By Philip Booth for the Gloucestershire Green Party, Lark Rise, Bread Street, Ruscombe, Stroud, Glos. GL6 6EL 26th August 2004

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Introduction

 

This could be one of the largest development sites in the area for many years. Many people have complained of a lack of information about such a potentially large development in Stroud and Cotswold Districts. This report was commissioned by Cllr. Sarah Lunnon (Stroud District Council) on behalf of the Gloucestershire Green Party in an attempt to set out the arguments around possible development of the site and help fill the gap in available information.

The report draws on currently available information provided by many sources. Attempts have been made to ensure the information is accurate, however it should be noted that the complex nature of the many issues surrounding possible development of this site has made this difficult at times. The report is written in good faith after looking at all sides of the arguments. I would welcome comments and any information that might be considered useful in the further discussions about possible development of this site. I will also be happy to update this report in the light of further information.

In May 2004 all 34 planning applications for Aston Down were withdrawn by the applicant. We do not yet know whether a new application for development will be any different from what was previously submitted, but it is likely to be of a very significant size. The previous withdrawn planning applications amounted to about 20 “Major developments” of the 34 planning applications. A Transport Impact Assessment is already underway and Stroud District Council will request an Environmental Impact Assessment for the whole site when plans for the site are submitted. These essential reports will hopefully address in more detail many of the issues raised in this report. Perhaps the most important issue at present is whether the site has or has not got planning permission for “existing use”. Stroud District Council are currently seeking outside legal opinion on this question.

Philip Booth, Gloucestershire Green Party

Contents:

1. Brief history
1.1 History of airfield use to 2001
1.2 From 2001 to the present time
1.3 Current uses on application sites and on land adjacent to the application sites
2. Stroud District seeks legal opinion re “existing use”
3. Environmental and Transport Impact Assessments
4. What development might be proposed
5. Issues to consider regarding the development of Aston Down
5.1. Development will be contrary to Gloucestershire CCâ€â&dbquo;¢s adopted structure plan
5. 2. AONB objectives.
5.3. Transport issues
5.4 The Commons
5.5. Current use
5.6. Archaeological and historical potential
5.7. Water Aquifer
5.7. Tourism
5.8. Employment
6. Other issues regarding development 7. Conclusions

1. Brief history

1.1 History of airfield use to 2001

1.1.1. Aston Down was first used as an airfield in the first world war, when the Australian Flying Corps were based there. In those days it was known as Minchinhampton Airfield, but was renamed Aston Down after Minchinhampton residents became worried that the name would attract bombers to their village.

1.1.2. In 1937/8 the MoD requisitioned Aston Down. During the second world war the hard runways and hangars were built and the airfield was used as a ferry base. The site remained a military airfield until the early 1960s when it became known as Defence Storage and Distribution Centre (DSDC) Aston Down. The Cotswold Gliding Club moved in 1967 to Aston Down.

1.1.3. In 1981 the airfield became surplus to requirements and was sold by the MoD. The MoD retained 55 hectares (136 acres) including the main site, 5 outer sites, and the perimeter road. Some materials talk about the site being 51 hectares (131 acres). It is not clear why there is a difference. The Cotswold Gliding Club purchased a large part of the airfield within the perimeter track, through a company, Aston Down Farms limited. In 1998 they submitted a Certificate of Lawfulness of Proposed Use or Development (CLOPUD). The remaining farmland was sold to previous land owners and HRH.

1.1.4. One warehouse unit was sold for use by the Cotswold Gliding Club (Unit 40 in front of hangers on B site). This unit was later sold to Adtech who still continue to work from these premises. Following the later sale the MoD demolished the remaining 39 warehouse units. Residents heard at the time it was because the MoD did not wish to see the area become an industrial estate.

1.1.5. MoD operation and maintenance tasks were contracted out to Serco on three year contracts from 1986 through to 2001. It is said that up to 2000 military vehicles and 1.75 million boxes of ammunition were stored on the site at any one time. Local residents say the main site use was minimal during this time and that the MoD were “excellent neighbours”. Figures show during this period that at peak times there were 1000 vehicle movements per month which included all MoD operations but not DEFRA to the main site. This equates to an average of 34 vehicle movements per day (Aston Down Action Group note this figure was supplied by the applicant in the first Transport Appraisal December 2002). Paragraph 7.09 of Transport Appraisal also states "Security recorded approx. 1,000 vehicle movements per month via the security gate." Therefore the total approximated vehicle movements to the site during MoD operations equated to an average 65 vehicle movements daily. During this same period it appears the outer sites were in effect not utilised at all. David Drew, MP, has advised that the outer hangars were either empty or still had parts of Wellington Planes stored from the 2nd World War. This has been confirmed by a number of locals who have been using the east perimeter road since the 1980â€â&dbquo;¢s to walk, ride and cycle. Occupants of neighbouring properties overlooking the outer sites, have also said they have never until recently seen the hangar doors opened on the outer sites. The MoD used the main site to sell off old stock, mainly vehicles and trailers. This took place about 6 times a year. The MOD did not allow any vehicles to go west from the site on the Cirencester Road. All vehicle movements had to go onto the A419 so as to protect the Commons and the tranquillity of the rural community. Furthermore their vehicles did not have reversing warning signals and their operations have been minimal.

