Pegasus Group Land Value Alliances LLP

Local Plan Part II: Focussed Consultation on Proposed Changes – Contact Form

The Council is inviting responses on its Proposed Changes to the Local Plan Part II and updated submission documents. These will be provided to the Local Plan Inspector to be considered in the examination. ►An information note gives guidance on what you can comment on at this stage.

Copies of this form are available from the Council Offices and Access Points or from www.mendip.gov.uk/localplanpart2 . If you require this document in another format such as Braille, large print or another language or for other queries, you can contact us at [email protected] or via Customer services (0300) 303 8588.

Contact Details If you have appointed somebody to act as your agent, please give their contact details. All correspondence will be sent to the agent Name: Agent Name: Mr Alex Bullock

Organisation (if applicable): Company Name: Pegasus Group Land Value Alliances LLP

Address: Barrow Hill House, Milborne Wick, Address: First Floor, South Wing, Equinox North, Milborne Port, Sherborne, Dorset Great Park Road, Almondsbury, Bristol

Postcode: DT9 4PP Postcode: BS32 4QL Email: Email: [email protected] Tel: Tel: 01454 625945 Date completed Date completed: 24/04/2019

You can also attach one contact form to a group of representations. Data protection – please read - The information collected as part this consultation will be processed by the Council in accordance with the Data Protection Act 1998. The purposes for collecting this data are: to assist in plan making; and to contact you, if necessary, regarding the planning consultation process. Please note that representations must be attributable to named individuals or organisations at a postal address. Representations and contact names will be published on the Mendip website but no other personal information

►Have you already made representations to the Pre Submission Plan? * (tick) x ►Have you already made a response to the Proposed Changes * (tick box) Do you wish to up update or add to this response? ►Do you wish to be notified of future stages of Local Plan Part II (tick box) X ►We will contact you by e-mail only unless you confirm here (tick box)

Please return your response by 5pm Wednesday 24th April 2019. By post to: Planning Policy, Mendip District Council, Cannards Grave Road, Shepton Mallet, Somerset, BA4 5BT By email to: [email protected] By hand to: The Council offices in Shepton Mallet (address above) or Access Points

Local Plan Part II: Focussed Consultation on Proposed Changes – Detail Form

Please use this form to submit responses to the Proposed Changes & Schedule of Maps, Addendum to the Sustainability Appraisal, Habitat Regulations Report And supporting Documents.

Please read the supporting Information note for guidance which explains what you can respond on in this consultation and the technical terms

Copies of this form are available at www.mendip.gov.uk/localplanpart2, at the Council offices and Access Points

Name / Pegasus Group on behalf of Land Value Alliances LLP Organisation

Q1: Which Proposed Change are you responding on? Proposed Change/ Map – Ref Number, Topic, Site or Document Your representation must refer to the Proposed Change, Map Reference or supporting document

In relation to Butleigh PC51, PC52, PC53, PC54, PC55 and PC56

In relation to Stoke St Michael PC71a and PC72

Q2: Does your representation relate to a previous one you submitted at the pre-submission stage or previous consultation stage. If so, has the Council satisfied your objection through the Proposed Changes (tick the box)

● Yes, the Proposed Change meets a previous objection which I would now be willing to withdraw

● No, the Proposed Change does not meet my previous objection X

● I did not submit any comments on the previous stage

Q3a: Is the Proposed Change Legally Compliant yes no (tick box)

Q3b: Is the Proposed Change Sound yes no (tick box)

‘Legally compliant’ means the Proposed Change to Mendip Local Plan Part II has been prepared in line with the Council’s Statement of Community Involvement (SCI), and meets the requirements for engagement, consultation and ‘duty-to-co-operate’ in national planning legislation and has been subject Sustainability Appraisal/ Habitat Regulations Assessment – See Information Note.

Sund’ means the Proposed Change is positively prepared, justified, effective and consistent with national policy (see paragraph 182 of the National Planning Policy Framework). – See Information Note.

