Site Allocations Plan - Main Modifications Consultation

Document Section Site Allocations Plan - Main Modifications Consultation MM25 [View all comments on this section]
Comment ID 1019201//4
Respondent Wrington Parish Council [View all comments by this respondent]
Response Date 30 Oct 2017

Section 2. Policy SA 1 – Housing Allocations

Proposed housing allocation, Cox’s Green, Wrington, ref MM25

This concerns a proposal to erect 28 dwellings on a site at Cox’s Green, with a planning application having been submitted and still to be determined, ref 17/P/0485/O. It was subsequently included in a list of sites submitted to the NSC Executive, 5 September 2017. The relevant report stating:

The 22 additional housing sites comprising 821 dwellings as set out in Table 1 are recommended to the Site Allocations Plan Inspector for inclusion in the plan to provide additional supply to address concerns about housing delivery identified in her letter of 26 June 2017.

and in referring to Cox’s Green under item 3.11e it states:

This is a site which is subject to two applications; the larger site for 59 dwellings is the subject of an appeal to be held at the end of September. While the larger proposal has significant adverse landscape impacts, the smaller site is of a scale of development which it is considered could be more readily assimilated, subject to resolution of detailed layout, design, and landscape impact. The smaller site for 28 dwellings is recommended for inclusion, but the Council will continue to resist the larger site at appeal due, in particular, to its greater landscape impact.

Under Appendix A: ‘NSC conclusions on the sites assessed’:

Site is adjacent to the settlement boundary of Wrington, which is a Service Village. Subject to ensuring safe pedestrian access arrangements (as part of the current application) the site will be served by local facilities and services. The larger scheme previously proposed is subject to significant landscape objections (and is currently at appeal), however the smaller scheme is considered to be capable of assimilation into the village (subject to layout, design and landscape impact). Measures to address any local flood risk impacts will be important in facilitating development of the site. This must be dealt with by conditions attached to any planning consent. The site is within the control of a house builder, who advises that site is deliverable within two years.

and under Conclusions:

Identify the site within Schedule 1 of the plan for 28 dwellings, with reference to requirement for measures to address any impact on local flooding issues.

Commenting in brief on the points made above. It seems to us that the landscape impacts resulting from the 28 house development would be little different to those created by the larger 59 house proposal. This is an undeveloped rural green field site, adjacent to the Green Belt boundary and with a Wildlife Site close to the south. Development on the site, whether one, 10, 28 or 59 houses, would be visible from both Wrington Hill and the Mendip Hills AONB and would certainly have significant negative landscape impacts, not least from the effects of lighting.

On the point made about being served by local facilities and services, should the site be developed then any new residents would probably do much the same as many of our existing residents, which is to use the more comprehensive facilities and services elsewhere. This would of course create more traffic movements. However, and perhaps more significantly, the regular flooding experienced around this site cannot be mitigated through planning conditions, as was obvious from the recent planning Inquiry on the 59 houses proposal. See appeal ref APP/D0121/W/16/3166147.

Under MM25 and ‘Site specific details/notes’, NSC states:

- New allocation.
- Vehicular access off Havyatt Road.
- Design/layout to minimise visual impact of the scheme.
- Retention of existing hedgerows.
- Improved footpath access to village.
- Open space requirements to be fixed through planning application.
- Sufficient space to be allowed for effective access for maintenance of watercourses and surface water drainage features.

While we comment further below, it should be noted that there is no ‘footpath access to the village’, although a new footway has been proposed by the developer. However, this is not achievable as to build on the existing highway surface would result in an unacceptable reduction in road surface width, and the owners of the relevant neighbouring residential properties have stated in writing that they will not sell any land to allow the footway to be built. It is concerning that there is no reference by NSC to the potential ecological impacts.

Planning application 17/P/0485/O

Your attention is drawn to the various representations submitted on the relevant planning application. These should be read alongside the comments on application 16/P/1291/O for 59 houses and the subsequent appeal. The issues are much the same and include landscape impact, flood risk, flooding of the access roads, poor pedestrian access on narrow roads which carry regular HGV traffic, limited public transport services, ecological/wildlife impacts and, of course, sustainability. Most new residents would choose to drive rather than walk or cycle, in which case they would be more likely to use larger shops and other facilities elsewhere. Also, it can now be difficult to park in the village centre following conversion of various shops and other commercial premises to residential use.

We have enclosed the Council’s comment on application 17/P/0485/O, together with the original comment on 16/P/1291/O, but with the latter as submitted as an Annex to the later 28 houses application. These previous comments should be read as key elements in this submission to the Inspector, which means that we can reduce the length of this comment.

However, we do need to make some additional points, these concerning the NPPF and, particularly, flood risk.