1.1.6. In 1998 the MoD submitted notification to the LPA under Circular 18/84 advising of their intentions to refurbish the roofs of all hangers on C and F sites, to rebuild a chimney on F site to a height of 60 feet and the removal of asbestos from a number of hangers. Rumours began circulating that the MOD was disposing of the Aston Down site, but it was not until January 2000 they entered into a consultation process on the sale of the Aston Down site.

1.1.7. DEFRA have operated from the main site for about 20 years. Prior to the MoD sale, applied under DOE Circular 18/84 for existing use with employment up to 100 people, This was later approved by the LPA and DEFRA purchased the north-west corner of the site.

1.1.8. In July 2000 a planning application for a 3 hectare site directly adjacent to the main site was resubmitted. It had been approved five years earlier but was time expired. Although the applicant noted the Government Guidance on the re-use of brownfield sites the SDC Planning Officer stated; “It is also worth noting guidance on sustainability outlined in Planning Policy Guidance Note 13 which should be read in conjunction with it”. SDC with the full support of CDC rejected the application on sustainability grounds.

1.2 From 2001 to the present time

1.2.1. March 2001 saw the MoD vacate the site and the end of their contract with Serco. Up until this time there were 80 employees working for the MOD and they were all made redundant (Hansard). The site was actively marketed for sale. From March 2001 Serco was contracted to operate the security on the site with some general maintenance.

1.2.2. In March 2002 Aston Down was sold, the main site, the five outer sites and the perimeter road to Leda Properties Limited, Leda Properties Pension Fund and personally to the Directorâ€â&dbquo;¢s of Leda Properties Limited in that order. These sites contained 13 hangers, 5 smaller warehouse units and a number of smaller brick buildings and represented 68,000sqm of building space.

1.2.3. In December 2002 a series of planning applications (30 applications in SDC and 4 in CDC) were submitted for development at the Aston Down site together with a Transport Appraisal; 20 of the 34 applications constituted Major development. There has been confusion about an Environmental Impact Assessment and whether it had been requested for the whole site on these planning applications (See point 3 below).

1.2.4. In June 2003 the Highways Agency were not satisfied that the Transport Appraisal was robust enough and requested “that the applications should not be determined until a revised traffic and supporting planning statement have been supplied and assessed to our satisfaction”.

1.2.5. In February 2004 an addendum to the Transport Appraisal and a new planning statement were submitted. However the Highways Agency (HA) continued to be dissatisfied with the information within the recent transport report. There existed an agreement between HA and both SDC and CDC not to determine the applications until such time as the Transport Impact Assessment was to the HAâ€â&dbquo;¢s satisfaction. In May 2004 the applications were withdrawn before they went to Committee.

1.3 Current uses on application sites and on land adjacent to the application sites

1.3.1. Planning consent exists for the Cotswold Gliding Club (Gliding planes only), DEFRA, Adtech Limited and the three residential houses (Two on the site in front of hangers on B site and one in front of D site on the Cherington Road). The majority of the airfield is farmed and until recently the grass around hangars on the site was cut and used for silage.

1.3.2. Since the sale of the site residents have witnessed a significant increase in “unauthorised” activity on the site compared to the previous operations in the last twenty years. There are now a significant number of activities and businesses being carried out on the site. These are mainly located on the main site, but the hangars on the outer sites are also being used. It is unknown the whole extent of these but they include over 12 companies. Among these are Treasure Trove (packaging services), the Service Team, Colt Cars (Mitsubishi), Unite Limited, Cotswold Plastic Reclamation and Mole Plastics Limited. See 5.5 for further information on how these are impacting on the site.

2. Stroud District seeks legal opinion re “existing use”

It is expected that a planning application for the whole site will be submitted with the new Transport Impact Assessment this September. Currently outside legal opinion is being sought by Stroud District Council on what planning permission may or may not exist on the site. It is apparent that the MOD did not apply for an "existing use" under DOE Circular 18/84 before the sale despite going through this same process for the refurbishment in 1998. The outside legal opinion is expected at any time and SDC have said the summary of the results of that opinion will be made public (Meeting 3/8/04 with Aston Down Action Group).

