Draft Gloucester City Plan 2016 - 2031

Draft Gloucester City Plan

F: Natural Environment

F: Natural Environment

Policies in this section:

  • Policy F1: Landscape
  • Policy F2: Biodiversity
  • Policy F3: Nature Improvement Areas
  • Policy F4: Trees & Hedgerow
  • Policy F5: Green Infrastructure
  • Policy F6: Geodiversity
  • Policy F7: Flooding

Key issues:

As a focus for growth across the County, Gloucester will need to balance development with the requirement to protect worthy landscapes from inappropriate development and maintain and enhance biodiversity.

When looking at the current state of landscape, the City has a tightly drawn urban form surrounded by countryside. The green belt to the North, the AONB to the East and the Severn Floodplain to the West has ensured a sharp urban rural interface. Given the City will need to grow there is an expectation that some of these urban fringe sites will be developed. Also, within the City there are areas of valued landscape that may need to be protected, however, the reality is that they are predominantly in public or benign ownership and do not face the sort of development pressures seen on the periphery.

Concerning biodiversity and geodiveristy, as is the case with many other urban authorities Gloucester is surprisingly diverse with its mosaic of gardens, allotments, railway lines and parks providing a rich diverse habitat. Biodiversity loss in this environment can be piecemeal and potentially on an individual basis can go unnoticed, while development if done properly can be biodiversity positive.  With this in mind, it is important the City Council is aware of gains and losses from planning applications. Many of the City’s recognised biodiversity assets are in City Council ownership, however, there are sites within private ownership and because of their urban nature suffer from development pressure. With regard to Geodiversity ‘Natural’ Regionally Important Geological Sites (RIGS) in Gloucester are owned by the City and should not be threatened from inappropriate development. Those not in a natural outcrop will be part of the built fabric, if they cannot be saved in situ then they can be moved.

The Severn and its Washlands Nature Improvement Area (NIA) is identified to the west of the City, any development will be severely constrained here due to its floodplain nature. Notwithstanding this, any essential development within this area will need to support the wider benefits of the NIA. Development in the City looking to mitigate its ecological impact could do so in this area.

With regard to Green Infrastructure (GI) the County has a strong Local Nature Partnership with a commitment to deliver GI benefits across the County. The GI strategy for the JCS identifies a number of issues for Gloucester, of most relevance is the need to connect the urban area with its rural hinterland, in particular the Regional assets of the Cotswold AONB to the east and the River Severn and its Washlands to the west, identified in the JCS as a potential regional park. Development will need to take opportunities to maximise connectivity through innovative use of open space, existing natural features and SUDs. Reducing the impact of pinch points and barriers to biodiversity movement will be a priority. The City owns and manages an excellent network of existing semi natural open spaces on its periphery, connectivity to this will be key.

GWT are working on a GI benchmarking tool, its aim to encourage quality of GI within new development, the City Council will work with GWT developers and other stakeholders to promote this tool as a means of raising quality.

Climate Change

The Gloucester Climate Change Strategy 2010 identifies that even the lower emission (best case) scenarios will result in the following climate changes for the local region:

  • Winters up to 42% wetter.
  • More frequent flooding.
  • More frequent droughts.
  • Worsening summer air pollution.
  • More storms and gales and the resulting damage to property.
  • Loss of wildlife habitats and species.
  • Social unrest through increased migration.
  • Higher average temperatures will create a greater need for cooling in offices and homes along with a higher probability of extreme temperatures that could threaten the health of many people.
  • Drier summers, that will put a greater strain on water resources and wildlife and put pressure on farmers to diversify crops.
  • Rising sea levels that will lead to more coastal erosion and a greater risk of flooding.
  • Increased heat stress to the elderly and infirm (the 2003 heat wave in France killed 14,500 people). The weather conditions causing such events will become very frequent.

The high emissions scenario (essentially business as usual) is even more stark, predicting that by 2080 a maximum increase in temperature of 6.9 degrees C. This would leave much of North Africa and Southern Europe uninhabitable.

Gloucester will clearly need to ‘do its bit’ and help deliver what are challenging international targets. While new development over the plan period will only be a small fraction of the built environment it is important to get it right. Low carbon techniques used on new build will also help reduce the cost of retrofitting the existing building stock as new technologies become mature and more cost effective.

While an urban area such as Gloucester may not be as well endowed with renewable energy potential as some more rural districts, there are always opportunities as has been shown in Gloucester and other urban areas with regard heat pumps, solar and low head hydro. The close proximity of the Canal/River too many development sites in particular has the potential to provide heating and cooling for new build and retrofit. While biomass has potential, being predominantly on the gas grid currently means this may be a niche market. Hempsted land fill and Netheridge sewage works currently produce methane for electricity generation. Exploiting this energy to the full including exploiting waste heat should be maximised.

