Site Allocations Plan - Main Modifications Consultation

Document Section Site Allocations Plan - Main Modifications Consultation MM26 [View all comments on this section]
Comment ID 1190177//1
Respondent Churchill Parish Council [View all comments by this respondent]
Response Date 19 Oct 2017


Churchill Parish Council note that this site has now been included in the draft modification to the plan.

Churchill Parish Council does NOT SUPPORT such an inclusion. The council holds the view that the site should be withdrawn from the plan, and we have recently made a lengthy and well evidenced submission as a statutory consultee on an outline planning application for that site. The reasoning for excluding it from the plan includes:-


Any development of the site would be an unsustainable development outside the settlement boundary of a designated Service Village on prime agricultural land in a sensitive rural location. The development is an incongruous encroachment on the countryside, harmful to the landscape immediately adjacent to the Mendip Hills Area of Outstanding Natural Beauty and is not in keeping with the character of the settlement. Of equally serious concern is the major flooding risk it poses to the A38 and to neighbouring properties and the serious congestion and traffic issues raised by the proposed access on to the extremely busy A38. Irrespective of pressure on North Somerset Council to meet short term housing targets, the adverse impacts of this proposed development significantly & demonstrably outweigh the benefits of new housing and the site should be excluded from the plan.


The proposal is in conflict with Core Strategy Policy CS32 relating to Service Villages as a site of over 25 houses (outside but adjacent to the settlement boundary of the village). The proposal is also in conflict with planning policies within the Core Strategy and Policy and the North Somerset Local Plan which aim to minimise the dispersal of dwellings outside existing settlements in order to protect the character of the countryside and to reduce the need to travel. As a substantial site immediately adjacent to an AONB, it is also starkly in conflict with Paragraph 109 of the National Policy Framework which states that the planning system should contribute to and enhance the natural and local environment by protecting and enhancing valued landscapes.

CS20 supports an employment led economy seeking to increase sustainability by "decreasing out-commuting, provide for a large range of local jobs and reduce carbon emissions from unsustainable car use." Developing this site would result in a dormitory development for commuters which will achieve exactly the opposite.


Churchill, by the assessment of NSC itself, has been assessed to be the least sustainable of the 9 Service Villages with the exception of Wrington. The NPPF (para 7) sets out the three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles:

“An economic role –

contributing to building a strong, responsive and competitive economy, by ensuring that sufficient land of the right type is available in the right places and at the right time to support growth and innovation; and by identifying and coordinating development requirements, including the provision of infrastructure;

A social role –

supporting strong, vibrant and healthy communities, by providing the supply of housing required to meet the needs of present and future generations; and by creating a high quality built environment, with accessible local services that reflect the community's needs and support its health, social and cultural well-being; and

An environmental role – contributing to protecting and enhancing our natural, built

contributing to and protecting and enhancing our natural, built and historic environment; and, as part of this, helping to improve biodiversity, use natural resources prudently, minimise waste and pollution, and mitigate and adapt to climate change including moving to a low carbon economy.”

The NPPF (para 8) states that:

"to achieve sustainable development, economic, social and environmental gains should be sought jointly and simultaneously through the planning system. The planning system should play an active role in guiding development to sustainable solutions.”

Any proposed development of this site fails to meet any of these criteria for sustainability:

Economic -

CS20 supports an employment led economy seeking to increase sustainability by "decreasing out-commuting, provide for a large range of local jobs and reduce carbon emissions from unsustainable car use." Development of this site would become a dormitory development for commuters which will achieve exactly the opposite.

Social -

The local primary school is already at capacity and is unfortunately on the other side of one of the busiest arterial roads of the south west but with no prospect of places being available for the new families. (See Schooling below). There are very limited social amenity infrastructure provisions within the village.

The site is in very poorly positioned indeed. It is on the wrong side of the A38 in a self-isolating location which does not add at all to social cohesion and integration with the existing village. The creation of a substantial block of housing within what is exclusively strip development on that side of the A38 will be an incongruous oddity with 2 of its boundaries formed by the extremely busy A roads.

Environmental -

This development does not enhance the natural, built and historic environment. Please see Landscape and Transport and sections below.


