Site Allocations Plan - Main Modifications Consultation

Document Section Site Allocations Plan - Main Modifications Consultation MM24 [View all comments on this section]
Comment ID 17708609//1
Respondent Deleted User [View all comments by this respondent]
Response Date 26 Oct 2017


This note is an objection to the inclusion of the Broadleaze Farm Site on the Publication Version of the Site Allocation Plan put forward by North Somerset Council (NSC). The various points made in this objection also apply to the other sites mentioned in the attached schedule at Appendix 1.

The NSC Core Strategy makes repeated references to ‘sustainable development’ and ‘employment-led development. The proposed sites in the new allocation schedule clearly demonstrate that these two policy requirements will not be met.

Appendix 1 listing the sites allocated for residential development in the Service and Infill villages within a rough 3 mile radius of Broadleaze Way in Winscombe illustrates the unacceptable scale of the policy being pursued by North Somerset Council. This policy is demonstrably unsustainable in a number of areas.

Appendix 1 also shows the impact of the probable increases in population resulting from the development sites proposed in the new site allocations but, in summary:

  • Using an example of 2 adults plus 2.4 children per dwelling, that means a potential increase in the population of
  • Adults 1724
  • Children 8
  • Total 8
  • and 1724 vehicles
    • there is only one very small new employment site proposed in Wrington
    • It is not proposed to build any new Primary Schools or Secondary Schools
    • It is not proposed to build any new Medical facilities
    • there is no new road infrastructure proposed


From North Somerset’s own document “Reviewing the sustainability and settlement hierarchy of settlements in North Somerset” (Revised Report, July 2016) the percentages of residents’ methods of getting to work are as follows:

                                                                Driving                                  Description

Sandford                                                 74.1%                                    Relatively High

Churchill/Langford                                  73.4%                                    Relatively High

Banwell                                                   74.0%                                    Relatively High

Winscombe                                             70.4%                                    None given, but close to Relatively High

As a further example of a village more or less adjoined to Banwell

Locking                                                   78.5%                                    Relatively High

Attached (at Appendix 2) is a sheet showing the impact of the above percentages in daily use of motor vehicles as a means of travel to work of the first 4 villages combined with the level of proposed developments set out in the site allocations under consultation.

It would seem that North Somerset continually ignores Government Planning Practice Guidance Travel plans, transport assessments and statements in decision-taking in its decision making, which stipulates that account must be taken of in-combination transport impacts, giving:

 ‘appropriate consideration to the cumulative impacts arising from other committed development (i.e. development that is consented or allocated where there is a reasonable degree of certainty will proceed within the next three years) …. At the decision-taking stage this may require the developer to carry out an assessment of the impact of those adopted Local Plan allocations which have the potential to impact on the same sections of transport network as well as other relevant local sites benefitting from as yet unimplemented planning approval'


 In other words transport assessments for new developments must NOT be considered in isolation, as has happened with all previous applications in the local area.

According to the Planning Inspector (David Richards B Soc Sci DipTP MRTPI) who gave the decision not to award Costs to the Appellants (Strongvox ‘et al’) in their application in relation to Appeal Ref: APP/D0121/W/15/3139633 (decision dated 12 October 2016) -

“There are fundamental differences between the parties. The Appellants reliance on the concept of ‘opportunity’ highlights their erroneous approach.  It requires the application of common sense to understand that people do not use the public transport services available, and that the same pattern of car dependant travel is likely to apply if the appeal is allowed. This is the proper approach.”

The rating of services as “Amber – “ in the category of being ‘Well Connected’, is frankly ludicrous given the two comments below (again taken from NSC’s sustainability and settlement hierarchy review). In addition, the only direct destinations of the two bus services available (126 and A2) are limited to Weston-super-Mare, Wells and Bristol Airport.  There is no direct access to Bristol itself which is by far the main employment area for all the villages mentioned above.

  • “Closest rail station is over 5km.
  • Bus services limited, especially off peak. “


There is a single Primary School in each of Winscombe, Sandford, Churchill and Banwell.

All are currently oversubscribed and there is no immediate prospect of expansion to any of them neither is there any land available for expansion at any of the sites without reducing the area available sports activities or recreational time.

If the proposed developments proceed, the only possibility of housing the extra pupils would be in temporary classrooms with all their inherent disadvantages, again reducing the area available sports activities or recreational time.

The only secondary school in the area into which all four primary schools feed (Churchill Academy) “currently has a little capacity” and is in need of new facilities.


There are only two practices operating within the area:

  • Mendip Vale Medical Practice which operates surgeries at Langford, Congresbury, Yatton and St Georges (on the edge of Weston-super-Mare) and
  • Winscombe and Banwell Family Practice which operates surgeries in those two villages

Currently the waiting time for a routine appointment is around 2 weeks at both practices although in theory it is possible to make an appointment to see a non-specific GP on the day. That does however depend on the ability to get through to the reception areas of both practices before all a particular morning’s appointments have been allocated.  Not at all easy or usually successful!


In answer to the question posed in the NSC document:

“Are there a range of local employment opportunities, suitable for those living within the community? Or is the community reliant on one of two big employers?

We have the NSC responses which include the ‘traffic light’ coding as:

  • Winscombe -  Amber
    Limited employment opportunities: Sidcot School, Primary School, Post Office sorting Office, local Shops
  • Sandford - Amber
    Thatcher’s and St Monica’s are the only large employers within the village. Also CJL Construction, Lyncombe Lodge Hotel and Mendip outdoor pursuits.
  • Banwell - Amber Plus
    Various local business. Co-op has just opened, Bristol waterworks, Banwell garden centre
  • Churchill/Langford - Amber 
    A few opportunities available, Mushroom Farm, pub, School etc. Bristol University School of Veterinary Science

Frankly, these ratings are gratuitously disingenuous and bear little resemblance to reality.