Q4: If the Proposed Change is not Sound – is this because it is NOT:

Positively Prepared X Justified X Effective Consistent with National Policy X

These terms are explained in the Information Note. You can tick more than one

►Please set out your reasons in the Detailed Response Box on the next page

Please see enclosed letter of representation and accompanying Site Comparison Assessment.

Local Plan Part II: Focussed Consultation on Proposed Changes – Detail Form

Detailed Response to Proposed Changes

Name

Please see enclosed letter of representation

AJB/P18-0524

24th April 2019

Mr Andre Sestini Planning Policy Mendip District Council Cannards Grave Road Shepton Mallet Somerset BA4 5BT

Dear Mr Sestini

MENDIP LOCAL PLAN PART II: SITES AND POLICIES – FOCSSED CONSULTATION ON PROPOSED CHANGES

I write on behalf of my clients Land Value Alliances LLP (LVA), who have land interests across Mendip. In particular and of direct relevance to this consultation land at Butleigh and Stoke St Michael.

In the case of Butleigh, my clients control the site proposed for allocation ‘West View, Sub Road (Policy BT1). Whilst we continue to support the allocation and wish to agree a Statement of Common Ground with the Council we consider the proposed changes to the allocation to be unjustified. It should also be noted that LVA have a current undetermined outline application (2018/2648/OTS) for up to 32 dwellings which was made in line with the pre-submission preferred allocation.

In relation to Stoke St Michael, LVA control HELAA site SSM007 which is not proposed for allocation. However, we continue to express significant concerns with the Councils approach to site identification at Stoke St Michael to meet the remaining need for that settlement.

Our views within this consultation response directly correlate with the focussed changes but it is important to highlight that they build upon earlier representations made in 2018 and will set the context for our hearing statements and representations which we intend to make to the forthcoming examination.

West View, Sub Road, Butleigh (Policy BT1)

The Council proposes a series of modifications to Policy BT1, namely PC51-PC56. We consider each of these changes in turn.

PC51 & 52 relate to amended supporting text to reflect proposed changes to the development limits of Butleigh to account for a 2012 consent for the redevelopment of the former Butleigh Hospital site.

Pegasus Group is a trading name of Pegasus Planning Group Limited (07277000) registered in England and Wales Registered Office: Pegasus House, Querns Business Centre, Whitworth Road, Cirencester, Gloucestershire, GL7 1RT

Page | 1

This proposed change results in a significant extension to the development limit of Butleigh and the proposed allocation would be within the defined settlement boundary and we are supportive of this approach so far as it extends to existing development along Barton Road, but we would question the approach to drawing a settlement boundary around the isolated Butleigh Hospital site.

It is the case that given that the Butleigh Hospital permission dates from 2012 and therefore pre-dates the commencement of work on the Local Plan Part II (as set out in SD6 Statement of Consultation) we would query why at the point of submission do the Council now seek to change the approach at Butleigh and by consequence seek to reduce the quantum of development for the settlement. We consider strongly that such an issue is not one which relates to ‘soundness’ as the Council purport.

PC53 seeks to introduce a requirement to provide a footpath link to the village core. Whilst we are generally supportive of provisions to increase permeability we consider that the proposed amendment isn’t specific enough to be of value.

There is no existing defined footpath along much of Sub Road, typical of a village location, and it would be almost impossible for a developer of the proposed allocation to deliver such a connection due to multiple land ownerships between the site and the village centre.

However, it is potentially possible to deliver a footpath connection from the allocation site through the existing adjacent children’s play area which is owned by the Parish Council. LVA have allowed for such a connection. We consider the policy should be specific about this possible connection instead of the current more general point.

PC54 this change introduces the need for a “safe access” to be provided onto Sub Road. We consider that amending the policy wording in this regard is not necessary to add this within the bullet point list.

The policy already benefits from a section on highways which states:

“The site has access onto Sub Road and will need to meet highways standards on width and visibility.”

The proposed amendment to the bullet list adds little and, in the event, a safe access wasn’t proposed the Council could resist an application on those grounds as part of normal development management considerations.

