange Road and Stroud Road deal with the damage to the already pot-holed surface
and waste, mud and debris that the construction would create?
There are plans to build 12 homes at Stroud Road/Grange Road junction and a convenience
store in the car park at the Fox and Elms pub if these are built at the same time as the
proposed development, how will the council manage so as to avoid traffic problems?
How would construction vehicles enter/exit the site, as they cannot pass under the railway
bridge? They will cause extra problems with traffic and congestion, entering from Stroud Road
end and cause further concern for the safety of our pedestrians?
Council seem unconcerned about traffic congestion seeing it as reducing speed and lessening
accidents however slow or queueing traffic results in higher pollution emissions!

Traffic from St Barnabas up Stroud Road at 8.50am, backed up to Grange Road & Tuffley Lane
blocked.

Grange Road leading to Epney Road, leading to Cole Avenue, blocked in all directions
at 2.50pm.

All 4 entry exit points of St Barnabas roundabout, bocked at 3.55pm this is only the
lead up to rush hour!

Buses:
No regular bus service on Grange Road due to railway bridge.
Nearest bus service to Gloucester (No.9) is 9 minutes walk and Gloucester/Cheltenham (No.10)
10 minutes walk other side of bridge. Also Gloucester/Stroud (No.63) 9 minutes walk.

The average person is NOT going to carry bags, with children and buggies, this distance. Each
bus also has a restriction on number of buggies.
Statistics show car use at over 70% - single car use at 63% (2011)
A high proportion of Tuffley Residents (87% in some areas) commute by car, meaning many of
the developments cars would be used daily.
http://www.gloucestercitizen.co.uk/Commuters-Gloucester-exclusively-using-cars-work/story28579666-details/stroy.html
School buses at St Peters High add to traffic at peak times.

Cycle:
There is no cycle path on Grange Road and, at present is not used frequently by cyclists. A few
school children that do cycle, use footpath, due to the lack of a cycle path, build-up of traffic at
peak times and speed of traffic at off peak times.
Stroud Rd has a cycle path, but again is not well used probably because of incline, numerous
potholes and the traffic risk (1 cyclist fatality in 9/14).
The developer states that there are employment opportunities at Waterwells however this
involves an incline and a bridge to Kingsway and is not a 10-minute cycle for an average person
(15/20 mins)?
How does the lack of bus routes and lack of local employment opportunities fit in with HLMs
marketing plan to limit car usage?

Local Facilities and Walking to Local facilities:

Schools
The 3 Primary schools and 1 (non-selective) Secondary School are local but necessitate travel
through the traffic bottleneck of the railway bridge, restricted to 1 person at a time with a pram,
wheelchair or mobility scooter.
All are near capacity and are having to build extra classrooms to accommodate present intake
levels.
Many parents are already finding that there is a difficulty gaining their first choice school place
because of this.
St Peters is a catholic school with restrictive selection and buses in many of its students due to
this.
Crypt and Ribston are Grammar entry level schools.
If children from the new development did walk to school, under the bridge, they would have to
cross the restricted footpath that the developer plans to install and as it ends before the bridge,
offering no commitment to the safety of those children, with more traffic on the roads!
HLM have stated that Beaufort Secondary has an attached Leisure Centre. There are limited
services open to the public, at this centre.

Shops
The nearest shop is Tesco Express, through narrow raised walkway under bridge. It is proven
that even very local residents drive to this shop and, as parking spaces are limited, this has
created parking & congestion on Grange Road.
If you want to do a full weekly shop, car travel is essential.

Doctors

There is only 1 Doctors surgery in Tuffley, which is a small bungalow in Warwick Ave It is over
capacity and many Tuffley residents have to travel, by car to surgeries further afield.
There is no surgery in Tuffley Lane, it closed in 2015, meaning 700 patients have already been
trying to find a new practice.

Travel Plan:
Quote - 'reducing the dependence on private car usage' - the site is wrongly positioned to
achieve this!
Travel Survey will occur on 75% occupancy of all the housing!

