Parish Council response to the draft FoDDC Local Plan consultation

Purpose of the Local Plan
The Local Plan should address the specific needs of the Forest of Dean and reflect local circumstances, rather than respond solely to national policy changes. The Plan lacks the evidence required to justify its strategic approach and proposed policies, especially housing. Under the Examination process, a Local Plan must be founded on robust, up‑to‑date local evidence. This Plan does not meet that standard.

Housing Need

No evidence has been provided to justify the significant increase in the proposed housing numbers.

ONS data shows the Forest of Dean population grew by 4% between 2019–2024, continuing a similar trend from 2014–2018. Even if this rate continues, the projected growth to 2041 is just over 11,000 people, which does not support the requirement for 12,500 additional homes.

The most recent Housing Needs Assessment dates from 2009. NPPF paragraphs 34, 62 and 69 require an up‑to‑date housing needs assessment, no more than five years old. There is also no information explaining how the Council assessed its housing requirement for the purpose of demonstrating a five‑year housing land supply if there is no recent housing needs assessment (NPPF para 78).

The NPPF and housing methodology were revised in December 2024, increasing the district’s indicative housing requirement to 12,080 homes by 2045. The Plan does not confirm whether this figure is supported by current and accurate needs data. The Council’s own statement that housing numbers “may” increase by 12% highlights the uncertainty. Without transparent evidence, the proposed requirement is driven by central government expectations rather than demonstrated local need. We cannot support a Plan that lacks justification for this level of growth.

Infrastructure

Although the Plan references future collaboration with infrastructure providers, there is no evidence of meaningful engagement or confirmation that essential infrastructure can be delivered. As a result, the policies remain aspirational rather than actionable.

NPPF paragraph 20 states that strategic policies should make sufficient provision for infrastructure for transport, telecommunications, security, waste management, water supply, wastewater, flood risk and community facilities (such as health and  education). NPPF paragraph 27 states that where matters which require collaboration have been identified, the Local Plan should be aligned with the investment plans of the infrastructure providers.

Local Plan Policy RLP.2 Infrastructure does not currently provide sufficient assurance. It should be strengthened to require infrastructure to be delivered in phases alongside development rather than at the end of the development, with enforceable mechanisms and penalties for non‑compliance.

Early phases of new developments frequently rely on existing, already strained infrastructure. Without firm commitments, new and existing communities risk facing significant deficits in transport capacity, education, health services, green space, and utilities. Experience shows that developers often cite viability issues to reduce agreed S106/CIL contributions; this Policy needs clear safeguards against that outcome.

Given the lack of detailed evidence or confirmed commitment from infrastructure providers to delivery this Local Plan, we cannot support the Local Plan’s approach to infrastructure.

Traffic Impact

The Plan does not assess the substantial traffic implications of development along the key transport corridors (A40, A48, A417, A4136). The assumption of 1.4 cars per household is unrealistic, especially where new developments are likely to consist of larger family homes, typically accommodating multiple vehicles.

There is no clear alignment with the Gloucestershire Local Transport Plan 2020–2041, which was based on an assumed growth of 6,600 homes by 2041—far lower than the level now proposed. While a transport hub is mentioned near the A40/A48 junction, most new developments would sit upstream of this point, meaning congestion would worsen significantly.

Paragraph 2.22 states the intention to place housing and employment close together but provides no clear strategy for achieving this. Without coordinated planning, dispersed development patterns will force residents to rely heavily on private cars, further increasing congestion and emissions. This contradicts the Council’s commitment to become carbon neutral by 2030.

There is also no detailed strategy for public transport improvements, cycling infrastructure, or sustainable travel options, despite the implications for carbon emissions. NPPF paragraph 109 requires transport issues to be considered from the earliest planning stages, understanding the potential impacts of development on transport networks and the environmental impacts of traffic and transport infrastructure. This has not been adequately addressed. We cannot support a Plan that does not fully assess and mitigate transport impacts.

Brownfield Sites and Empty Properties

The Plan contains limited policy direction on brownfield redevelopment and none on bringing empty homes back into use. It does not propose measures to encourage developers to prioritise existing sites or seek funding support. This undermines long‑standing local and national policy objectives and continues to favour greenfield expansion over more sustainable alternatives.