PC55 we strongly object to the inclusion of an additional bullet concerning the need to “safeguard against creating issues with subsidence”. Clearly, we would not want to cause subsidence through development, but as the Council’s table makes clear that “there is no evidence of subsidence other than anecdotal”. Indeed, having reviewed the consultation responses it is noted that respondents have simply stated that subsidence is a local issue.

Such evidence falls significantly short of a reasoned justification for this amendment and we would suggest this is not necessary and should be deleted.

PC56 this amendment is closely related to those under PC51 and PC52 which have been discussed in part above.

Page | 2

We disagree with the Council’s assertion that you see the redeveloped hospital site in the context of the wider settlement of Butleigh. It is quite clearly separated from it and should not in our view result in an isolated settlement boundary being established. Such an approach has not been proposed for other parts of the village which are much more closely related.

We also query as to why the Council is changing its approach to the quantum of development for Butleigh at the point of submission, particularly where the Butleigh Hospital permission has existed since 2012. It is our view that Butleigh Hospital should continue to be excluded and as a result a 32-home residual requirement remains.

We would also highlight that as of December 2019 (less than 8 months away), the Council’s adopted housing requirement will be out of date and the new requirement will be based upon the Standard Methodology. Such a requirement will see the Council’s annual target increase significantly. We would question why the Council, in this context is seeking to artificially constrain a site which the Council considers is suitable for residential development.

As noted above LVA have an application pending for an outline application which proposes development of up to 32 dwellings. This application was made regarding the preferred option policy wording which proposed the site for allocation for 32 dwellings.

We note now that the Council considers the site to be somewhat constrained due to “potential issues identified around highway access, and impact on the conservation area.” Whilst local people have raised issued around “amenity, landscape, flooding and subsidence” which the Council concludes gives rise to a reduction of the site capacity/density by 7 dwellings.

It is therefore necessary to analyse the evidence for this view.

In the case of highways, no issue has been raised by the highway authority in respect of the quantum of development proposed under the pending outline application. The only concern which has been raised relates to the formation of the site access and what impact it has on the existing road width on Sub Road. Discussions with the County Council have been on-going, and it is expected that their objection will shortly be removed to the application. Accordingly, there is no highways issue to justify a reduction in dwelling numbers.

In respect of impact on the conservation area, the Butleigh Conservation Area was revised and designated in 1995 and there is currently no adopted Conservation Area Appraisal for this Conservation Area. A Heritage Note submitted with the application concludes that the development of this site will not lead to any harm to the Conservation Area. We assume that the Council must have reached a similar conclusion previously when both proposing the site for allocation and recommending that 32 dwellings could be accommodated. On the basis that the Butleigh Conservation Area has not been amended since 1995 we would question what evidence exists to demonstrate harm.

In respect of amenity, no concerns have been raised regarding the impact of residential amenity by statutory consultees nor by the case officer to date. It is our view, that although indicative, the submitted masterplan ensures that minimum separation distances

Page | 3

are exceeded, and the site can easily accommodate residential development of 32 dwellings which equates to a density of approximately 20 dph which is entirely appropriate for an edge of village location.

In respect of landscape, the Council’s own response to the pre-submission consultation notes on numerous occasions that “the site is visually well contained, with existing housing on 3 sides. It is not prominent in the landscape”. With this view in mind we would question whether there are any landscape issues associated with the site.

In respect of flooding, it should be noted that the site sits wholly within Flood Zone 1 area of lowest risk. The applicant has proposed on the current application a comprehensive drainage solution which has been discussed at length with the Local Lead Flood Authority. It is understood that the initial objection has now been resolved and a revised consultation response will be issued shortly. Accordingly, there is no outstanding flood risk concern.

As highlighted above there is no evidence, other than anecdotal (i.e. local respondents) of subsidence being an issue. If it is a local issue, then this would apply to any site within the village and not a limitation of this site. We do not consider that this should limit the quantum of development on this site.

It is therefore clear that the issues identified by the Council to justify a reduction to 25 dwellings is not substantiated and is not based on any demonstrable evidence. We therefore oppose the reduction and respectfully request that the Council reverts to the 32 dwellings figure.