  • All the jobs available are obviously already occupied so only very slow turnover is likely
  • The variety of experience/qualifications/educational background required to fulfil the relevant jobs are gathered at the top and bottom end of the educational scale.
  • Thus, the vast majority of new residents (of which there are potentially nearly 2000) will be forced to look to the two big employment areas (Weston-super-Mare and Bristol) outside the area of the 4 villages in question.
  • Thus, increasing the already high incidence of private vehicles on the roads via the four ‘pinch points’ of Banwell, Greenhill Road Sandford, Sandford/Churchill traffic lights and Congresbury traffic lights.


  • The proposed development has unacceptable adverse impact on views from the Mendip Hills ANOB to surrounding countryside. North Somerset sites and Policies Plan Development Management Policy DM11.
  • The application is in breach of the Core Strategy Policy CS19 –it does not maintain the Strategic Gap between Winscombe and Sandford.
  • The application is in breach of Core Strategy Policy CS5 – it does not enhance the beauty of the Mendip Hills ANOB.
  • The application is in breach of Core Strategy Policy CS4 – it does not encourage the retention of trees.
  • The application is in breach of Core Strategy Policy CS32 – it is outside the village settlement boundary and is for more than 25 dwellings.
  • The application is in breach of North Somerset Sites and Policies Plan and Development DM10 ‐ the proposed development is harmful to the character of the local area, inappropriate and unsympathetic to the appearance and character of the local environment.
  • The application is in breach of Core Strategy Policy CS5 – it does not protect and enhance the local environment, wildlife, habitat and trees.
  • North Somerset Council has a legal duty to preserve the character and appearance of the Mendip Hills ANOB.
  • The application is in breach of Core Strategy CS5 – the proposed development is out of scale and character.
  • The application is in breach of Core Strategy CS4 – the applicant has not liaised with Advisory Bodies or Interested Consultees in relation to the landscape.
  • The Visual Impact Assessment is inadequate as it contains no photographs or simulations of the landscape. This is in breach of North Somerset Sites and Policies Plan Policy DM11.
  • The application directly contravenes North Somerset Council Sites and Policies Plan
  • Development Policy DM11 – the proposed development does not provide adequate privacy for occupants of adjacent residential properties, particularly with regard to quiet enjoyment of garden amenities.
  • The proposed site is within J1 Lox Yeo Rolling Valley Farmland.
  • The proposed development is in breach of the Human Rights Act Protocol 1, Article 1 – ‘a person has the right to peaceful enjoyment of all their possessions which include home and other land’.
  • The proposed development is in breach of Article 8 of the Human Rights act – ‘Substantive right to respect for private and family life’.


  • Adjoins the Mendip Hills Area of Outstanding Natural Beauty (AONB)
  • Gradual coalescence of Winscombe and Sandford
  • Strawberry Line extends directly adjacent to western boundary of the Site, only 19% of this 3km section is free from urban development on both sides
  • More mature trees present prior to the clearance works undertaken by the Applicant along Towerhead Brook Site of Nature Conservation Interest
  • Applicant’s own comment ‘the proposal for a new residential development is generally considered to be of high significance in terms of visual impact’
  • A ‘line in the sand’ must be drawn somewhere to protect the distinctive qualities of the landscape
  • Applicant’s clearance of habitats just prior to commencing ecological surveys is insupportable
  • Increasing traffic in the village and surrounding villages (in particular Banwell)
  • 5m buffer to the AONB and Strawberry Line Local Nature Reserve is a derisory concession from the Applicant
  • Demolished a barn‐like structure potentially used by roosting bats and nesting birds


  • Significant impacts on the nearby North Somerset and Mendips Bats Special Area of Conservation
  • The clearance of habitats by the Applicant immediately prior to the commencement of ecological surveys puts the findings of the ecological surveys into serious question impacts on key protected species, most notably bats, Dormice, Badgers and Great Crested Newts, have not been adequately assessed
  • Adjacent to the Mendip Hills Area of Outstanding Natural Beauty Strawberry Line
  • Local Nature Reserve and Site of Nature Conservation Interest on the western side
  • Towerhead Brook Site of Nature Conservation Interest
  • Design and Access Statement that ‘habitat is considered to be of negligible ecological value providing minimal resources for wildlife’
  • Possible requirement for HRA in the Applicant’s document and there appears to have been no consultation with Natural England
  • Applicant’s clearance of habitats just prior to commencing ecological surveys is insupportable ‐ meadows were ploughed in May 2015
  • Sutherland Property and Legal Services argued on the Applicant’s behalf (at two parish presentations) that the habitat clearance was just part of routine agricultural management ‐ entirely implausible and must be robustly challenged by North Somerset
  • Applicant’s ecologists state ‘the site is considered to have limited optimal terrestrial habitat for great crested newts’, this was certainly not the case prior to it ploughing up the old livestock grazed meadows (perfect habitat for foraging newts) immediately preceding the ecological surveys
  • Ecological impacts on the Strawberry Line is not discussed in any detail in the Applicant’s report

I believe that there is absolutely no justification for including the Broadleaze Farm site in the new allocations.

Robert Court



Please see attachment containing appendices