Resilience to weather extremes, especially the heat island will be a key issue. Gloucester will need to maintain and enhance its tree stock and generally encourage a greener urban fabric with everything from green roofs to public open space. This will also have positive implications for biodiversity.

In 2010 Gloucestershire County Council published a Renewable Energy Study for the County. This was for the purpose of providing an evidence base to help develop Local Plan Policy for renewable energy infrastructure provision on potential strategy development sites in Gloucestershire to help contribute to a reduction in CO2 emissions in line with Climate Change Targets.

Background topic papers on Natural Environment, Flooding, and Climate Change can be found on the council’s website by visiting www.gloucester.gov.uk/cityplan

Key evidence:

  • Strategic Flood Risk Assessment Level 1, Halcrow on behalf of JCS Authorities, December 2007
  • Strategic Flood Risk Assessment Level 2, Halcrow on behalf of JCS Authorities, October 2011
  • Strategic Flood Risk Assessment Level 2 – Additional Assessment, Capita Symonds on behalf of JCS Authorities, January 2013
  • Pitt Review (2008)
  • Sustainable Drainage a Design and Adoption Guide, Gloucester City Council, July 2013
  • Gloucestershire SuDS Design & Maintenance Guide, Gloucestershire County Council, November 2015
  • Briefing Note - Reducing flood risk from the River Severn in Gloucester and the surrounding area – Initial Assessment, Environment Agency,  March 2016
  • Regional Spatial Strategy South West evidence base
  • Revision 2020, Centre for Sustainable Energy, 2005
  • Merton Council, Merton Rule 2015.
  • Renewable Energy Study – Final Report, Gloucestershire County Council, June 2010
  • Gloucester City Climate Change Strategy, Gloucester City Council, 2010

Other relevant strategies:

  • United Nations Climate Change Conference 2015

Relevant National Planning Policy Framework paragraphs:

  • 100, 101-109, 113, 117 and 118

Relevant policies from the JCS:

  • Policy SD4 Climate Change
  • Policy SD7 Landscape
  • Policy SD10 Biodiversity/Geodiversity
  • Policy INF4 Green Infrastructure
  • Policy INF3 Flood Risk Management

JCS strategic objectives met:

  • Strategic Objective 4: Conserving and enhancing the environment
  • Strategic Objective 6: Meeting the challenges of climate change
  • Strategic Objective 7: Promoting sustainable transport
  • Strategic Objective 9: Promoting healthy communities

Key City Plan principles met:

9, 13 and 14

Natural environment policies

The natural environment is a precious resource. Not only do natural places provide a refuge from our daily stresses they provide what are increasingly called ecosystem services. Essentially these are functions that green semi-natural spaces provide such as flood management, extreme weather mitigation and other well-being benefits that are rarely costed but are none-the-less essential to modern living. As well as these functional benefits we have of course a moral duty to ensure that species do not further decline. We are currently experiencing a collapse in biodiversity not seen since the mega extinctions of earlier geological epochs. Development has its role to ensure that this is not only halted but reversed.

Gloucester is a diverse City that benefits from a high quality natural environment which it will seek to protect and enhance where possible. Within the City there are:

  • Sites of Special Scientific Interest
  • Key Wildlife Sites
  • Regionally Important Geological sites
  • Sites of high sensitivity in landscape terms
  • Green network of formal and informal open spaces linked by green corridors such as disused railway lines and watercourses.
  • Ancient trees and hedgerows

A landscape characterisation and sensitivity analysis has been undertaken on the periphery of Gloucester as part of the JCS evidence base. A number of sites vulnerable to large scale development within the city have also been subject to a Landscape Visual Analysis and indeed developable areas identified. Any application will be subject to JCS policy SD7 Landscape. Any sites within the city will also be subject to the following:


Policy F1: Landscape

Smaller areas of land within the urban area not subject to formal landscape characterisation/sensitivity analysis will be judged on their merits. For larger sites (10 dwellings and more 1,000 sq. m commercial floor space) a Landscape Visual Impact Assessment may be required where landscape issues are considered pertinent.

Development proposals on land outside the built up areas of the City will need to take account of the landscape character and sensitivity of the area. Applications for development may require a landscape and visual impact assessment to be prepared to inform development proposals.

Proposals within sites of higher sensitivity will be subjected to increased scrutiny and constraint and will generally be protected from development to ensure their landscape qualities are retained and safeguarded.

The open areas around and within the city are a precious resource that is enjoyed by residents and visitors on a daily basis. The planning system should ensure that this asset where appropriate is protected and if possible enhanced ensuring future generations can share the experience. All development can play a role in protecting and enhancing biodiversity and where appropriate the City Council will seek bird and bat box provision and other associated infrastructure as part of development and landscape proposals.