Drainage and Flood Risk:

Geology of site (and area) is charmouth mudstone and blue lias with a topsoil of 0.2 - 0.3 m.
Quote from developers documents - 'the mudstone deposits are unlikely to have sufficient
permeability for surface water disposal'.
Heavy or continual rain results in water laying on top of field surface draining towards Grange Rd
and railway corner, due to the camber of the road.
There are 2 Brooks in area - Daniels & Whaddon - both flow to River Severn.
Whaddon Brook is particularly relevant to Grange Rd drainage.
Are Savills correct in saying that the site is not within 20 metres of a watercourse. (Their words)
This is incorrect as there is a concrete watercourse in the north-east corner of site, fed from a
gully separating the fields!
Are Savills correct in saying that this site and adjoining land are not affected by flooding? (Their
words)
Are HLM aware of the flood history within the area?
Are HLM aware of the works completed and works still in progress, to reduce flood risk to the
area of proposed development?
Are HLM aware that local residents are unable to negotiate buildings insurance without a higher
flood risk premium?
Do house insurers take flood mapping data from the E.A?
On Land Registry site, looking at http://watermaps.environment-agency.gov.uk . This
clearly shows Whaddon Brook and land South of brook as highest risk of flooding from surface
water. Therefore, according to E.A. How can this be flood zone 1?
There is a common theme of flood risk from the insurers and risk assessors (when purchasing
property in the area), as homes in the Grange Road and adjacent roads have been flooded
previously?
Will HLM re-consider their assertion that this is not a flood risk area, taking into account the
photographic and historical evidence, the impact on insurance on local homes and the flood
alleviation work carried out to date and still in progress?
Have GCC made a recent assessment of the capacity of Whaddon Brook to take increased water
flow based on recent rainfall running off the field over Grange Road? Not 100 year events, not
30 year events this happens all the time, after short bursts of rain suggesting a high water
table?
Just 2 weeks ago, Stroud Road flooded, the soakaways in the proposed fields for
development overflowed and poured out over Grange Road and Whaddon Brook burst
its banks.

Site falls from south to north/Grange Rd (30m AOD south > 25m AOD north), gradient greater on
north east to water gulley near concrete concourse to Whaddon Brook under Grange Rd.
Regarding gradient has GCC considered how STW will be able to route the foul water pipe to
Bybrook Gardens with sufficient gradient and without any detrimental effect to Whaddon Brook?
Also, how will the route of the pipe effect the nearby houses? Will an enforcement order for
access be necessary by STW?
We would also like to make clear that there are still flood risk measures on the Drainage
Departments action plan for this area and these are ongoing.
The measures that have been put into place, over the years, are somewhat dependant on
Whaddon Brook being kept clear of litter, branches and general debris. It requires a
permanently maintained, clear flow. A team was put in place to ensure this happened and this
process is not occurring. There is already a grill missing from a drainage pipe and local residents
are having to clear litter and waste to ensure a clear flow.
What impact will the waste, mud and debris from the site have on these measures breaking
down?
There is a long history of flood risk in this area we have a newspaper article here from 1977
with details of Grange Road and Whaddon flooding back then and believe that the history of
flood risk dates back beyond that.
Persimmon Homes built the houses opposite the proposed site and obviously thought they had
planned their site correctly. However, this has proven to be incorrect, as some of these houses
were flooded in 2007 and 2012. Unfortunately, this demonstrates that developers sometimes
get things wrong!
Attached are some of the photographs taken by various homeowners in the area there are
many more, should you wish to view them and Wayne Best and Nick Chadwick have hundreds
more within GCC achieves relating to 2007 and 2012.
We also have photos of many other dates over the years, since 2012, which show an inability of
the flood measures coping with heavy rain, in a short period, on dry land. Regardless of the high
water table.

2007 FLOODS Bybrook Road and Whaddon Brook opposite proposed site.

Grange Road/Stroud Road Junction note height of bollards!

2007 Bybrook Road onto Grange Road facing the proposed site

Many homes were flooded, causing so much upset and s of insurance claims

2007 Harwell Close view from Grange Road opposite proposed site

Grange Road leading away from proposed site, towards Stroud Road

2012 FLOODS After some flood prevention measures are in place Proposed
site!

Harwell Close opposite field

2012 Running off HLMs proposed plot

Bybrook Road and Whaddon Brook

MARCH 2016 After 1 night of rain - this has happened many times over the years, since flood
defences were built