National Planning Policy Framework (NPPF)

The NPPF has sustainable development as its core aim, yet the Cox’s Green site cannot offer sustainability on any level. We won’t expand too much on this here but please refer to our comments on the relevant planning applications. These are enclosed with this submission.

The NPPF promotes sustainable transport choices under para 29, recognising that ‘transport policies have an important role to play in facilitating sustainable

development but also in contributing to wider sustainability and health objectives’ and stating that ‘the transport system needs to be balanced in favour of sustainable transport modes, giving people a real choice about how they travel’. However, there would really be no choice on travel modes resulting from development at Cox’s Green, with residents having no practical alternative to using their cars for access to supermarkets, retail outlets, medical services, employment, railway stations, etc.

We suspect that any significant development in or around Wrington would result in increased congestion, particularly in the village centre, in conflict with para 30.

We suggest that the development proposal fails to meet the requirements of para 32 in relation to ‘safe and suitable access to the site …. for all people’. Cox’s Green is a narrow country lane. It is currently between 5.3 and 6m wide and could not be narrowed further without breaching accepted highway safety standards, particularly in relation to HGV and bus traffic, ref Manual for Streets, and NSC and bus operator design guides. In the circumstances, it is hard to understand why NSC Highways did not object on these grounds.

Under para 35, the NPPF states that ‘developments should be located and designed where practical to:

- give priority to pedestrian and cycle movements, and have access to high quality public transport facilities;

- create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones;

However, the Cox’s Green site is located more than 800m from the village centre which is the recommended IHT maximum. The route to and from the village has obvious conflicts between vehicle traffic (including HGVs) and pedestrians, and could not be considered ‘safe and secure’. Also, there is certainly no ‘high quality public transport service’, nor is this likely to be provided in what is a rural area where more frequent high quality bus services would inevitably be uneconomic.

The local authority is not in any position to improve car parking in the village, ref para 40. There is no more space available, either for creating parking spaces on the highway or for off road parking.

The NPPF clearly requires that sites proposed for development are ‘deliverable’, para 47. This is not the case with Cox’s Green as the proposed pedestrian access would need a new footway to be constructed and this is not feasible without the co-operation of residents, as suggested earlier.

Under para 55 the NPPF states ‘To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities’. We agree, although anything other than small scale, or very minor new development should only be located where there are adequate services and facilities available. As a minimum this should include a school (para 72), medical facilities, at least a small supermarket and a post office. Please note that the Mendip Vale Medical Practice has given notice that the small branch surgery in Wrington is to close, although MVMP has allegedly deterred residents from using it in recent years. Also, and significantly, there is no ATM in the parish other than at the airport.

The NPPF comments at length on protecting the Green Belt, paras 79 - 92. While the Cox’s Green site is not within the Green Belt, it is adjacent to it, as it is adjacent to the settlement boundary. As such it can be argued that the proposed development would impact on the openness of the Green Belt.

Finally, we have noted the recommendation under para 100 that ‘Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk’, and also the points made under paras 101 - 103. It is a fact that the roads surrounding the site proposed for development all flood. This is fluvial in the case of Mill Lane and Havyatt Road, and pluvial in Nates Lane and Cox’s Green itself.

Surprisingly, in an email sent 22 September 2017, an NSC Flood Risk Officer stated that they ‘have no local records of flooding in Nates Lane’. But, the road here floods regularly, with other NSC Officers being well aware, and of the risk to drivers on the A38 main road when they immediately stop on turning in to see the deep water. In the same email it is stated that ‘Priority is given to highway flooding/drainage problems that pose a significant risk to road users, or cause flooding of dwellings’

and that ‘we have no records of road flooding on Cox’s Green’, although photographic evidence has been provided to NSC showing the road completely flooded and it is well known that at least one house here has flooded in the past. It is also stated that the location ‘hasn’t been flagged up as a problem’, which isn’t correct, and that NSC does not ‘have details of all our drainage systems’.

The latter point is deeply concerning as it means there can be no guarantee that any related planning conditions could be met, although this lack of understanding is perhaps why NSC didn’t object on flood risk grounds. The road surface in Cox’s Green floods because the drainage is inadequate and the development site could not drain fully to the south because of the topography. Development would be certain to increase surface water flows to the north where there is no dedicated surface water drainage system, just a small capacity road drain. A further issue is that if the development was to proceed and the footway constructed, it would be unusable in flood conditions as the water depth would exceed any normal kerbing level. The developer’s drainage consultant appeared to have little understanding of these practical Cox’s Green issues when he presented evidence at the recent appeal hearing, having stated that he hadn’t visited the site, nor has the developer asked for the Council’s experienced views on these and related issues.

We suggest that built development on this site would not meet the requirements of paras 100 - 103. We wanted to highlight this and the other NPPF issues to make the point that including the Cox’s Green site would be mistaken.