When assessing applications for development where biodiversity is potentially affected it will be judged against policy SD10 of the JCS in conjunction with local designated sites as identified on the proposals map. This is to ensure that small-scale development does not erode biodiversity on a piecemeal basis.

Policy F2: Biodiversity

Small scale piecemeal erosion of background biodiversity is to be resisted, applications for small scale development will be judged as a component of a wider system and applications will need to show how biodiversity interests will be taken account of and mitigated against.

As a focus for growth in the County, we need to ensure that new development takes place in appropriate locations in order to safeguard the City’s valued natural environment. For a number of reasons biodiversity has been in significant decline for a number of years and it is clear that Government expects development to play a role in protecting and where appropriate enhancing biodiversity.

Policy F3: Nature Improvement Area

Development within/adjacent to the Nature Improvement Area (NIA) as defined on the proposals map will not be subject to any further constraint over and above floodplain requirements , however, any biodiversity mitigation/compensation required will be expected to contribute to the overall NIA target species and habitats. Developers wishing to offset biodiversity loss elsewhere in the plan area can do so by contributing to NIA target species and habitats within the identified local NIA.

The Severn and is Washlands NIA lies to the west of the City and is focused on the floodplain of the river Severn. It is an important habitat of strategic value and could be the focus for biodiversity offsetting when proposals within the City cannot deliver biodiversity enhancements on site.

Policy F4: Trees & hedgerows

Development will be supported where:

  1. It does not have an adverse impact on trees, woodlands or hedgerows of wildlife, landscape, amenity, or cultural value; and
  2. It includes the appropriate retention and new planting of trees and woodland; and
  3. It does not have an adverse impact on ancient woodland or a veteran* tree; or
  4. In the case of an unavoidable adverse impact on trees and woodlands of wildlife, landscape, amenity, or cultural value, appropriate compensatory provision is made.

 * Please note: Veteran trees are defined as ‘trees that are of interest biologically, culturally or aesthetically because of their age, size or condition’.

Trees and hedgerows have cultural significance as well as biodiversity interest. Development proposals should seek to retain where possible these assets for the enjoyment of future generations.

Compensatory or mitigation planting depending on location will in general be required to be locally appropriate native species.

Tree preservation orders will be served where appropriate to protect trees for their amenity, cultural or biodiversity value. Trees and hedgerows are an important part of the City’s landscape. Not only do they give a sense of maturity and attractiveness to development, they are also an important wildlife resource. The City contains a small amount of Semi ancient woodland, this will be protected for its cultural, wildlife and amenity value.

Policy F5: Green Infrastructure

Development proposals will have regard to Gloucester City Councils Green Infrastructure Plan (GIP) as articulated in the JCS Green Infrastructure Strategy. Proposals that do not contribute to the connectivity of the GIP will not be permitted unless other aspects of the overall GIP are supported. Development adjacent to or within the identified Green Infrastructure asset will be expected to connect to and support the GIP in particular the target points identified.

The Green Infrastructure Plan (GIP) seeks to connect the urban areas of Gloucester with the high quality Green Infrastructure (GI) assets of the Cotswold’s AONB and the Washlands of the River Severn. Proposals will be supported that contribute to this objective.

Development generally will contribute to the broader network of GI corridors and assets across the City by the use of SUDS, open space, green roofs and tree planting.

GI and its associated corridors and links are a vital component of maintaining and enhancing wellbeing. It also has functions with regard to biodiversity, surface water management, climate change adaption and amenity value. Development has the potential to block corridors resulting in the isolation of habitats which is a particular concern in an urban area such as Gloucester. The rivers, brooks, disused railway corridors, footpaths, open spaces form important corridors linking communities within the City and habitats to the wider countryside. These vital corridors need to be protected and where possible enhanced for their biodiversity value and as pedestrian/cycle routes through the city. GWT are developing a GI benchmarking tool, the City Council will work with developers and other stakeholders as a means of raising the standard of GI across the City.

Policy F6: Geodiversity

Any proposal that impacts upon RIGS will be re-sited unless it can shown that the geological interest can remain in situ and be made available to the public potentially this could involve removal to another site. In exceptional circumstances where the permanent loss of a RIG is unavoidable then and relocation is not possible then a full geological assessment will be required and the information deposited on an appropriate records site.

The stock of geological exposure is limited and critical (once lost it cannot be recreated) and for scientific and educational reasons needs to be maintained.


The JCS, NPPF & NPPG cover most policy concerns for Gloucester and all development will be expected to be in accordance with these policy statements.  Furthermore on all planning applications involving surface water discharge, development will be expected to be in accordance with the latest version of Gloucestershire County Council’s SuDS Design and Maintenance Guide.