3. Environmental and Transport Impact Assessments

There was, as noted, some confusion about an Environmental Impact Assessment and whether it had been requested for the whole site on the previous planning applications. However Stroud District Council have confirmed at a meeting with Aston Down Action Group (3/8/04) that an EIA would be requested for the whole site inside Stroud District when a new application is made. John Sands, of the Cotswold and Vale AONB Partnership, who has visited the site regards an EIA on the whole site as essential. This view is common with groups like the Rodborough Commons Committee, the National Trust and the Aston Down Action Group also saying an EIA is essential. A comprehensive Transport Impact Assessment is currently underway by David Tucker Associates (see 5.3.). It is envisaged it will be available in September 2004.

4. What development might be proposed

We do not know yet what might be proposed on the site, but it could include a large plan for industrial use on the lines of the previous applications. The area has 68,000 Sq. metres of existing buildings, some of which are in use. Some people consider development here would be less intrusive than on other sites. It is also argued that businesses and industrial premises could be good for employment in the area. Some people have suggested applications might eventually include mixed use housing. There are arguments that small scale housing projects could enhance the existing sites natural beauty by replacing some of the ugly hangers. However as the next section illustrates there are a number of issues and material considerations that need seriously to be considered.

5. Issues to consider regarding the development of Aston Down

Aston Down is located in the open countryside in the AONB on a site of 55 hectares (136 acres). The following issues need considering:

5.1. Development will be contrary to Gloucestershire CC's adopted structure plan

5.1.1. This site has not been allocated for development in either CDC or SDC Local Plans. Indeed those plans have identified sufficient sites for industry and housing, without this possible development. The site is also not located within a settlement boundary and is therefore classed as open countryside. In addition it is located wholly within the Cotswold AONB.

5.1.2. Any Major development (i.e. in excess of 1 hectare or change of use of a building 1,000sq m), like those proposed in the withdrawn applications, would be contrary to NHE4 of Gloucestershire Structure Plan, SDC Local Plan Policy N6 and the CDC Local Plan.

5.1.3. The Gloucestershire Structure Plan “ Policy NHE4 states "in AONBs the conservation and enhancement of the natural beauty will be given priority over other considerations. Regard will also be had to the economic and social well-being of the AONB. Provision should not be made for major development with the AONB unless it is in the national interest and the lack of alternative sites justifies an exception". CDC Policy 19.2 similarly states “Major industrial or commercial developments which are likely to be in conflict with AONB objectives will not be permitted unless justified exceptionally due to national interest and lack of alternative sites.” It has neither been demonstrated that the planning applications within the AONB are in the national interest nor that there is a lack of alternative sites.

5.1.4. The Gloucestershire Structure Planning Policy S.4. states that “Development within open countryside will be strictly controlled”. E.4. states: "commercial and industrial development in the open countryside will be strictly controlled and restricted to small scale sensitive enterprises which are essential to agriculture or forestry or other rural industries, or which reuse existing buildings in a manner which maintains or enhances the character and appearance of the surroundings". See section 5.8. below for further information.

5.1.5. Policy S.3. of the GCC Structure Plan states that “In rural areas previously developed land may exist but it may be in locations where development could be intrusive in the countryside or highly unsuitable”. In this respect, it is important to note that policy T.1 states that “New development should be located so as to minimise the length and number of motorised journeys, and encourage the use of public transport, cycling and walking. New development should be genuinely accessible by these modes of transport as alternatives to the car.”

5.1.6. Although this site could be considered as previously developed land (brownfield) not all previously developed land is suitable for development through location and sustainability. Under Policy 15 of SDC Local Plan it cannot be demonstrated that all the criteria can be met for re-use and adaptation of buildings in a rural area. The hangars and warehouses do not appear to fit the specifications as outlined in paragraph 7.8.9. which specifically notes buildings of “substantial, sound and permanent construction.” The MoD describes the hangars and sheds as “Semi-Permanent buildings”. At least four hangars appear to be in a particularly poor state of repair.

5.1.7. Aston Down is not listed under the Major Strategic Employment sites identified (SD.14). The Gloucestershire Structure Plan identifies sites of 12 hectares or more as Major Strategic Employment sites which should be located close to principal urban centres, close to large pools of labour, with appropriate infrastructure and free from constraints such as designated AONBs. Gloucestershire Structure Plan Policy SD.14 states "Major Strategic Employment sites.... - A minimum size of 12 and preferably 50+ hectares -Free from significant constraints; and -Close to large pools of labour, with appropriate infrastructure, including sustainable transport opportunities" The proposed development of Aston Down therefore goes against the Development Plan. Paragraph 3.2.64 states: "It is not appropriate for such sites to be located at other rural settlements nor within the open countryside, where appropriate employment development should be more limited in scale(see policies SD.5 and SD.6). This is because locally significant employment sites in these locations would be both less likely to be accessible to sources of labour and business services as well as less likely to be well served by public transport."

5.1.8. Any significant development will prejudice the well being of the AONB, the local community and tourism of the area.

5. 2. AONB objectives.

