Buckover Garden Village Joint Spatial Plan





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 Falfield Action Group is made up of a number of Falfield residents and other individuals who welcome
appropriate small scale development but who do not want to see in-appropriate and
unsustainable development that would destroy the character of the village.

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Falfield Village


Page last updated:Saturday, January 13, 2018



There is currently a very important public consultation taking place concerning the West of England Joint Spatial Plan, which includes the controversial Buckover Garden Village proposal. Full details can be found at www.jointplanningwofe.org.uk.

This is our final opportunity to comment via the consultation process before all submissions are forwarded to the Inspector appointed by the Secretary of State for consideration. This is key, as they will be reviewed independently, following which a Public Examination will take place. The inspector will then report back to the local authorities, which will include any proposed amendments, before the plan is adopted.

So, What Can You Do?

You can submit your comments independently – to find out how, please click here.

If are happy that Falfield Action Group’s submission represents your view – you can sign-up to be included in our group submission, which is detailed below. There are three ways you can sign-up:

1. Email us at falfieldactiongroup@gmail.com stating: ‘I agree that Falfield Action Group may represent my view in the JSP response’ and provide your Full Name and Postcode*.

2. Complete our simple questionnaire online by following this link

3. Call us on 01454 501921 and leave a voicemail confirming you agree that Falfield Action Group may represent your view in the JSP response and provide your Full Name and Telephone Number*.

Please encourage others in your household, friends and relatives to sign-up. We want as many people as possible to register their support.

Please respond by lunchtime on Wednesday 10th January, to ensure we have sufficient time to finalise and submit our response before the deadline.  

*Please note we will not share your email address or telephone number without your prior consent to do so (if required by the Inspector).

If you would prefer to submit an independent response, please feel free to re-use any of the comments we have made. Details of how to submit your comments and useful documents can be found here.

Falfield Action Group
Response to Joint Spatial Plan Consultation January 2018


Our View

Our Proposal

Basis of JSP

The locations of future development are being driven by landowners who have offered their land up for development, rather than being based on sound planning principles and decisions. This is not a sound basis upon which to shape our future.

Change the basis of where developments should take place and if land is not available, use Compulsory Purchase Rights to ensure residential and employment development is located on the most appropriate, rather than the most readily available land.

Housing Need Data

The housing need forecast was produced in 2015 and is now out of date and does not take into consideration the impact of Brexit.

The 2011 Census is stated to be a main source of data. There is mention of a review of the plan in 2023, but no committed timescales. The next Census is due to take place in 2021.

Under the NPPF, local authorities must use latest available information in their calculations.

The housing need should be revisited using the most recent forecasts available.


The JSP should include a committed timetable for reviews throughout the policy period, rather than just state they will be held every 5 years. This should include a review to coincide with publication of the Census results to ensure the strategy and housing numbers are ratified at the earliest opportunity.

The Allocation Between



Since 2006 South Gloucestershire has delivered 23.8% of new dwellings in the West of England, second only to Bristol’s 43.6%.

The JSP does not provide a breakdown of the number of dwellings each authority will deliver for each of the different categories of development. South Glos is to provide at least 6,000 across only 5 strategic development locations, each being 500 or more dwellings. This represents 34% of this category of development. The provision of strategic developments is unfairly distributed between authorities; there is no evidence that there is any correlation to future housing needs within each authority. No evidence has been presented that South Glos needs upwards of 6,000 new dwellings on top of those already taken into consideration in different development categories.  

Furthermore, of the contingency locations identified, 48% of the 3,080 dwellings are to be provided by South Gloucestershire. This is excessive. The burden of any of the local authorities’ inability to deliver should not be primarily borne by South Gloucestershire.

The area of the JSP expanded mid-way through the process beyond the Bristol Housing Market Area (HMA) to incorporate the Bath HMA (BANES Local Authority is partly in the Bristol HMA and partly in the Bath HMA). The housing requirement projected for the Bath HMA is 13,500 but there are almost no house build proposals – therefore the JSP attempts to satisfy the demand of the Bath HMA by building in the Bristol HMA. This should not be allowed.

The allocation of new dwellings between the different authorities needs to be revisited, with consideration made for each of the authorities’ future housing needs, with fully evidenced outcomes.  

The policy for contingency locations needs to be revisited, with consideration made for authorities taking responsibility for shortfalls in their region.

Although the city of Bath itself is constrained in terms of housing growth potential, there are other options within the Bath HMA inside B&NES that should be utilised in preference to “exporting” their housing need into the Bristol HMA. Failing that, the Bath HMA occupies only about half of B&NES and extends into W Wilts to the East and Mendip to the South.

This should remove the need for more than 10,000 houses in the Bristol HMA.

The Green Belt

48% of the West of England Area is Green Belt.  Bath & North-East Somerset is 70% Green Belt.  The Green Belt boundaries were defined predominantly between the 1950’s and 1980’s.