Stoke St Michael

We note that a substantial change (PC71a-PC72) is proposed in respect of Stoke St Michael which sees the Council propose to allocate land (Policy SS1a) to the east of Frog Lane and north of the playing fields (Ref: SSM0009) as opposed to land west of Frog Lane (SSM008).

The Council’s justification for this change is that it benefits from better access to the footpath network and therefore the existing services and facilities within the village are more accessible. In addition, the Council purports that the site is larger and therefore able to accommodate a greater proportion of the residual requirement for Stoke St Michael.

We are supportive of the Council’s identification of the need to identify land which would address more closely the residual requirement (30 dwellings). We are also supportive, as per our earlier representations of the removal of site SSM008 as the site did not represent a suitable and logical site.

However, the substitution site which has been identified is fundamentally flawed in respect of highways and no consideration has been given as to how the site will be delivered particularly in relation to ecological and landscape constraints.

Highways

We would request that the Inspector makes a site visit to the proposed allocation with a view to understanding its relationship with the village and the services and facilities available.

Page | 4

Appended to these representations is a detailed highways assessment (Appendix 1) of the proposed allocation at Frog Lane and this explains why this proposed allocation is unsuitable for residential development.

APPENDIX 1 – STOKE ST MICHAEL SITE COMPARISON ASSESSMENT

The supporting text suggests that the preferred point of access (the only potential point) will need to meet highways standards on width and visibility.

It should be noted that Frog Lane has no pedestrian infrastructure during the entire section and is currently the subject of national speed limit. We have also undertaken on-site measurements which shows the carriageway has a variable width of between 3.9m and 5.9m (which equates to a single passing point). Of note is the 100m section to the north of Stoke Hill which has a width narrower than 4.1m which prevents two cars to be able to pass each other side by side.

In addition, where Frog Lane meets Stoke Hill the current visibility splays are significantly sub-standard even in the eventuality that the speed limit along Stoke Hill is reduced by a Traffic Regulation Order (TRO) to 30mph. We have fundamental concerns about the ability, given land ownership, to improve the visibility and safety of this junction.

As a result, we would question the suitability of the access for vehicles onto Frog Lane. We have also reviewed the extent of the public highway along Frog Lane and can confirm it is restricted to the existing width of the carriageway and land beyond is within 3rd party ownership. This means that the opportunities for any improvements will be limited and given that all vehicles will use this route, and this is a significant short coming of seeking to allocate this site.

In respect of pedestrian movements, the Council suggest that this site is better positioned to be able to make use of the existing Public Right of Way network. Whilst it is true that routes 18/45 (connecting into 18/14) and 18/5 are in relative proximity to this proposed allocation.

However, to have a site which must rely fully on rural PRoW’s is fundamentally flawed as whilst they might be suitable to use during good weather, they are largely unused during winter months, at night or by potential users who have either mobility impairments either physical or with pushchairs etc. It also seems unlikely that such routes could be upgraded given their rural nature and as such there are no suitable alternatives for pedestrians who won’t risk walking along Frog Lane, as a result this site will encourage the use of the private car as there are no reasonable alternatives.

We note also that reference is made to the site’s proximity to the Primary School. Whilst it is true that they are adjacent, there is currently no lawful ability to access one site from the other and no vehicular access through to the school. As a result, any one wishing to access the site would have to walk either via Frog Lane or one of the PRoW’s which would not be suitable for most of the year or for people with small children/pushchairs or those with disabilities. It is considered overall to be poorly located and inappropriate in respect of highways connections. There are better located sites within the village which could deliver this quantum of development, not least LVA’s land at Coalpit Lane.

Page | 5

Ecology

We would question whether this site can be successfully developed when regard is had to the known ecological constraints.

As the policy wording identifies the existing hedgerows on the site could potentially support hazel dormice as well as being important for greater horseshoe bats which are associated with SSSI St Dunstan’s Well and Mells Valley SAC which lies only 250m to the west of the site.

It is clear from the evidence base provided by the Council that no detailed survey effort exists in relation to either how dormice or bats use this site. We would question why this has not been undertaken given the sensitivities of this site and its proximity to the St Dunstan’s Well Catchment. We are aware that other part II allocations make a specific provision for ecological mitigation as part of the policy proposals.