HLMs proposed site North/East corner

2016 Exiting bunds in the fields are full, overflowing onto the roads and water is
backing up onto the field.

Whaddon Brook burst its banks behind Chislet Way

2 Ponds Maintenance.
The success of the drainage system is dependent on the ponds working and providing slow drain
off (approx. 10cm pipe) however if there is no maintenance the ponds could silt and block the
filters in 5/10/15 years time?
Who will take on the maintenance contract for the ponds now and forever?
Developer hopes and assumes the Council will adopt the sites roads and drains and that Severn
Trent Water(SWT) will adopt sewerage/foul water.
However, will the Council adopt the 2 Ponds?
Will the developer assume the associated costs?
And if not will SWT still adopt drainage and sewerage?
Will HLM compensate existing home owners, should their SuDS scheme and other relief drainage
fail, in the future?
Can you absolutely confirm that an approved SuDS scheme will prevent any flooding on Grange
Road and surrounding houses and that Whaddon Brook can take the extra flow at the set release
rate of the ponds?
Will the ponds have enough capacity in 15 years and beyond with the expected effect of urban
creep and climate change effects?
Is there any evidence that these ponds will work on a sloping site with impermeable ground,
further degraded by urban creep?

Urban Creep/Density of Housing:

For profit the developer requires either high density build, higher value per unit/less units or a
mix; the dwelling density dph (dwelling per hectare) is high at 40, but that is based on 250
homes, if there are 300 homes (as quoted in some of their documents) the density will increase!

The Council Housing are demanding 40% affordable housing - this will inevitably increase the
40dph.
What percentage for social housing will be insisted on by the city and accepted by the
developers?
How will HLM comply with the requirement of 40% affordable housing or even a lesser % after
negotiating with GCC?
How will noise level controls (re railway) effect the housing layout and density of housing?
The greater level of ground coverage will reduce the ground permeability and probably increase
surface water runoff.
After building completion the permeable driveways and paths will gradually become less
permeable and also, home owners will patio, tarmac and concrete ground further reducing
permeability.
Urban Creep Studies show that over 15 years the initial build ground covers of 55% of the site
(seems low compared to this application) and this then increases to cover 85% of the ground.
Therefore, the 2 ponds may not have sufficient capacity for drainage or surface water and
flooding could occur to Grange Rd and adjacent homes.
Will the ponds be large enough for future volume capacity after Urban Creep reaches 85% over
a period of time?

Experts:
'Unprecedented' rainfall, or 1 in a 100 years events, are terms we have heard in relation to
flooding in Somerset, York, Cumbria, etc. The theme is that the so called experts and
Governments Depts. have been incorrect (or not funded). However, rainfall records only go back
200 years, so perhaps the events have occurred before, but have not been recorded.
Why does Tewkesbury Church not get flooded? Because it has been built where it would not be
flooded. Our ancestors had the knowledge!
Will the Council and Developers recompense the residents of Tuffley if flooding occurs as a result
of covering this field with concrete & brick?

Landscape/Visual/Nature:
We appreciate houses need to be built and the need for affordable housing, however the loss of
views for everyone using the road with contrasting views against the hills enhance the area, the
house heights will affect the panorama. The density of the houses will also have a detrimental
effect.
Why is there no detail on the exterior brick and colour, this is a major point in how the houses
will blend in - visual affect?
HLM have used pictures of the site from all directions to enhance their application but have
avoided superimposing houses onto those pictures.

Why are there no pictures of what the houses would look like on HLMs landscape documents?
House density will be greater next to the railway therefore the inhabitants will probably create a
short cut to the bridge, with poor visibility to the road, thus negating the designated entry
points?
Will 3 storey houses be permitted on the North and West boundaries in view of the landscape
issues?
The fields act as a buffer between urban and green belt and provide a good nature habitat, a
neighbour has kept a log of the local wildlife sightings.
The area is classed as rural according to Flood Risk Assessment and Drainage Strategy 2.8.
HLM state that the farm building on the site is disused It has had recent roof repairs and often
is used by livestock. There are also reports of bats occupying the barn?
Why does the developer think that this site holds no particular interest in relation to wildlife and
hedgerows?
The 2 ponds will probably attract wildlife; however, the concern is whether it will also attract
vermin and insects.
Are HLM aware why the remaining land on the site within the City boundary was not included in
the planning application? Because it is a Landscape Conservation Area?
Why is this area classed as a L.C.A. and not the rest of the field/site?
Why did GCC change the land designation for the proposed field for development but
not the other 2 fields, enabling this application?
Is there a need for housing in this area, when there are so many other areas that could be built
on first? Using the little green land left in our community, should be a last resort?
The field contains a farmhouse dating to 1799 and we believe that the whole site could have
archaeological interest.
There is a huge sadness that we will lose the agricultural land and the impact on the landscape.
There fields appreciated by many, to take in the outstanding views.
It IS an area of Outstanding Natural Beauty!

