Meeting documents

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Dr D.P. Smith

Bathampton Parish Council

i) Page 4-Para 3.8 Add light pollution to the list at the top of Page 5 ii) Page 12 - B.1 A more comprehensive list. These points should be added to the Local Plan list at B.1 on Page 131 policy GDS.1 iii) Page 13 - B.5 a) The statement is ambiguous. The impact of this development is considerable especially when viewed from the south side of the valley.

i) Light pollution could be considered for inclusion as a Sustainable Development criterion in future Sustainability Appraisals. Ii) As para 6.28 of the Summary points out, these outcomes are largely additional recommendations for the GDS site requirements. A number of the issues referred to are already dealt by other policies in the Plan and it is therefore not considered necessary to repeat as site requirements. Others might need to be the subject of more detailed consideration through the preparation of Supplementary Planning Guidance and the Masterplan for Western Riverside . Iii) As consideration of 'views' was not one of the Sustainable Development criteria and therefore this aspect of the development of site B5 was not appraised. However, a negative impact on both landscape and townscape was recorded. ACTION: Include 'light pollution' and 'views' as potential Sustainable Development criteria in the next Sustainable Development Appraisal.

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Mr P.D. Chivers

Charlton Park does not meet with the proper criteria for sustainable development taking into account PPG3 and the DETR's 'tapping the potential'. Research into the availability of brownfield sites in the area has proved to be inadequate. Insufficient thought has been given to vehicular movements from Charlton Park through the town to the larger conurbations to the north. The inclusion of Charlton Park for residential development has not been sufficient to meet your affordable homes target in a practical way. There are no definitive proposals for self-build housing on any sites mentioned around Norton Radstock. There appears to be no policy relating to work/live units addressing employment needs. The employment policy will lead to further dereliction of sites around Midsomer Norton unless transport communications are improved to the conurbations to the north, and is unrealistic in its assessment of market needs. Appraisals need to be systematic and conform with your expressed duty to monitor. Your urban capacity study (not available on your website) has apparently taken sites at random. If employment sites become unsustainable (and such sites are evident in the Norton Radstock Area) residential use may be a viable option which needs to be analysed in more detail.

These comments relate more to the allocation of a site in the Local Plan than to the Sustainable Development Appraisal. Site GDS.1/NR1 ( Charlton Park ) was deleted following the identification of additional brownfield sites in the Revised Deposit Local Plan . ACTION: None required.

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Mrs Christine Baldwin

I object to the building of new houses on green belt land. Brownfield that is derelict or has been used before seems to be a good site to use. The reasons I object are as follows: 1. Destroying the countryside - killing wildlife 2. Minimising the countryside 3. Building on green belt will make the towns/villages close together or blend into one. 4. Parking in high street areas will become more of a problem. 5. Leisure and shopping facilities will become overcrowded. 6. It will have an effect on our environment and pollution Therefore I hope our voices will be heard.

As stated in para B7.21, the Local Plan seeks to promote sustainable residential development partly by, as far as possible, maximising the re-use of previously developed brownfield land and converting/re-using existing buildings. Housing allocations are also based on the sequential approach advocated in PPG3. Given the limited supply of previously developed sites within the district, it is inevitable that greenfield land will also need to be developed for housing in order to meet the JRSP dwelling requirement. Greenfield sites have been allocated on the basis of their potential to promote sustainable development but it is now proposed to reduce their number as additional brownfield sites have been identified since the Local Plan went on deposit. ACTION: None required.