5.2.1 The objection submitted by the National Trust in a letter dated 4 March 2004 to the first applications highlights their key reasons for objecting and testifies their experience as landowners to land adjacent or close to former airfields that have been developed commercially.

They write: “The National Trust wishes to object strongly to these applications on the following grounds:
o The applications are entirely contrary to adopted and developing Planning policy.
o They are likely to lead to significant increases in HGV traffic on unsuitable roads across land which the Trust owns for the benefit of the nation, and which is very well used by the public for quiet recreation.
o The site is within the Cotswold Area of Outstanding Natural Beauty, and - whilst the applications are primarily changes of use of existing buildings – evidence suggests that an incremental growth in signs, advertising, lighting, security fencing etc. would take place which would effectively urbanise inappropriately this AONB location.”

5.2.2 The National Trust notes they have properties around the country located close to former airfields. They say they: “have observed an incremental change to the nature of the local environment, which has in effect led to the creation of an urbanised and heavily developed site on what was formerly an open site with several individual, though large, buildings on it. The visual impact is often compounded by small-scale changes, such as security fencing, lighting, outdoor storage, parking, and advertising boards…" The letter continues "In some locations this gradual change is regrettable but not greatly damaging. Within an AONB location – where a recent change (June 2000) to PPG7 has established AONBs as of equal landscape importance as National Parks – it would be unforgivable".

5.2.3. English Nature Land Restoration Trust note that some “brownfield” sites are not suitable for development because of their location and sustainability.

5.2.4 The English Partnerships, The National Regeneration Agency (special adviser to the Deputy Prime Minister on brownfield issues) compiled a report "Towards a National Brownfield Strategy" for the DPM dated September 2003. Paragraph 3.4.1 Regulatory Constraints states "The fact that a given parcel of land or property was once in a particular productive use does not mean that a similar use would be judged appropriate at the current time........At the same time, regulatory change of one form or another may dictate that alternative economic activities are no longer appropriate at that location. Factors that could influence such changes include:
- specific land protection policies (e.g. Green Belts or AONB),
- strategic land use planning policies (e.g. the presumption against freestanding development outside establish urban areas),
- nature conservation factors......
Clearly, the regulatory constraints can vary in the degree of their impact. Certain constraints may be fairly absolute and preclude a given form of development. Others may, on investigation, be subject to amelioration, albeit with the consequence that addressing these constraints adds to the uncertainty, and therefore to the costs of redeveloping such sites.

5.3. Transport issues

The volume of traffic that will be generated by any Major development of Aston Down is of enormous concern to all living and working in the region. The previous applications caused considerable concern. The GCC lodged a strategic objection to the proposed development. The Highways Agency also wrote saying they would consider issuing an Article 14 direction against every application for development on the site (ie prevent the SDC from determining any of the applications) unless a more robust Transport Impact Assessment was made. The following points are worth considering:

5.3.1. The January 2004 Addendum to the Transport Appraisal states that the overall parking spaces allocated for the application sites numbered 997 spaces. In addition to this DEFRA have permission for 100 employees, currently they have 94. At a recent count on the DEFRA site there were over 100 cars, including visitors and cars in the compound. The size of the car parking allocations suggest the unsustainability of the site and the reliance on the private car. Sustainable development is central to government policy. This proposed development is therefore contrary government policy.

5.3.2. The site is located within the open countryside and is not served by adequate footways, cycleways or public transport facilities where there is already a high reliance upon the private motor car and the development would be likely to increase this reliance contrary to adopted Structure Plan policy T1.

Indeed paragraph 7.04 of the Transport Appraisal states total daily vehicle movements to the site could be in the region of 2,940. "Daily flows generated by the proposed development when all premises are let could be in the region of:
SITE NO. TRIPS
Main site 1,428
Site B 275
Site C 388
Site D 275
Site F 281
Site G 293
TOTAL 2,940
This is a significant increase on previous levels (See 1.1.5).

5.3.3. There is a potential conflict between the volume of traffic on the perimeter road and the safety requirements necessary to operate the Cotswold Gliding Club. Mr Bagley of the Cotswold Gliding Club notes they do not as a club have any objection to development of the Aston Down site as long as the Airfield Safeguarding procedures are met. These requirements include no vehicle movements across the approach to the airfield. Leda and the Gliding Club are having discussions to resolve this breach. I understand that if planning is approved on the outer sites which leads to breaches in the Safeguarding procedures for operating the gliding club a claim may be brought against SDC/CDC for potentially high losses. It is clear that if the legal position of this has not already been examined, then it should be clarified.

5.3.4. Development at Aston Down will lead to an increase in vehicle movements to the site putting the safety of other road users, particularly horse riders, cyclists and ramblers at risk. Already the unauthorised use of the site has generated a significant volume of HGV movements that has made an adverse impact on the local highway network. (See 5.5.6.) There are a number of professional equine yards, riding schools and livery stables as well as several private stables, the majority of which access directly onto the Cirencester Road. The actual number of horses that access onto the Cirencester Road number 100.

