The Voice Of The People Of The Forest of Dean

Allocations Development Plan Document. ADPD

This represents a submission by Dean Forest Voice (DFV) to the Forest of Dean District Council (FoDDC) in response to its invitation to comment on the Allocations Development Plan Document (ADPD).

About DFV

Dean Forest Voice was founded in 2000 to bring, the then, Countryside Agency in touch with local public opinion. At that time a "Special Status" for the Forest of Dean was under consideration.

The constitution was drawn up in 2001 and included (among others) the following objectives :-

  • To provide a collective voice able to address governmental and administrative organisations.

  • To promote and maintain Forest Culture

  • To ensure that ancient rights specific to the Forest of Dean are protected

DFV has gone from ‘strength to strength’ and currently has a recorded membership of 1000 plus and growing.

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The DFV Submission

The Inspector's report containing his assessment of the FoDDC's Core Strategy (CS) contained the following paragraph under the heading ‘Assessment of Soundness’ :-

I have also had regard to the draft National Planning Policy Framework (NPPF) document, issued for consultation on 25 July 2011, but it is still in draft form and subject to change so have accorded its policies little weight. Clearly the Inspector did not anticipate the subsequent impact that the NPPF would have on the CS once it had been published in its final draft.

Under the heading, ‘Examining Local Plans’ the NPPF states :-

Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the NPPF.

It is on this basis that DFV make their comments on, and proposals for consideration, when drafting the ADPD.

DFV wish to confine their arguements to two areas :-

  • 1. The total protection of the Statutory Forest in general and Forest waste in particular.

  • 2. The protection and retention of leisure and recreational areas in the Forest of Dean.

The adoption of the FoDDC's Core Strategy and Cinderford AAP was completed prior to the publication of the NPPF and, as such, does not take into account the findings of the latter.

Under Annex 1: Implementation of the NPPF it states :-

212. However, the policies contained in this Framework are material considerations which local planning authorities should take into account from the day of its publication. The Framework must be taken into account in the preparation of plans.

213. Plans may, therefore, need to be revised to take into account the policies in this Framework. This should be progressed as quickly as possible, either through a partial review or by preparing a new plan.

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The Statuory Forest and Forest Waste.

The Inspectors report, under the heading ‘Community Facilities (CSP.8), Recreation and Amenity Land (CSP. 9)’ states :-

Policy CSP.9 clearly states that all existing recreational land and buildings, all land identified as of high amenity value, and specifically all "Forest Waste" (FW) within the "Statutory Forest" (SF) (as defined in para 6.57 of the CS) whether so identified or not, will be protected from development, except where allocated otherwise in a development plan or containing existing buildings.It is the latter part ( "except where allocated etc..") that DFV wish to see deleted from Policy CSP.9 and in so doing give complete protection to the SF and FW.

The NPPF states:- 118. Planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss. The Inspectors Report states that the SF is clearly defined on the proposals map, and that the legal status of the SF can only be changed by Parliament and/or defined by the courts and not by anything in the CS (or an AAP).

The Rt Hon Greg Clark MP the Minister for Planning stated in the ‘Technical Guidance to the NPPF’

  • 1. Requirement on local planning authorities to take strategic approach in Local Plans to creation, protection, enhancement and management of networks of biodiversity and green infrastructure.

  • 2. Recognition of designation within Local Plans of locally designated sites of importance for wildlife, geo-diversity or landscape character.

  • 3. Clarification of which wildlife sites should have same protection as European sites. DFV believe that adherence to these principles will give the protection to the SF and FW for which we seek.

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The second issue on which we wish to comment is that of the retention of Recreation and Leisure facilities in the Forest of Dean, and in particular, the Five Acres Leisure Centre and grounds.

The Inspectors report states :-

Policy CSP.8 and CSP.9 makes it clear that the loss of existing recreational land and buildings will not normally be permitted and that new development is expected to make provision to meet its own needs, including for new facilities as well as open space.

The NPPF states :-

Existing open space, sports and recreational buildings and land, including playing fields should not be built on unless:

  • 1. An assessment has been undertaken which has clearly shown the open space, building or land to be surplus to requirements, or

  • 2. the loss resulting from the proposed development would be replaced by equivalent or better provision in terms of quantity and quality in a suitable location; or

  • 3. the development is for alternative sports and recreational provision, the needs for which clearly outweigh the loss. DFV request that ALL recreation and leisure areas be retained and maintained and not sold for development.

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Finally, we submit in support of our evidence, the opinions and proposals of HRH Prince William who has set up the Queen Elizabeth II Fields Challenge. He is aiming to safeguard 2,012 outdoor spaces by the end of 2012. The sites will be legally protected from sale to developers and badged as QEII Fields.

The outdoor spaces can be playing fields, recreation grounds or natural habitats such as meadows and coastline. They can be owned and run by local authorities, parish councils, community groups, sports clubs or private individuals. So far more than 1,300 local authorities, sports clubs, community groups and individuals have nominated land for Royal recognition. As well as sports grounds and recreation areas. they include an orchard, a stretch of coastal path and a wildflower meadow. Woodlands, waterways, play areas and cycle tracks are also eligible to be honoured.

HRH said that the dearth of green spaces is denying young people the chance to play and excercise - and issued a rallying cry to support a campaign to stop developers concreting over even more playing fields.

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This concludes the evidence submitted on behalf of Dean Forest Voice. It deals with the protection of the Statutory Forest and Forest Waste, and the retention of Leisure/Recreational facilities throughout the Forest of Dean. We hope that you will give consideration to our submissions and include them in the ADPD when it is compiled.

Keith Morgan (Hon Sec DFV)

Tel: 01594 833552