Development of the site would fail to protect and enhance the character, diversity and quality of the landscape. It would conflict with CS policies CS5 (landscape and historic environment), CS32 (Service Villages), the provisions of DMP policy DM10 (landscape), DM11 Mendip Hills Area of Outstanding Natural Beauty) and would be contrary to paragraph 109 of the Framework.

Moreover, significant weight should be given to the Mendip Hills AONB Management Plan 2014-2019 (MP), to the National Character Area (NCA) profile for the Mendip Hills (NCA 141) and the North Somerset Landscape Character Assessment Supplementary Planning Document (SPD).

Detailed consideration should be given to the Appeal decision APP/00121/W/153138816 of Neil Pope, Planning Inspector, in respect of a proposed development of land south of Knightcott Road. The Inspector concluded that considerable weight can be given to the landscape issues and found it to be a major ground for rejection of the appeal. That development site ("the Knightcott site") was similarly adjacent to the AONB and the parallels with this site are extensive. It is difficult to see why a Planning Inspector would not reject this application on very similar grounds to those set out in Mr Pope’s conclusions, with much the same reasoning and much the same weight.

It is strongly arguable that the proximity of the Roman Hill Fort on Dolebury Warren makes this an even more sensitive site than the Knightcott site in respect of landscape and history. AONBs are, unlike National Parks, rather small areas and so much of their highly valued scenic quality derives from regions near their boundaries; consequently views outwards and inwards may assume great importance for the scenic integrity of the AONB itself.

This is certainly the case at Dolebury Warren. Here the prospect north from the extensive east-west ridge contains, in the middle ground view, the settlement patterns of Churchill and Langford village as a substantial part.

A notable feature of this settlement is the way it is broken up into small and varied built components, each separated from the others by trees, hedges and open fields. The proposed insertion, into this pattern, of a substantial block of uniform development would serve visually to join the built components together and to confer an urban appearance on an otherwise rural scene. This is indeed one reason why village settlement boundaries have become an important part of Local Authority planning policy. This visual transformation would be apparent within the AONB, not only along the Dolebury ridge but on Lyncombe Hill to the west and on Burrington Ham to the east.

However, this is not a case of just visual impact but of the very proximity of a large residential development to a sensitive AONB which contravenes a plethora of policies referred to above and designed to protect such locations.


The NPPF (par 112) states that "Local planning authorities should take into account the economic benefits of the best and most versatile agricultural land.

Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of higher quality.”

The site is on best and most versatile land Taking account of other proposed developments at Pudding Pie Lane and in Sandford, Winscombe, Banwell and Congresbury, there is the potential loss of very significant areas of best and most versatile land in what is a small radius area.


(i) Location

The site is narrow & tapers between natural frontage of A38 Bristol Rd &A368 Bath Road. These principal roads create the western site boundary & form part of the traffic light controlled, 4 way, Churchill crossroads.

Together with an adjacent upland area of Mendip AONB, these principal roads & their junction dominate the site.

No accommodation is made re pending JSP & JTS. The site should not be included in the plan thereby avoid prejudicing these ongoing West of England policies.


(ii) Access


Vehicular access from the A38 Bristol Road would cause difficulty for school & medical centre traffic as well as other users approaching or leaving the acute Ladymead Lane junction.

Movement risks in this area will be increased by the A38 bus stop.

The statutory requirement for turning visibility East of the proposed access is questioned, particularly with the increased number of pedestrians that will be encouraged to use the proposed crossing point & footway.

Existing evidence of westbound A38 queue lengths on the approach to the traffic lights demonstrates that the PAR requirements cannot be met. At peak flows on a daily basis A38 westbound is jammed past the proposed development access. This is exacerbated on Thursday & Friday late afternoons over several hours while the increasingly frequent restrictions on M5 add to this problem at any time of a 24 hour/7 day week.

Parish council concerns regarding this in no way remove support from our view that the PAR correctly embargoes access from A368


(i) Surface Water Drainage

The ground is of low permeability. Of the 3 infiltration tests recently commissioned by an applicant developer only one is completed and this gives questionable infiltration results.

If ever developed as a site the council asserts that it will lead to major increases in flooding in and around the new development.