5.3.5. The Transport Appraisal states that there will be no lorry movements from Aston Down westbound along the Cirencester Road or along the Crackstone Road. This has not been the case. Two of the companies that have set up operations at Aston Down, namely The Service Team and Downton Haulage have consistently been using the Cirencester Road to cross the Commons exiting via the Butts having driven through the settlements of Minchinhampton and Rodborough. Downton Haulage has also been seen using the Crackstone Road having passed through the settlement of Avening. The Aston Down Action Group have photos that show the dangers of the current situation.

5.3.6. The proposed development would result in a material intensification in vehicular movements along narrow, poorly aligned highways leading to/from Minchinhampton and Rodborough Commons including the Commons themselves all to the detriment of Highway safety (See 5.4 for further information). The Rodborough Action Group was set up last year in response to increases in traffic. A petition was signed by more than 100 people complaining about the traffic through a narrow road and the safety of pedestrians and other road users.

5.3.7. The County Council, as Highway Authority, is very concerned about the potential increase in vehicular movements across the Commons via Cirencester Road which has a higher accident rate per 100,000 vehicular km than the adjacent roads; and in addition, on leaving the common vehicles have to negotiate narrow, steep, poorly aligned roads. They have also expressed other specific concerns.

5.3.8. The A419 is already stretched to capacity. with many problems reported by residents.

5.3.9. Public transport provision is currently very poor. It is also subsidised and its continued use cannot be guaranteed. There is also no other sustainable transport-related supporting infrastructure such as cycle ways or footways etc.

5.4 The Commons

5.4.1. The main accesses to Aston Down are onto the unclassified grade 3 Cirencester Road that leads to the A419 and West to the Minchinhampton and Rodborough Commons. This route across the Commons, which are just over a mile away from the site, is seen as the faster, more direct way to access the Ebley By-pass and onto Stonehouse and the M5.

5.4.2. The Commons are one of the best examples of unimproved limestone upland in Europe and are established as Sites of Special Scientific Interest (SSSI). Rodborough Common is designated as a European Special Area of Conservation (SAC).

5.4.3. The current traffic volumes are already high over the unclassified road and present a very real danger to the grazing animals on which the status and ecology of these areas rely. Each year a number of animals are killed by vehicles crossing the Commons, should this continue or increase it will only be a matter of time before the Commoners decide the losses are no longer acceptable.

5.4.4. The National Trust has expressed concern about increasing traffic volumes across the Common, which they say “are the source of erosion of verges, and damaging to the particular character of this large public open space.”

5.4.5. The National Trust also expressed concerns about certain aspects of the January 2004 Transport Appraisal. In particular they write: “the Trust is less than convinced by assurances that mitigation such as lorry routing and a signing scheme will solve the problem of HGVs using entirely unsuitable roads, or that a travel plan will be effective in reducing private car movements. What is perhaps most concerning is the applicantsâ€â&dbquo;¢ claim that the proposals are sustainable [para 7.2]. This site may involve re-use of existing buildings, but is entirely unsustainable in terms of travel to work distances for employees, and distance from of employment land from either the trunk road network or from rail/water alternatives.”

5.4.6. Steven Davis, speaking for the Commons Committee which is responsible for the fragile ecology of the Commons, said they have been concerned with increasing traffic across the Commons. This increase (See also 5.4.8 below) appears to have been due to a number of factors: the much-needed traffic calming measures on the London Road, the considerable road works in the area and to some extent the unauthorised development at Aston Down. However these do not seem to be a full explanation of the recent increases. The Committee would be “deeply concerned” by any further development. He noted the economy of grazing has been effected by deaths of animals and he believes grazing will not survive further increases in traffic. So far this year there has only been one animal death, which is down on previous years. This is possibly partly due to a high profile campaign around the issue. Controlling traffic speed is another issue.

5.4.7. Brian Oosthuysen of Rodborough Parish Council notes that the Council has expressed “deep concern about the prospect of any development at Aston Down and the implications it will have on traffic.”

5.4.8. GCC figures show an 11.8 per cent increase in traffic across the Commons from 1997 to 2001 whereas in the same period average traffic increase in SDC (not including trunk roads or motorways) has only increased by one percent and in Gloucestershire (not including trunk roads or motorways) only 2.4 per cent. Care needs to be taken when viewing these figures as they are only from one-day traffic count surveys. ATC figures for traffic flow (24 hour 5 day, two way) for November 2002 show 10,000 vehicles while for September 2003 it was 8,800. These figures are for different months and do not take account of factors like roadworks on A419, Butterow Hill and the Butts. They also do not seem consistent with other information received. The Commons Committee, Rodborough Parish Council and others consider that traffic on the Commons has been increasing over the last two years. This is largely due to the general increase in traffic everywhere and the roadworks with the A419. It is not possible to say to what extent current developments at Aston Down may have on traffic across the Commons, other than to note that it is also a contributing factor.