OUTSTANDING NATURAL BEAUTY AND VIEWS ENJOYED BY MANY

Local City Plans and JCS:

The JCS has not been finalised by the Inspector and this has delayed the Gloucester Plan this
should not be an excuse to pass this 'small' 'under 500' development. Stroud DC have their a 5year plan in place.
In 2005, the site was not carried forward into the preferred options document owing to the
significant level of responses received relating to; loss of greenfield site, impact on local
services, infrastructure, accessibility, traffic generation, the lack of need for new housing and
impact on views to and from Robinswood Hill.
Reflective of this, the development of the fields surrounding Whaddon is not in Stroud DCs 20152031 Local Plan.
The site was not approved as a preferred site in 2005 what has changed?
Gloucester City Strategic Assessment of Land Availability & S.W.O.T evaluation in 2012 identified
the same issues in Tuffley & Grange Wards.
The real concern is passing this application will allow the larger Origin3 from Grange Rd to the
M5 and Stroud Road to the railway. 250+ homes may be the prelude to wider development of the
surrounding fields on Stroud DC land.
We are still awaiting full effect of Huntsgrove/Kingsditch continued building, which is the other
side of the railway, traffic uses Haresfield Lane.
Has the JCS or GCC identified this site as one of the 4+ sites suitable for development within the
city?
Does GCC recognise the concept of Green Belt Buffer land and is this one such site?
Is the content and timing of the completion of the JCS influential on this application?
Can the city, without its 5 Year Local Plan in place, refuse the application on the basis that there
is brownfield land available or wait until the Local Plan is in place?
We do not know the GCC house building requirement verses existing developments + agreed
planning sites. Therefore, how do we know that these 250+ houses are required?
Although this proposal is within Gloucester City Councils limits, its expansion will intrude into
Stroud DCs.
This raises a question of fairness would it be right for Stroud DC collect Council Tax when GCC
would have to face the problems, should further development lead on form this application?
Kingsway and Huntsgrove are Stroud developments but in reality, they house Gloucester
residents?
Building 250+ extra homes would equate to approximately an 8% increase in Tuffley housing
stock and a further 10% increase in Tuffley population.

Section 106:
Any money from developers will be inadequate for the loss of this buffer'.
Any Section 106 money usually goes into the county pot and is rarely spent at the point of need!
What Section 106 implications are likely to be imposed on the developers?
What guarantee would we have of the money being put back into Tuffley to develop roads from
a safety aspect, pot hole and other road repairs, leisure areas and parks, local facilities including
doctors and dentists, community centres, leisure facilities, shops, cafes we have nothing here?
Speaking to our local County Counsellor for Tuffley, she had no idea of any projects in place for
the regeneration of Tuffley, poor roads, schools, doctors and lack of other facilities and knew
nothing of these plans, until our phone call! She does not know of any money currently put
aside for Tuffley and could not confirm about the developers contributions!

WHO CAN ANSWER THESE QUESTIONS THEN WHAT HOPE HAVE WE GOT IN REGENERATION OF
OUR ALREADY DEPRIVED AREA? (GCC SALA 2012)

Other questions:
Environmental Impact Assessment 15/00934/EIA is noted and linked to this planning application
but is restricted from public viewing why?
What previous communications have GCC had with HLM with regards to 15/00934/EIA, before
and after the main outline application?
Why do HLMs plans quote 250, 260 and 300 houses on their different documents?
Stroud DC have not highlighted the fields adjoining the proposed site on their Local Plan and we
question what is HLMs interest on the area highlighted in blue on their plans, as this is Stroud
Land, adjacent to the proposed site?
Why have the brownfield sites for 200-400 homes on Bristol Road and Civil Service ground not
yet been started, even though the plans have been approved, instead of this site?
HLM spokesman stated in the Citizen last week to judge the plan on its own merits and as a
suitable location for new homes. Based on recent housing purchases, these are the sort of
houses that buy to let investors prices young couples and families out of, contrary to HLMs
statement. In reality, all any developer cares about is selling houses to the highest bidder!

In conclusion, Hallam Land Management - We, the residents of Tuffley, would like you to
respond to all of the above questions and reconsider the need to build on this land.
You are a land management company who intend to sell the land on to a builder and
need to be made aware of all of our concerns.
We would also like GCC to comment and respond, where relevant.
We live here and value our community spirit and appreciate the little green land there is
left in the area.
We act as a voice of the community, young and old and worry what this development
would do to the future of the local area as we already struggle on a daily basis with all of
the above points raised.
Yours faithfully,