(ii) Foul Water Drainage

Wessex Water is having to undertake previously unforeseen work to accommodate recent development approved in Churchill Parish. These works may increase the flood risk adjacent to Langford Brook.

If developed, this site will add to the need for even more FW drainage improvement & a raised urgency for North Somerset Council to address even more flooding in Lower Langford.

(iii) General Comments:-

North Somerset Local Flood Risk Management Strategy Feb 2014 identifies the top 15 communities in North Somerset which are considered to be most vulnerable to flooding from surface runoff, ordinary watercourses and groundwater. It identified the measures proposed to be taken in these communities to reduce flood risk, subject to sufficient funding and resource availability.

The top 15 communities in North Somerset considered being most vulnerable to flooding from surface runoff, ordinary watercourses and groundwater are:

Backwell, Long Ashton, Churchill, Nailsea, Claverham, Pill, Clevedon, (East) Portbury, Congresbury, WInscombe, Hutton, Wrington, Langford, Weston-Super-Mare


The village is very poorly served in terms of public transport with 1 indirect bus per hour to Bristol, and no local cycle routes. There are no taxi businesses based in Churchill or Langford. Cycle rides to Yatton station would include the highly dangerous nature of the B3133 particularly with regard to pinch points on Stock Lane where HGVs regularly are  obliged to cross the centre of the road. This is not in any way a safe cycle route. No local employment will be attracted or generated by development of this site which will be of a dormitory nature and all residents will rely heavily on private cars and commute to work.

Accordingly, any development of this site would lead to further undesirable and unsustainable out commuting to work and is contrary to local policies (CS20) and NPPF criteria.


Considerable additional primary school numbers would be generated by any proposed development of the site. This, when taken together with the 3 substantial and recently approved developments in the village at Pudding Pie Lane and Says Lane would lead to unsustainable and non workable schooling provision.

Churchill Primary School is the only school within 2 miles of this site. It cannot be expanded on its current site to accommodate such an increase in its pupil numbers.

We understand that there are no plans or funds for new primary schools in the area. The one site that might allow potential expansion opposite and across Pudding Pie Lane is one of the 3 approved housing sites. Therefore the proposal to include this site is unsustainable on grounds that there will be no adequate schooling provision at primary level. Any 'per pupil' financial contribution from the developers would be irrelevant. In addition any solution proffered of providing school transport to mitigate a lack of school places is of no value in light of the influx of development across a so many villages all of which have no capacity to cope with the scale of pupils these combined speculative developments will bring.

In respect of secondary school places at Churchill School, there is no safe route to school from the site.


Between 2005 and 2008, the Parish produced a very comprehensive Parish Plan following an extensive review of various aspects of the village and full consultation with the all the householders. In respect of Housing and Development, overwhelmingly residents who expressed a view (89% of 1109) felt it was either vital or very important to preserve the character of the villages of Churchill and Langford. 33% were against any further development and 50% were in favour of some new housing but for local people or those in vital services. Whilst this document doesn’t have the legal standing of the Neighbourhood Plan the Parish has begun the process of producing, it still has relevance today as the village has changed very little since it was completed in 2008.

At a recent public meeting on 17th May 2017, attended by over 300 residents, considerable concern was expressed about the 3 approved applications and the proposal in the Joint Spatial Plan for a Garden Village nearby. These 4 developments and the JSP proposals amount to the rapid, un-cohesive and chaotic urbanisation of the villages of Churchill and Langford.


The village is facing a tsunami of speculative planning applications on greenfield sites outside the settlement boundary, 3 now approved and others in the application stage. There is the prospect of well over 250 new houses in a village of 880 dwellings and an increase in population of circa 1,100 to a current population of 2,200 (2011 census). This represents a 50% increase in population with no social, environmental and economic benefit whatsoever, and more importantly, no infrastructure improvement provision in the immediate future.

Neighbouring villages of Winscombe, Sandford, Congresbury, Banwell, Yatton and Claverham also face significant developments.


This Parish Council asserts that the Site Allocations Plan needs to recognise all the above factors that evidence and demonstrate that the inclusion of this site in the submitted modification to the Plan is not justifiable or acceptable.