LVA is aware from the detailed ecological evidence that it prepared for its site at Coalpit Lane, Stoke St Michael and associated application (2016/3122/OTS) that the mitigation measures secured in full agreement with Natural England and the County Ecologist equated to the provision of almost 2ha of land for direct mitigation for development of up to 36 dwellings.

Whilst we accept that development on this site is for a lower quantum of development it is reasonable to assume that a similar level of mitigation might well be required, we estimate this could be in the order of 1.5 ha. Assuming this to be the case then that alone would exceed the total site area of the proposed allocation which we estimate to be approximately 1.4ha. We are therefore of the view that the allocation at this size is not deliverable.

It should also be recognised that a significant proportion of the hedgerow along Frog Lane may well need to be removed to deliver a vehicular access and any associated improvements to the width of Frog Lane. Clearly hedgerows as linear features are of fundamental importance for both dormice and the navigation of commuting bats. Accordingly, whilst we do not suggest this alone would prevent the development of this site its impact would nevertheless have to be considered in the round with the wider impacts discussed above.

Landscape

We note that the policy requires the “site should be designed sensitively to ensure no harm to the countryside setting”. We consider that the development of this site would undoubtedly result in significant landscape harm given its exposed rural setting.

Whilst we accept that the rear of the Primary School and properties of Moonshill Road can be seen views north along Frog Lane see the site as a constituent part of the agricultural setting of the village and there is no sense that this land forms part of the village, it is simply open countryside. This s fundamentally not the case of land at Coalpit Lane which is seen as transition land between the rural and urban forms.

Page | 6

Summary

It is clear from the discussion above that this proposed allocation is not deliverable as it won’t be possible to deliver enough land as mitigation for its development, it won’t be possible to provide a suitable means of safe access for vehicles and pedestrians and we consider it likely to cause significant landscape harm. We see little improvement between the allocation of this site in preference to the earlier preferred option to the south. The same deliverability issues must apply, and we raise more detailed concerns with this site.

We would politely suggest that there are highly deliverable sites within the village, which have been through the application process and have found technical solutions in respect of highways, ecology and landscape. If the Council is committed to delivering housing including affordable housing in Stoke St Michael it must not allocate this site.

Conclusion

LVA have land interests across Mendip and these representations focus on proposed changes to the Local Plan Part II at Butleigh and Stoke St Michael. LVA intends to take a full and active role in the forthcoming examination.

LVA are concerned regarding the proposed changes to the Butleigh allocation. There is no substantive evidence to justify the amendments to the policy wording. As they are unjustified and are not necessary for the soundness of the Plan they should be reverted back to the Preferred Option consultation version.

In respect of Stoke St Michael we are pleased that there is a recognition to deliver a greater proportion of the residual requirement for the village and that the previous allocation has been withdrawn. However, our concerns which were applicable to that site are similar to those for the new proposal. We have scrutinised this alternative and consider that it is not deliverable in its current form in respect of ecology and that no safe means of access can be provided. We would urge the Council to delete this allocation. We remain of the view that the LVA site at Coalpit Lane is highly deliverable and has already been tested by an earlier application. We suggest therefore that if the Council wishes to deliver the residual requirement for Stoke St Michael, the site at Coalpit Lane should be allocated.

Yours sincerely

Alex Bullock Associate e-mail: [email protected]

Page | 7

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

April 2019

For and on behalf of

Stoke St Michael LVA LLP

Project Ref: 4347

Trace Design Consultants Limited Transport and Civil Engineering

This page is intentionally blank for double sided printing

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

REPORT CONTROL

Trace Design Consultants Limited

3 Silverdown Office Park Fair Oak Close Exeter Devon EX5 2UX t. +44 (0) 1392 927717 www.trace-design.co.uk

e. [email protected] w. www.trace-design.co.uk

Report Title: Transport Analysis of Draft Site Allocation SSM009 File Location: \Active\4326-4350\4347 Stoke St Michael\Reps 19