Given the unique position of Gloucester at the interface of tidal and fluvial events in the Severn, any development within the Severn Floodplain will be expected to increase flood flow across this area.

The Environment Agency Briefing Note “Reducing flood risk from the River Severn in Gloucester and the surrounding area – Initial Assessment” March 2016, seeks to protect properties predominantly within Westgate Ward by increasing flood defences along the Eastern Parting of the Severn. Development that contributes to the delivery of the Environment Agency plans outlined in the Briefing Note, and any subsequent amendments, will generally be supported.

Policy F7: Flooding

All development should not be subject to flood or lead to increased flooding elsewhere. Drainage schemes should broadly be in accordance with the Local Lead Flood Authority Gloucestershire SuDs Design and Maintenance Guide and Gloucester City Council Sustainable Drainage Design and Adoption Guide, and any subsequent amendments.

Large Scale Development should deal with its own water and provide betterment of 20% on the calculated greenfield run off rate.

Large scale development within flood zone 2 and 3 in Lower Westgate will be expected to contribute to new flood defences along the eastern parting of the River Severn.

The effective management of water is important in the development of sustainable communities. It reduces the impact flooding may have on the community, maintains the quality and quantity of our water environment, and can help to enhance local amenity value and biodiversity through the provision of green space.

The Strategic Flood Risk Assessments (SFRAs) for the JCS area identify fluvial flood risks from the River Severn and local tributaries, in addition to increased problems from surface water runoff. Site specific flood risk assessments (FRAs) should be submitted alongside development proposals, consistent with national policy and JCS Policy INF4.Developers should use the SFRAs as a starting point for understanding the level of flood risk posed to a particular site. FRAs should be proportionate to the level of flood risk, scale, nature and location of the proposed development, as identified within the SFRAs.

The City Council seeks to avoid flood risk. It recognizes also that there is a need to reduce the impact of flooding when it does occur. Proposals should have specific regard to the design principles outlined in the SFRAs, including taking a sequential approach to site layout, ensuring safe access is available for the lifetime of the development and is supported by flood warning and suitable evacuation plans. Surface water runoff can contribute to flood risk and new development will be required to incorporate Sustainable Drainage Systems (SuDS) where appropriate to manage runoff and to ensure that flood risk is not increased elsewhere and to improve the quality of the receiving watercourse and groundwater.

All development, including any proposals relating to the existing building stock, should contribute to the management of surface water runoff through the use of SuDS. Consideration should be given to the appropriate application of SuDS, in relation to the scale of development and site characteristics. Proposals should recognize the multi-functional role of SuDS and demonstrate that provision has been made for their long term maintenance and management.

Climate Change

All applications for development will be assessed against SD4: Sustainable Design and Construction of the JCS.  In addition, to ensure the renewable energy potential of the river and canal are exploited and indeed not sterilised by inappropriate development the following policy will apply:

Policy F8: Potential of River and Canal

Development that exploits the renewable energy potential of the River and Canal will generally be supported. Any development that could potentially disrupt or indeed sterilise this potential will be resisted.

Policy F9: Efficiency measures

In exceptional cases major applications where no form of renewable/low carbon generation is practical or viable then the extra insulation and efficiency measures may be appropriate.

Policy F10: Mitigation through planting and SUDs

Development will be expected to help mitigate against the impacts of climate change. In this respect development that provides for trees, green roofs, green open space and Sustainable Urban Drainage Systems will be encouraged and supported.

Climate change is an issue that will impact upon us all. Gloucester needs to develop in a manner that minimizes the emission of green house gasses and in a manner that is resilient to the impacts of climate change. There are very tough international targets that need to be met. As climate change becomes more of an issue then it is likely that the pressure to do more will increase. The recent UN conference on climate change will only add impetus.

Policy SD4 of the JCS provides a strong policy position on these issues and applicants will need to demonstrate that they have met the requirements of the policy.

Buildings currently account for about a third of the UKs greenhouse gas emissions when coupled with transport between them then land use planning clearly has a significant role to play. Roofs on buildings are a vast un-exploited resource that in many cases be utilised for energy generation every effort should be exploited to ensure this resource is not wasted. Also as renewable technologies often require planning permission then the authority needs to be supportive where landscape and other constraints are not overly prohibitive.

With regard to resilience, flooding is perhaps the most obvious concern, however other impacts of climate change such as extreme temperatures should also be a factor. Trees and other greenery for example are shown to have a significant cooling effect on urban areas. Trees green walls and green roofs for example should be supported. Research from Manchester University for examples suggests that trees in urban areas can reduce summer heat levels by as much as 4 degrees centigrade.