Site Allocations Plan March 2016

Document Section Site Allocations Plan March 2016 Schedule 1: Proposed large sites for residential development over 10 dwellings (Sites marked with a * are mixed use sites). Nailsea Land at North West Nailsea [View all comments on this section]
Comment ID 14823809//8
Respondent Nailsea Action Group [View all comments by this respondent]
Response Date 27 Apr 2016
Comment

Land at North West Nailsea (Residential)

Summary

There are many reasons why this land should not be developed: encroachment of the flood plain due to global warming, difficulties draining the developed site, intrusion into distant views, potential damage to the adjacent SSSI, damage to otter habitat, loss of visual amenity from the Pound Lane footpath, lighting disruption of bat routes to their forraging grounds. It's noticable that no developer suggested developing the football field and the part of the site to the north east of it. Two previous planning applications that were not refused but did not proceed. Perhaps the developers have noted that and looked at the issues and concluded that the site is not developable.

The most serious practical issue is the predicted increases in flood plain level attributable to climate change. Based on Government recomendations, the rise is predicted to inundate the north east end of the land. All of the land is prone to significant surface water flooding and the increased flood plain level makes it unlikely that a cost effective drainage scheme can be found.

The site should be deleted from the plan.

Protection of the Pound Lane Visual Amenity

The proposed development would destroy the visual amenity of the view from the public footpath at the bend in Pound Lane, Nailsea (ST466713), which is illustrated in figures 1 and 2. The public footpath provides views over Tickenham church and of Tickenham ridge to Clevedon. Members of the public walking on the footpath are often seen to stop to admire the view and cars are seen to stop in the gateway on to other side of the road for the same reason.

see attachment 

Figure 1 - North west to Cadbury Camp on Tickenham Ridge

This view from the footpath will be improved when the proposed work on the pylons is completed. One of the existing lines of pylons is to be removed and the other is to be undergrounded. From the footpath, National Grid’s proposed line of 'T' pylons will be less intrusive than the existing pylons because, although larger, they are much more distant.

The visual amenity value of this viewing point was recognised by the Woodspring Green Belt Inquiry Inspector in his inquiry report. It would be unfortunate if, having been improved by changes to the power lines, this visual amenity was lost.

 

Figure 2 - West to Tickenham church and Tickenham Ridge

Protection of Distant Visual Amenity

In the consultation document sustainability Appraisal Appendix 1 spreadsheet the “Result of the Assessment” for HE14368 (Land north of West End Nailsea) is “No - nature conservation constraints and landscape impact”. Emails that followed Nailsea Action Group's Freedom of Information request revealed that the landscape impact was the view from the north. We are concerned that this consideration was applied inconsistently to the sites assessed, particularly the land at North West Nailsea, because development of the NW Nailsea site would be far more prominent in the landscape. It is very open to views from Tickenham Ridge as can be seen from figures 1 and 2 above and it is more than six times bigger than HE14368.

Future Flood Risk

Residents report that while walking on footpaths between Nailsea and Tickenham over many years there has been an increase in plants associated with marshy ground, indicating that the water table is rising.

Maps showing the increases in the flood risk areas in North Somerset, published in 2009, can be accessed from http://94.175.229.157/Environment/Planning_policy_and-research/localplanning/Pages/Strategic-flood-risk-assessment-FAQs.aspx

Map ST47SE (existing and future) shows current fluvial flood zones, mainly flood zone 3b, abutting the entire length of the western edge of the land at NW Nailsea. The map show encroachments into the site of “Climate change additional extents” along the length of its north western edge. North east of the playing field the encroachment covers most of the width of the land proposed for residential development.

The sustainability main report paragraph 4.8 says that flood zone 3b sites were sifted out at the first stage of the site selection procedure. This is as required by the NPPF and its guidance. The land at NW Nailsea has been included in the assessment because it was in a previous adopted local plan. However, planning guidance has changed since that local plan but the site appears not to have been adequately reviewed in the light of the new guidance.

Uncertainty surrounds the prediction of the effects of climate change. Since publication of the NPPF technical guidance on flooding significant amounts of research indicate that global warming is proceeding more quickly. The recent floods on the Somerset levels were unusually prolonged. Unusual, repeated recent flooding in some northern towns, possibly associated with climate change, caused substantial infrastructure damage in response to which the prime minister said that we need to work harder to prevent building on flood plains. All this raises the possibility that the peak rainfall intensities and peak river flows recommended in the NPPF technical guidance may need revision upwards. Would it be better to be safe or sorry?

The “Existing and Future” flood risk maps are already out of date. By the time the pylons have been removed they will be more out of date. The closer to 2026 that an application is submitted the greater will be the encroachment that a 100 year future flood risk assessment will indicate.