5.4.9. GCC figures suggest that HGV only make up about one per cent of traffic using the Commons at present. The planned ban of larger 7.5 tonne HGV vehicles using this road is a very positive step forward to tackling traffic use on the Commons, but is still only a very small part of the growing problem.

5.4.10. Many residents have expressed concerns that the new 5000 seat stadium and housing in Nailsworth will also add to the traffic on the Commons.

5.5. Current use since the “unauthorised” use of the hangars/buildings at Aston Down there has been an increase in light pollution, outside storage, litter, parking and noise. Residents in the area have made a number of complaints:

5.5.1. The existing hangers and buildings are unsightly and out of place in the open countryside in the AONB. The “blister” type hangers are some 300 feet long with large doors at each end. They have special regulations that include when wind speeds exceed 60 mph, the doors should be closed and in snowfall of up to 4 inches the hangars must be examined to ensure the additional weight is not undermining the structure and vacated if under threat of damage. Some of these hangers may not conform to Health and Safety regulations. At other ex-MOD airfields such hangers have been removed to make way for modern development e.g. Javelin Park. In other situations they have been demolished as part of an overall development proposal to develop a limited area.

5.5.2. Storage - There has also been an increase in outside storage, much of it unsightly. Photographs are available from the Aston Down action Group showing the extent of this storage including portacabins. Unite Limited, for example, store many of their brightly coloured pods (accommodation units) outside. This type of outside storage devalues and degrades the AONB. It is not only the views to the site but from the site which impacts on the AONB.

5.5.3. Light pollution - When the MOD operated from the base only the Main Site had lighting. The outer B, C, D, F, and G sites were always kept unlit. Since last summer and the creeping unauthorised industrialisation of the outer sites each hangar now is lit up by an overhead light above the hangar doors (some 40 feet in height). These lights can be seen from the top of Beacon Farm on the stretch of the A419 overlooking the site and the country roads around the site. There has also been an increase in light pollution from the flashing lights from forklift trucks and other vehicles.

5.5.4. Noise - There are very few barriers to stop any industrial noise from Aston Down travelling across the escarpment. For example from over a mile away the clattering of the forklift can be heard moving from the Main Site to F Site, noises from Building 15, the Service Team, when the Scarab was being tested and machinery from the plastic reclamation companies operating from G site and the main site. The reversing warning noise of vehicles can also easily be heard from a mile distance. This is a significant change into what has consistently been exceedingly quiet countryside. This was demonstrated by noise readings taken in June 2000 by SDC when the only background sounds were bird song.

5.5.5. Litter - Packaging and rubbish that in the past was never observed now is seen regularly being blown around the site; particularly plastic and foam.

5.5.6. Extra traffic - Many people have already noticed a significant increase in traffic. People living on the local country roads at Crackstone that lead to Avening and Tetbury have noticed an increase in traffic movements, particularly HGVs. These roads are not suitable for both the development traffic to Aston Down and horse riders, cyclists, and walkers. See 5.4.8. re the Commons. The HGV movement from the site through the settlements of Minchinhampton and the Butts at Rodborough have also had a serious adverse impact on the residents particularly of Rodborough. So much so that the Rodborough Action Group was set up last year (See 5.3.6.). The Service Team and Downton Haulage appear to be the most frequent offenders, and more recently Alpha Hire. Car drivers have reported several very minor incidents in the last week alone where HGVâ€â&dbquo;¢s from Aston Down have driven over kerbs and had rear wheels slip in the wet on the hills.

5.5.7. Mr Bagley of the Cotswold Gliding Club notes that they are concerned that current traffic use on the site breaches the Airfield Safeguarding procedures.

5.5.8. The current use of the site is already causing difficulties. It should be noted that this is only part of the site.

5.6. Archaeological and historical potential

C. Parry, Senior Archaeological Officer, GCC in a letter to SDC (6/02/03) wrote: “the site has considerable archaeological and historical potential.” He also wrote “any development requiring alteration to existing buildings or requiring groundwork's, may have significant archaeological implications.” On 15/01/04 he wrote, in the light of the various planning applications, recommending “that a study of the historical and archaeological character of the whole airfield should be undertaken.”

5.7. Water Aquifer

The Environment Agency confirmed in a letter to SDC (12/02/03) that the site overlies Oolitic Limestone and as such is classified as a Major Aquifer of High Vulnerability. This means that watercourses must be protected with any development of the site. Conditions include oils, fuels or chemicals being sited on impervious bases and surrounded by impervious walls plus no discharging of foul or contaminated drainage into groundwater or soakways.