The strategy is flawed in that it ignores the availability of more sustainable sites in relation to employment and transport connections on the edge of

Bristol and around Bath which are within the Green Belt.

Calls for the Green Belt boundaries to be redefined during previous consultations have been disregarded

Without a revision of the Green Belt boundaries, greenfield areas will be lost, including those of high agricultural quality. The WoE authority have a duty to ensure greenfield sites do not suffer disproportionately because of boundaries which are upwards of 20 years old, which do not consider recent or future population and economic growth.  

There should be a thorough and robust review of the Green Belt.

There should be a testing strategy adopted to ensure proposed strategic sites are the most sustainably located in relation to employment and transport connections.

The Principle of



The strategic residential developments are located long distances from the strategic/main employment areas. This create a separation between where people work and where they live (satellite development), creating dormitory towns. It is not conducive with reducing the use of private motor vehicles.

The proposed transport solutions will not be able to accommodate the range or flexibility of routes required and will not satisfy the needs of commuters needing to travel beyond the boundaries of the local public transport routes. The inconvenience and lack of well-planned connections will result in commuters choosing to continue to travel by car. This is contrary to one of the key principles set of the JSP, namely to minimise the number of car journeys. Congestion and air pollution will be increased by taking this satellite approach.

There should be a comprehensive review of the residential and employment sites identified in parallel with the Green Belt review as detailed above, to ensure that housing locations are in the right places to enable them to be sustainable in transport and employment terms.

The reviews will highlight the fact that there are housing solutions available much closer to areas of employment growth, for example around the M4/M5 interchange. Although these sites are within Green Belt they are not areas of great environmental value, and can be developed without the detrimental environment impact or the sustainability issues.   

Alternative proposed strategic locations such as Woodlands Garden Village (adjacent to M4/M5 interchange) should be revisited and the merits of proposed locations analysed thoroughly with transparent outcomes being made available.

Transport and


There is no committed Joint Transport Plan in place at the time of JSP examination. This is a key flaw.

The vast majority of the technical reports for strategic locations cite strategic transport improvements as key risks with the lead times for implementation being delayed allowing them to be funded and programmed. South Gloucestershire is the only authority that has not made the provision of the transport infrastructure being in place before the developments start.

There is no commitment for infrastructure implementation schedules to be in place before the strategic locations are approved. Without this commitment, what is likely to ensue is development before infrastructure improvements, which will have a significant detrimental impact on communities. Infrastructure MUST to lead rather than follow development.  

Although the Government has devolved £900m to the combined authority, to assist in supporting priority infrastructure schemes, the tendency to overspend on infrastructure projects (including the Metrobus) is well documented. There are too many unknown costs documented.

Key risks are that costs are higher than the investment available and/or they escalate resulting in insufficient funding available to deliver the infrastructure for committed developments delivering later in the 18-year period.

The JSP and JTS should be delivered and approved in parallel due to the significant dependencies on the delivery of transport infrastructure. The delivery of these plans should include the estimated cost, timescales and clear funding approach to validate that the WoE has undergone due diligence and is proceeding with a sound strategy for how infrastructure will be funded and how any shortfalls will be met.

Infrastructure schemes should be prioritised in accordance with need, and providing the infrastructure for strategic locations is key.

For each strategic location the essential Transport and Infrastructure needs should be identified and tested to ensure there will be no significant strain on infrastructure of surrounding, pre-existing towns and villages at any stage of the development. The tests should include proving that the transport infrastructure changes will deliver a genuine transfer away from use of the private motor car.

The provision of the necessary infrastructure and transport either ahead or alongside the development should be made a precondition for granting approval of the strategic development sites.

Health Service Provision

The JSP fails to make any mention of the critical health service needs to service the growth, or even mention the requirements that NHS England would need to put in place. In doing it fails to fulfil its responsibility under the Town and Country Planning regulations (2012).

The Authority should be required to go back and evaluate the current capability of health provision against target standards by NHS England (including measures against key performance capacity standards such as patients per full-time equivalent GP) and set out what additional capacity is necessary to support the growth. It should then state how this is going to be achieved in terms of the Local Authority’s Duty to Cooperate with NHS England.

Specific to Thornbury

Thornbury has and continues to grow at a rate faster than its ability to manage in terms of infrastructure. This will continue if additional 500 dwellings go ahead.

No action has been taken to deal with the consequences of this influx on services such as GP capacity, on roads, public transport and parking capacity.

Two areas reserved for employment in the South Gloucestershire Core Strategy are now in the process of being developed to provide residential housing. The JSP proposes a new greenfield site for employment purposes which is in a high flood risk area, potentially nestled between new housing developments. The location of the employment area will increase congestion on stretches of road leading to the A38 that are already severely congested.

There should be no further major developments (over 10 dwellings) in Thornbury the next ten years in order to give the town the chance to absorb the numbers already approved or in progress.   