Client: Stoke St Michael LVA LLP Project Number: 4347

Report Issued – V01: 14 March 2019 – Draft Report Issued – V02: 11 April 2019 – Final Report Issued – V03: 24 April 2019 – Final (with title amendment)

Prepared By: Samuel Davies Office: Exeter Checked By: Rafael Morant Approved By: Martin Brady

434 7 – 24 April 20 19 Page i

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

This page is intentionally blank for double sided printing

434 7 – 24 April 20 19 Page ii

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

CONTENTS

1 INTRODUCTION ...... 1 Site Locations ...... 2 Policy SS1a: Site SSM009 “Land East of Frog Lane” ...... 2 Land Adjacent to Coalpit Lane ...... 2 2 TECHNICAL ASSESSMENT ...... 3 Introduction ...... 3 Distance to Local Facilities and Amenities ...... 3 Land East of Frog Lane ...... 3 Land Adjacent to Coalpit Lane ...... 5 Pedestrian and Cycle Facilities ...... 7 Land East of Frog Lane ...... 7 Land Adjacent to Coalpit Lane ...... 9 Accessibility to Public Transport ...... 10 Land East of Frog Lane ...... 10 Land Adjacent to Coalpit Lane ...... 11 Highway Infrastructure ...... 11 Land East of Frog Lane ...... 11 Land Adjacent to Coalpit Lane ...... 13 Existing Traffic Conditions ...... 15 Potential for Highway Improvements ...... 16 Land East of Frog Lane ...... 16 Land Adjacent to Coalpit Lane ...... 17 Potential for Improvements to Pedestrian Access ...... 17 Land East of Frog Lane ...... 17 Land Adjacent to Coalpit Lane ...... 18 3 LOCAL POLICY ASSESSMENT ...... 19 Mendip District Council Local Plan Part II (Sites and Policies): Sustainability Appraisal Report ...... 19 Addendum to Sustainability Appraisal- Proposed Changes, January 2019 19 Mendip District Council - Planning Application 2016/3122/OTS ...... 20 Highways Authority Consultation Reply ...... 20 4 SUMMARY AND CONCLUSION ...... 22 Land East of Frog Lane ...... 22 Land Adjacent to Coalpit Lane ...... 23

FIGURES

Figure 1. Site Location Plans ...... 1 Figure 2. Frog Lane Site – Distances to Primary School ...... 4 Figure 3. Frog Lane Site – Distances to Village Centre ...... 5 Figure 4. Coalpit Lane Site – Distance to Primary School ...... 6 Figure 5. Coalpit Lane Site – Distance to Village Centre ...... 7 Figure 6. Carriageway Widths and Vehicles that Can Be Accommodated ...... 11 Figure 7. Frog Lane Carriageway Measurements ...... 12 Figure 8. Carriageway Widths along Tower Hill/Coalpit Lane ...... 14 Figure 9. Extent of HMPE in the Local Area ...... 16

434 7 – 24 April 20 19 Page iii

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

PLATES

Plate 1. Photo of Connection of SM18/47 to SM18/45 ...... 8 Plate 2. The Gradient of the Westernmost Section of SM14/18 ...... 9

TABLES

Table 1. Distance to Local Facilities – Frog Lane Site ...... 3 Table 2. Distance to Local Facilities – Coalpit Lane Site ...... 6 Table 3. AM Peak Traffic Count at Frog Lane/Stoke Hill Junction ...... 15 Table 4. AM Peak Traffic Count at Coalpit Lane/Tower Hill Junction ...... 15

APPENDICES

Appendix A: Extent of HMPE Land Appendix B: Copy of Registry Titles on Surrounding Sites along Frog Lane Appendix C: Mendip District Council Local Plan Part II (Sites and Policies): Sustainability Appraisal Report – Addendum to Sustainability Appraisal, Proposed Changes, January 2019 Appendix D: SCC HA and PRoW Officer Comments on Planning Application 2016/3122/OTS

434 7 – 24 April 20 19 Page iv

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

This page is intentionally blank for double sided printing

434 7 – 24 April 20 19 Page v

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

1 INTRODUCTION

Trace Design Consultants Limited have been commissioned by Stoke St Michael LVA LLP to undertake a Transport Analysis of Draft Site Allocation SSM009 in terms of deliverability of this site, which is allocated under Policy SS1a “Land East of Frog Lane” of the Mendip District Local Plan 2006-2029 to accommodate residential development. This site has been compared to an alternative site accessed off Coalpit Lane and available for development.