5.7. Tourism

Stroud District Councilâ€â&dbquo;¢s Local Plan states they wish “to see the local tourist industry flourish in response to market demand. At the same time it wishes to protect the special environmental qualities that attract visitors in the first place.” Major developments on this site could jeopardise these intentions. Already we have seen the very sensitive Commons face considerable problems from the increase in traffic.

5.8. Employment

It has been argued that this site would provide employment to those living in the area. There is evidence of a growing need for smaller workplaces as outlined in 5.8.1 and arguments that Aston Down could be part of the solution. However the arguments make no reference to issues like traffic and furthermore the Local Plan does not appear to support such development at Aston Down as evidenced in 5.82 - 5.8.6.

5.8.1. Stroud Valleys Employment Study prepared for SDC by White Young Planning and Chesterton plc (November 2003) makes a number of important points. They include: Demand for B1 and B2 uses have dominated the market. B8 take up in the area is limited due to competitors like Quedgley. Indeed virtually no or very limited take up activity was recorded for B8 in Stroud (1996-2001). There is a demand for smaller workplaces (ie 2,500 to 10,000 feet sq.) and this looks set to grow. The existence of large vacant premises in the area reflects the unsuitability in meeting the requirements of local demand. The west of the area, benefits from its proximity to the M5 and tends to cater more for the larger units. Economic activity rates are growing in the District, unemployment is falling, overall skills base is improving and average earnings are rising. The districtâ€â&dbquo;¢s proximity to main urban centres such as Gloucester, Cheltenham, Swindon and Bristol means that it attracts commuters and there is a net outflow of employment from the district. Out-commuting is increasing, local employment opportunities have declined, but there is a positive growth in the number of business within the area. The loss of jobs is due to the decline in the manufacturing industry. “These job loses are having little impact upon the overall local labour force who reside in the study area”. The report notes some existing sites are under-utilised and in need of improvement. It identifies three key employment sites for future redevelopment in the district: Dudridge, Lodgemore and Ham Mill. The report urges the Council to be pro-active and ensure that “under-utilised employment land can be brought back into economic use” in central and eastern areas to tackle the lack of ”quality” premises in those areas. The report makes references to Aston Down: “A high demand exists for freehold premises. This can be irrespective of location. The appeal of workplace provision at Aston Down is likely to be determined by the availability of units on a freehold basis. Agents report that the success of this site should be based on a comprehensive master plan exercise and marketing campaign to understand true levels of demand for the accommodation available.”

5.8.2. Policy S.1. states that “the bulk of new development should be accommodated within and adjacent to the Countyâ€â&dbquo;¢s larger towns...” Policy E.2. states that “most employment development will be in the Central Severn Vale....In Stroud District outside the Central Severn Vale, development serving the needs of the District will be provided mostly in Stroud/Stonehouse...In Cotswold District development serving the needs of the District will mostly be provided in and adjacent to Cirencester.”

5.8.3. SDC Local Plan notes; “2.2.1g..this local plan can play its part in working towards a sustainable society in a number of ways;- 1 Influencing the location of new development in order to reduce the need to travel and make for provision for an integrated transport network”. They go onto note; “the overall healthy nature of the Stroud Economy”.

5.8.4. Aston Down is not mentioned in the Major Strategic Employment sites identified (SD.14) in the Deposit Draft Third Alteration. See 5.1.7. for further information. SDC has already allocated more than the 100 hectares of employment land indicated in the Structure Plan (Policy E.1) for the District.

5.8.5. The Structure Plan specifically attempts to prioritise B.8. at locations that have the potential to be served from wharves, harbours or railway sidings. this site does not have access to any of these. Stroud Local Plan E1A states that “....Development proposals for business and general industrial uses (uses B1 and B2) will only be permitted on protected employment sites, employment allocations and within, or adjacent to settlement boundaries where:- 1. They can be integrated with housing, commercial, leisure and community facilities. 2. They can be safely and conveniently accessed by public transport, from the anticipated employee catchment area and by walking and cycling. The site does not meet these criteria. It is also worthwhile noting that the SDC Local Plan - Proposed Changes (June 2001) which is currently being examined by the inspectorate, strengthens Policy E1A. The proposed changes to this policy are as follows: Development proposals for B1 business, B2 general industrial and B8 storage and distribution uses will only be permitted within defined settlement boundaries where they can be integrated with housing commercial, leisure and community facilities; Large scale travel intensive uses such as B1 (office) development should be located in the defined settlements of Cam and Dursley, Nailsworth, Stonehouse, Stroud and Wotton-under-Edge or where they can be safely and conveniently accessed by public transport from the anticipated employee catchment area and by walking and cycling. Large scale B8 storage and distribution uses will only be permitted where they will not lead to the increase of HGV traffic through defined settlements and they have good accessibility to, and use one or more of:
1. The rail network.
2. The port of sharpness.
3. The Gloucester and Sharpness Canal.
4. The principal road network.