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T.M.G Gray

Duchy of Cornwall

We object on the following grounds: 1. The Foreword recognises that Sustainable Development Appraisal is an iterative process and that the Deposit Draft has been 'informed' by the SDA carried out at the Issue Report stage in late 1999. The previous SDA amounted to little more than a check list of generalised objectives. Indeed the Issues Report did not contain a comprehensive and coherent strategy or a set of strategies which were capable of SDA. At no stage has the process identified 'the choices which need to be resolved by the plan' as recommended by para 2.8 of PPG12 (Dec '99). It is not 'clear from the process how and why policy and proposal options have been chosen ' nor is it 'clear from the reasoned justification/explanatory memorandum of the plan what elements of the appraisal have informed the policies and proposals in the plan' para 4.18 of PPG12. 2. At no stage has the apparently ongoing SDA set out 'alternative policies, proposals and locations for development' nor 'evaluated' them, as recommended in para 4.19 of PPG12. Effectively an important stage in the process has been omitted. Furthermore, there is no direct evidence that the SDA informed the decision making process of the Council - in particular the decisions taken by the full Council on 25th October 2001 . 3. It is far from clear as to whether the SDA relates to the Pre-Deposit Draft or the actual Deposit Draft Local Plan . The Foreword refers to the SDA as relating to the Pre Deposit Draft 'considered by the Council's Strategy Committee on 3.10.01 and Full Council on 25.10.01'. Yet the cover and detailed content give contrary indications. Indeed page 13 and the Appendix list 'land at South of Charlton Park, Midsomer Norton' as having been appraised, whereas this site was not formally identified until one hour prior to the full Council meeting. The removal of the longstanding allocation of land at Welton Vale, Norton-Radstock at that meeting and the consequent changes represented a fundamental change to the Plan as a whole. It is therefore important to clarify how the changes relate to and can be reconciled with the ongoing SDA process. This is especially pertinent in the view of the fact that the Welton Vale site remained in the Pre-deposit Local Plan , following eleven meetings of the Project Group since early 2000 and the Strategy Committee meeting of 3 October 2001 , which was apparently the last opportunity for the professional planning officers to advice members on the content of the LP. The inclusion of the Charlton Park site and consequent amendments was the result of an ad hoc Liberal democrat motion. The head of Planning was not asked to inform the subsequent debate at the Council meeting. 4. We note from annex 4, the report from Levitt-Therivel Consultants, that the ' three day intensive appraisal session' involved 'a dozen Council staff and two consultants'. In this context we make the following particular comments about the report: . The 'appraisal session' apparently took place some time in 'October'. In view of the above observations the precise dates are extremely relevant. .on page 24 there is a comment that 'the planners clearly know what the relevant issues are' and on page 25 the expressed hope that 'these planners will think sustainability first and draft in that spirit'. Such observations indicate that the consultants may have underestimated the impact of ad hoc political decisions making on the content of the Local Plan ; the process which has occurred has been neither objective, technical nor rational. . We concur with the criticisms the consultants have made concerning the content of the SDA, incomplete though these are. . In particular we concur with the comment that the Council 'should promote more innovative, leading edge, truly sustainable development.' The removal of Welton Vale from the Deposit local Plan, however, deprives the Council of one of its best opportunities in this regard. . The conclusions of the consultants need to be reviewed in the light of the above criticisms/reservations.

These comments relate more to procedural matters than to the appraisal itself. Policy options were first considered at the Issues Report stage which was itself appraised and the results used to inform the drafting of the Deposit Local Plan . The Issues Report set out options and the link between the Issues Report options and Deposit Draft Local Plan was set out in the report to Full Council in 2002. The SDA itself was carried out on the Pre-Deposit Draft by officers and overseen by the consultants. The Council considered at its full Council meeting on 25 October 2001 that the Welton Vale site allocation was not sustainable and that it should be deleted from the Local Plan . This was part of its democratic decision making process. The new allocation at Charlton Park was subsequently appraised by officers using the SDA methodology, the results of which were included in the SDA summary document. However, it is now proposed to delete site GDS.1/NR1 ( Charlton Park ) following the identification of more sustainable brownfield sites in the Revised Deposit Draft Local Plan . Sustainable Development Appraisals, including any amendments following public consultation, are used to inform the next formal stage of the plan making process. Thus comments and suggestions in this Appraisal were considered as part of the preparation of the Revised Deposit Draft which in turn will be appraised in 2003. This is explained succinctly in para A2.4 of the Local Plan . ACTION: None required.