Drainage

The football field is much used by dog walkers who report that, for many winter weeks, the pitch is unplayable due to retained surface water. Along the lower edge of the field between the pitch railings and the edge of banks above the stream there is a path and between November and March/April it is ankle deep in water after every extended rainfall for quite a few weeks and after continual rain always flooded and becomes a bog, which is surprising as normally water will try to find its lowest level and drain away but the water just sits there. Matches often have to be rearranged because there is too much surface water.

The large field behind Causeway View is also used by dog walkers when it is passable on foot. The bottom full length of the field is often impassable on foot due to surface water, which can spread up into the field as far as the large oak trees in the middle of the field making walking impossible for most people.

Residents who overlook the field with the pylon next to the Heath Farm farmyard report that for many weeks during the winter surface water just sits there, just does not drain away.

Over the years the land at NW Nailsea has been the subject of several planning applications and local planning consultations on designation of the land for development. During all of the local campaigns against development of the land, residents have consistently reported significant surface water flooding.

This flooding would require a developer to propose a significant drainage scheme but the drainage scheme options are restricted by level of the future flood risk zone.

  • a) A balancing pond would need a high water level below the level of the lowest house and low water level above the flood plain. Where there is only a small difference between high water level and low water level, the capacity of a pond could be increased by increasing its surface area. We believe that the future flood plain level at NW Nailsea will become is too high for a reasonably sized balancing pond to be accommodated.
  • b) We believe that the future flood plain level at NW Nailsea will also become too high for a sustainable urban drainage systems (SUDS) to be effective.
  • c) A sump with a pumping station could be used but that would attract ongoing running and maintenance costs, which would be a financial burden on the public purse and Nailsea's residents.

Flora and Fauna

In addition to Parish Brook being part of the Tickenham, Nailsea and Kenn Moors SSSI, Otters have started making use of Parish Brook and greater horseshoe bats use the hedges along the Causeway as transit routes to their forraging grounds. Consequently, in Schedule 1's Site Details columns we ask that developers are required to prevent site run-off into Parish Brook that would be detrimental to flora and fauna and to prevent light pollution that would adversely effect bat transit routes.

Inconsistent Site Assessment

In the consultation Sustainability Assessment Appendix 1 spreadsheet, the “Result of the Assessment” for HE14368 (Land north of West End Nailsea) is “No - nature conservation constraints and landscape impact”.

After Nailsea Action Group's Freedom of Information request the follow up emails revealed the conservation constraint to be the SSSI adjacent to the site. We are concerned that this consideration was applied inconsistently to the sites assessed, particularly to the land at North West Nailsea, which is adjacent to the same SSSI for a much greater length than HE14368.

Parish Brook

Parish Brook forms part of the boundary of the site. It is part of the Tickenham, Nailsea and Kenn Moors SSSI.

The Natural England web site already shows the condition of the SSSI next to the Causeway as unfavourable, mainly due to the very poor water quality in the rhyne alongside the road, which is likely to adversely affect much of the rest of the site.

Otters

Otters have started using Parish Brook since it was designated as an SSSI in 1995 but Natural England have not yet added them to the “Description and Reasons for Notification” for the site. Records at the Bristol Region Envirnmental Records Centre (BRERC) show otters using the parts of Parish Brook that would be further degraded by vehicle and other polluting run-off from residential development at the land at NW Nailsea.

Bats

The survey of radio tagged bats identified the hedges along the Causeway as bat transit routes to their forraging grounds (Billington (2002) Radio tracking study of greater horseshoe bats at Brockley Hall Stables SSSI, May-August 2001 No 442).

Subsequent work at Bristol University has shown that new lighting disrupts bat transit routes and reduces the resillience of bat communities.

Insurance

If residential development proceeds on any part of this site there is the prospect, within the lifetime of the houses, that proximity to the flood plane will increase insurance premiums and make house owners subject to losses due to reduced saleability of thir properties.

Requested Changes to the Plan

We ask for the following:

a) The site should be deleted from the plan because:

  • surface water and increased future fluvial flood zone level conspire to make the land at North West Nailsea unsuitable for development.
  • Impact on Bats, otters and the Barish Brook SSSI
  • Damage to local and distant visual amenity

b) If these adverse criteria are considered insufficient to delete all of the site from the plan then the boundaries of the land for residential development at NW Nailsea should be redrawn clear of the zone 3b:

  • The playing field and the land north east of it should be removed completely
  • The remaining north west edge should be revised well clear of the future flood risk encroachments and with a corridor suitable to prevent damage to the flora and Fauna of Parish Brook.

c) If any part of the site is retained then schedule 1 site specific details for the site should be amended as follows:

  • to reduce of the number of homes to reflect the reduced area
  • The addition of text calling for a full 100 year future flood risk appraisal
  • Full appraisal of likely impacts on bats, otters and the SSSI audited by an independant authority
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