5.8.6. Stroud Local Plan E1A states that “Storage and Distribution uses (Classes B8) will only be permitted where they will not lead to the increase of HGV movements through defined settlements and have good accessibility to the principle road network.” The site does not meet this criteria.

5.8.7. Existing industrial sites seem to not be developed as much as they could. For example the majority of units at Station Road Industrial Estate in South Woodchester are empty.

5.8.8. The applicants Transport Appraisal acknowledges that only 10 percent of the employment at the site will be from the local area with the remainder expected from areas up to 25 miles away.

6. Other issues regarding development

This report does not seek to make specific recommendations for or against the possible development of the site. Some issues to consider include:

6.1. The CDC Draft Local Plan 12/02/03 states “The Council will work with SDC on the preparation of a joint policy for acceptable uses of the site and buildings. A piecemeal development of the site will be resisted.” Cllr. John Marjoram (SDC councillor and Stroud Town Council) said: “It is vital that we in SDC look at this site with CDC. Any form of piecemeal development could have disastrous consequences for the whole area.”

6.2. Draft PPS7 Under “Key Principles” 1.v. “Priority should be given to the reuse of previously developed (brownfield) sites in preference to the development of greenfield sites, except in cases where brownfield sites perform so poorly in terms of sustainability considerations (e.g. remoteness from settlements and services) in comparison with greenfield sites.”

6.3. Martin Whiteside, District Councillor for Thrupp said regarding the previous applications: "Aston Down is not an appropriate site for this scale of development. The proposals we have seen so far would be unsustainable and could create a traffic nightmare not only for the commons but also for Cowcombe Hill and the Golden Valley. We need to think about the possibilities for the site that will benefit the environment and local communities - this needs creative thinking and proper consultation."

6.4. Simon Excell, Structure and Local Planning with GCC expressed “numerous concerns” about the previous planning applications for the site in a letter to SDC (12/05/03). He noted the “strict controls on development” in open countryside and AONB and that it was not in an area of development identified by the Structure or Local Plans for development. He also noted that while the applications were for the re-use of existing buildings, this does not alleviate planning concerns. Policy S.3. of the Structure Plan states that such previously developed land may not be in locations where development could be “highly unsuitable”. He says this is “particularly relevant regarding the transport concerns”.

6.5. David Sledge of the Highways Agency has written to SDC (31/12/03) noting numerous concerns with the original planning applications and that they believe that those developments did not comply with the Local Plan.

6.6. Consultants RPS Planning, Transport and Environment, acting on behalf of the Aston Down Action Group, reviewed the planning applications and wrote: “The impact of the proposals upon the environmental sensitivity of the locality, the local highway network, the residential amenity of neighbouring residents and the visual qualities and beauty of the surrounding area will be significantly and irreversibly damaged if permission is granted for these proposals.” They argue that the MoD site had been wound down, that no Circular 18/84 had been made and that the site would therefore no longer have any legitimate planning use. Under these circumstances, this brownfield site in an AONB would have to be looked at as new development. New development in AONB would not be permitted.

6.7. Views vary on what might be possible. In discussions with numerous people about possible development it seems there are those who consider any development on this site in an AONB is wrong and that the land should be returned to farming. This is a minority view. Few people have argued for full development of the site and few have expressed anything but alarm at the prospect of housing. Some people suggested the need for affordable housing, but on closer examination of the site they ruled this out for the many reasons already noted in this report, not least traffic considerations. The majority of people seem to accept that some very limited development maybe acceptable. In this group there are those who would not wish to see anything more than the current use and those who see this as already too much. A number of people have said development should be confined to part of the main site with the other sites being returned to farming. This has happened at other former MoD sites.

6.8 Minchinhampton Parish Council convened a meeting on 24th August with neighbouring parish councils to discuss the planned development and share ideas about the possible development. They plan to have more meetings in the near future with a wider group of people.

7. Conclusions

7.1. Any Major development would not comply with Local Planning Policy, the Gloucestershire Structure Plan, or National Planning Policy. The Site is unsuitable for these developments being in open countryside, in the Cotswold AONB and lacking transport connections that meet the criteria of sustainability. The volume of traffic that this Site would generate crossing the Commons is incompatible with the conservation of SSSI and European designated SAC. The increase in the volume of traffic that this Site would generate on our country roads would also compromise the safety of other road users. However it is clear that irrespective of any Aston Down development, traffic on the Common needs to be looked at and significantly reduced.

7.2. An Environmental Impact Assessment on the whole site is essential.

7.3. There are arguments that Aston Down could provide employment opportunities, but these appear to ignore the other issues that include traffic and the Structure Plan.

7.4. The current use of the site is already more development than is desirable or sustainable. If any development is to be approved for this site it would be best to concentrate it on one site. It would also make sense to use the more substantial buildings that comply with Policy B15 of the SDC Local Plan, like the red brick buildings rather than the hangars that appear to be in such a poor state of repair.