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Mr Townley

Batheaston Parish Council

A laudable report and any griping would be like 'preaching against motherhood'. B5 -the overall impact is quoted as "overall negative" but no mention of traffic implications onto A4 or Bailbrook Lane . Green Belt - We have already made comments on the draft local plan that some rationalisation be desired. Community services - Recent experience indicates a too-willing approach to converting shops into private dwellings (4 losses in Batheaston recently) Housing - there have been NO plans seen in the last 6 years for the provision of 'affordable' or low-cost homes.

Support noted. B5: Given the requirements of Policy GDS.1/B5, it is not considered that the proposals will give rise to adverse traffic implications along the A4 or Bailbrook Lane . As such, this issue is not identified by the Sustainable Development Appraisal. Green Belt: As these comments relate more to the Local Plan than to the Sustainable Development Appraisal, see response to Rep. 686/B20 regarding the boundary of the Green Belt at Batheaston. Community services: Disagree. Policy S.8 states that within district, local and village centres, the change of use of an existing shop to another use (e.g. residential) will not be permitted where the vitality and viability of that centre is adversely affected. As such, the policy will help to maintain the vitality and viability of retail centres, will help to safeguard the economy and employment, will promote and safeguard equality and will reduce the need to travel. Loss of shops will only be permitted where it is considered that they no longer contribute to the centre's vitality and viability. Housing: Policy HG.8 will ensure that a significant proportion of affordable housing is provided on all residential development sites in Batheaston that measure 0.5ha or more, or consist of 10 dwellings or more. However, affordable housing can only be provided if development proposals come forward which meet the thresholds set out in the policy. Policy HO.9 enables provision of affordable housing on exception sites in the Green Belt. ACTION: None required.

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S.F. Hobbs

I have only read the summary document but from that have the following observations:- Housing 6.22 - Is there a risk of opening up floodgates to people just wanting to live in rural idyll? (refers to Policy HG10) Built & Historic Environment 7.6 on Policy BH.1 - Any change in wording should still protect listed buildings from alterations which will destroy the characteristics which justified their listed status originally. Access - Agree need to amend T20 as suggested. GDS (page 13 in summary) - I support the suggestions made for K1 Somerdale in this summary on page 13 and for K2 south-west Keynsham although I think application of sustainability principles will have the effect of reducing or totally ruling out the development on the more southerly of these two sites. Green Belt - Environmental Assets Section - Policy GB1 - I agree with reinforcement of objectives for use of land in the Green Belt with the possible exception of a proven need for some affordable housing to meet the needs of local people (see HG9) Policy GB3 - all school playing fields must be protected and used if we are to provide opportunities for youngsters to improve fitness and maybe reach Olympic standards. I also share concerns with authors of this appraisal over the 'major increase' mentioned in GB3 in relation to Burnett Business Park and Uplands Farm and other such prominent and open sites. Finally I regret that a number of policies were not reviewed for various reasons.

Housing: Policy HG.10 states that dwellings outside the scope of Policies HG.4-6 will only be permitted if they are essential for agricultural or forestry workers, and places further restrictions on the size and location of the dwelling. These restrictions will ensure that residential development is limited appropriately and is not widely permitted. The policy accords with Government advice in PPG7: The Countryside (para 3.21), which recognises that it may be appropriate to permit new houses in the countryside if they are essential to enable farm or forestry workers to live at or near their place of work. Built & Historic Environment: Agree. The character and setting of listed buildings are more specifically safeguarded by Policies BH.2, BH.3 and BH.4. Access: Support noted. However Policy T.20 has not been amended as suggested as this policy, relating to the impact of proposals on existing off-street parking, is intended to read as a whole. Policy GDS.1/K1: Support noted. However the objective to promote renewable energy and improve air quality are dealt with in other policies in the Local Plan and therefore it is not necessary to repeat as site requirements. Policy GDS.1/K2: Support and comments noted. The site at South West Keynsham was deleted following the identification of additional brownfield sites. Policy GB.1: Support noted. However, it should be noted that Green Belt is primarily a protective designation i.e. its openness is protected by preventing inappropriate development. PPG2 makes it clear that the objectives for the use of land within the Green Belt is not a material factor in either its definition or its protection. Therefore it was not considered appropriate to amended Policy GB.1 or include a new policy as there are other policies in the Local Plan that seek to achieve such objectives as the enhancement of nature conservation and better accessibility to open space. Policy GB.3: The protection of open space (e.g. playing fields) is covered by other policies in the Local Plan . To include a clause seeking to safeguard playing fields within MEDS is therefore unnecessary. Secondly, the term 'major increase' is considered to be sufficiently restrictive, whilst allowing for interpretation on a case by case basis. Review of policies: As explained in para 3.10 of the Appraisal Summary, all policies in the Plan were assessed unless they had only a minor impact on sustainability issues or there was uncertainty about the nature or the policy or because of the time constraints. Very few policies were therefore not assessed. ACTION: None required.