In the meantime, action is required to tackle the current infrastructure and transport problems, including a re-examination of the proposal to reopen a train station in Thornbury


The location of the area for employment development should be reconsidered.

Specific to Buckover

Buckover Garden Village is not village. It is a town and would be one of the largest in South Gloucestershire, but without the supporting infrastructure, employment and services to make it sustainable. It is high density housing with a mere 11 hectares of land set aside for employment which would offer limited employment opportunities for the thousands of working-age adults.

Buckover Garden Village would not be a discreet settlement. It would be an extension of Thornbury and was originally marketed as just that until Tortworth Estate and South Glos Planning Department decided to apply for inclusion in the Governments Garden Cities Towns and Villages Initiative, when it was suddenly renamed a 'new settlement’ to try and align to the Government’s criteria for a Garden Village, which it fails to do. It is not locally led development. It is opposed by Falfield Parish Council and Thornbury Town Council. The application to the Government Scheme and inclusion in the JSP was without consultation with either.  It is opposed by Luke Hall MP and twice failed in its attempt to get government backing.

The development is favoured by SGC as the land is offered by a single landowner which simplifies the process.  This is not a sound basis upon which to select the site for such a major development.

We have already seen ‘compromises’ to the original offering proposed by Tortworth Estate - the ‘new’ M5 junction has disappeared as has the re-routing of the A38, hence the ‘village’ will be dissected by this very busy A road, which is the relief road to the M5. Simply stating “a solution must be found for the A38” is unsatisfactory.

This location would be a mere 500m away from the outskirts of Thornbury. The proposed ‘buffer’ is inadequate; in reality a thin strip of land.  If Tortworth Estate wish to proceed with the Garden Village, the location should be reconsidered - they have a vast estate with scope to site the 'village' elsewhere and create a genuine new settlement, which would not impact the busy A38 or have a detrimental impact on Thornbury. The Buckover proposal would be far more sustainable if the location was changed to an area east of the M5 Junction 14, east of the M5 alongside the main railway line serving Bristol, Yate, Cam, Gloucester and Cheltenham where there are opportunities for new railway stations to serve the residents. This would be in harmony with the aspirations of the Joint Transport Plan which aims to reduce car usage and road congestion.

The site is within a few miles of the proposed new nuclear plant which will be delivered in a similar time frame, yet there is no mention if the significant population increase in Buckover would be permissible due to its proximity to the new nuclear site.

There is no commitment to provide healthcare facilities in the plan, the nearest Drs and dentists are in Thornbury. Southmead Hospital is 12 miles away nowhere in the document is as assessment for the need for more hospitals to accommodate the population increase.

The assessment acknowledges the lack of employment opportunities, but suggesting the strategic transport package will improve access to Thornbury for employment does not recognise that the employment opportunities in Thornbury have shrunk considerably in recent years.

One primary school and a 3-16 school will not suffice. Castle School is almost at capacity without the main influx of children from the developments already approved. There is no proposal for additional Sixth Form provision. With current proposals to close Castle School Sixth Form and move pupils to the main Castle site – where will the children of Buckover get an A Level education?

The loss of landscape which is of high and medium-to high quality sensitivity is totally disregarded, as is the loss of grade 2 (very good) agricultural land.

Remove Buckover Garden Village from the JSP.

Undertake a full review of housing demand, the Green Belt and sustainable locations. Following which, if a strategic location/Garden Village is needed in South Gloucestershire, consider and fully analyse the alternative ‘Tortworth Garden Village’ (proposed by local architects, but disregarded by Tortworth Estate and South Glos) and ‘Woodlands Garden Village’ to ensure that the most appropriate location is selected.  



JSP Website

There are lots of documents on the JSP website. The JSP Publication Document is somewhat high level – you’ll find a link to it at the end of the first sentence following the heading inviting you to make your representation.

The real detail for each proposed development site is contained in the technical and evidence based papers – the link to these documents is under the heading ‘Evidence Base’.

This does make for a lot of reading and you may find it easier to search for ‘Buckover’ in each document.  

TRAPP’D Website

Our friends at TRAPP’D (Thornbury Residents Against Poorly Planned Development) hosted a very informative presentation in November, the slides for which are available on their website: – just click on the link for TRAPPD Slide Presentations 2017.

The CPRE slides on the TRAPP’D website contain some very pertinent points about the proposed developments in Thornbury & Buckover and highlight some key sections in the combined document which focus on these sites.

TRAPP’D have also put together some prompts for residents who want to take part in the consultation process. These can be found here.


By making an online comment on The JSP Publication Document or uploading a response document – via links under ‘Respond to this Consultation’ heading on JSP consultation homepage.  

By Post to: West of England Joint Spatial Plan, C/o South Gloucestershire Council, Planning, PO Box 1954, Bristol. BS37 0DD.

By email to: comment@jointplanningwofe.org.uk

If you wish to refer to specific issues, you may find this easier by email/post than the online form/upload functionality.


Many Thanks as always for your continued support.