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M.M. Stewart

The Springs Foundation

The appraisal regarding the sustainable use of resources has omitted to include impact on water resources, including the hot springs and their aquifer. Why? This is just not good enough!

Disagree. All the policies that were appraised have been assessed in respect of whether or not they will maintain and enhance water resources and quality. This is demonstrated in the matrices illustrated in the Sustainable Development Appraisal. ACTION: None required.

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Mr Len Morris

Norton Radstock Town Council

Comments regarding SDA: The Draft Deposit Plan begins its Policy Context Section A.2 with significant reference to "sustainable development." However, it becomes clear quite quickly that there will be trade-offs (Para A2.3). The Town Council is greatly concerned that many matters believed to be of considerable importance to Norton Radstock have not been appraised either because they are considered by the Local Plan ning Authority to have only a minor impact on sustainability issues or simply just to expedite the Plan. The Policies and Proposals concerned are detailed in Annex 2 to the SDA Summary. It could be argued that the lack of an appraisal of some of these policies and proposals make a mockery of the claim of the plan to sustainability. This particularly applies to matters relating to transport, social infrastructure and the making available land for employment purposes. The following Plan Policies should be appraised (and all of them should be appraised prior to the Revised Deposit Stage of the Plan): CF.6 Contributions from new development to community facilities; SR.3 Children's playing space and new development; SR.6 Provision of recreational facilities to meet the needs of new development; ET.2 Employment Land Availability; WM.12 Landfill; WM.15 Time Extensions for Landfill Sites etc.; T.2 Strategic Transport Corridors; T.3 Walking strategy: Pedestrian Safety and Convenience; T.8 Bus Strategy; T.12 Public Transport Interchange; T.25 Transport Assessments and Travel Plans.

As explained in para 3.10 of the Appraisal Summary, the Appraisal sought to assess Local Plan policies unless they had only a minor impact on sustainability issues or there was uncertainty about the nature of the policy or because of the time constraints. The respondent's comments will however be borne in mind when decisions are made about the appraisal of the Revised Deposit Plan. ACTION: Consider whether policies referred to should be appraised in the next Sustainable Development Appraisal.

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William Houghton

ROOT Association

Members have asked us to raise a specific item and area, some applicable to the present, the future and the past in relation to:- Lymore Park Open Space or the "Brickyards" as it is referred to locally. In particular is the foot access from King George's Road, which is an enclosed development. It appears that in the past an un-adopted path between the houses to their rear entrances has been opened up as a Public Access, and the original Public Access blocked up. Public signs making it unlawful to fowl the area have also been removed. There is also the problem to be addressed of people driving from miles around to use this access and parking in areas reserved for occupiers of the development and parking illegally. Local members wish to see this situation corrected as a matter of urgency, and several pieces of political skulduggery addressed regarding these past events. Our chairman has spoken to Planning Services on the actual footpath issues today and has been promised a response. As for the present and the future there are plans to site a private school on this open public ground and we would like to be kept appraised and kept up to date on the situation, a meeting with Planning Officers would be most helpful.