Figure 1. Site Location Plans

The site accessed off Frog Lane is known as HELAA site SSM009 and this is a new site which has replaced the previous site SSM008 “Land West of Frog Lane” and was allocated in the Local Plan as Policy SS1. The residential capacity of the site has been increased from 17 to 30 residential units.

This Transport Analysis has reviewed and compared the feasibility of the Frog Lane site to accommodate additional housing based on the existing highways infrastructure, distance to local facilities, pedestrian accessibility and the potential for improvements to achieve suitable access. These are then reviewed against the alternative option of the site accessed off Coalpit Lane and available for development.

Trace Design Consultants Limited as independent transport planning consultants have prepared this analysis providing what we consider is a fair and unbiased appraisal of the traffic and highways issues arising from the proposed development.

434 7 – 24 April 20 19 Page 1

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Site Locations

Policy SS1a: Site SSM009 “Land East of Frog Lane”

The allocated site is located on the western edge of the village and situated adjacent to the Stoke St Michael Playing field, which lies on the southern perimeter of the site. The site bounds the Stoke St Michael Primary School to the west. In all other directions there is agricultural land with Frog Lane running along the western perimeter of the site in a North-South orientation.

Land Adjacent to Coalpit Lane

The site is located on the eastern side of Coalpit Lane to the north of St Michael’s Close. Coalpit Lane runs along the western perimeter of the site in a North-South orientation, with a gated access located approximately 31m to the north of the property of Glenview. The northwestern boundary meets the property of Fairbanks.

434 7 – 24 April 20 19 Page 2

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

2 TECHNICAL ASSESSMENT

Introduction

This section provides a review of the conditions for the site accessed off Frog Lane in relation to transport. It includes a review of the site location and access to local facilities and amenities, a study of the existing local highway network and traffic conditions and the potential for pedestrian accessibility and improvements to highway network in order to accommodate the proposed residential units. This has then been compared to the same assessment undertaken for the site accessed off Coalpit Lane.

Distance to Local Facilities and Amenities

Land East of Frog Lane

The following Table 1 summarises the distance between the allocated site accessed off Frog Lane to these same facilities and amenities.

Distance from Distance from Service/Facility Location Site Site (Via PRoW)

Primary School Moonshill Road 1180m 670m

Church Church Street 785m 490m

Post Office Stoke Hill 650m 570m

Shops (Londis, Stoke Hill 650m 570m P&I Stores)

Public House Stoke Hill 620m 540m

Table 1. Distance to Local Facilities – Frog Lane Site

There are two primary ways of accessing the local facilities from the Frog Lane site, namely walking along Stoke Hill, or by the PRoW that provides a connection to Tower Close. It can be established that the journey to these facilities from this site takes place over a distance over 500m. The shortest distances are based on the use of PRoWs, which are not suitable to people with mobility impairment or in bad weather. The distances using the highway network are over 600m and based on long sections of road with no footways and people walking on the road.

434 7 – 24 April 20 19 Page 3

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Policy SS1a does not refer to the provision of a link between the site and the Primary School or Monshill Road, hence the distance shown in Table 1 despite the fact that the site is adjacent to the Primary School.

In the same way, Policy SS1a does not refer to the provision of new pedestrian links provided as part of the allocated development.

Figures 2 and 3 show the distances in a graphic way to the Primary School and the village centre respectively. The purple lines show the use of the PRoWs in the area while the red lines show the use of the carriageways and footways.

These Figures also show the extent of carriageway which would need to be used by residents due to the lack of footways and which would include circa 400m between the site and the Eldmere House bus stop accessed in Stoke Hill.

Figure 2. Frog Lane Site – Distances to Primary School

434 7 – 24 April 20 19 Page 4

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Figure 3. Frog Lane Site – Distances to Village Centre

Land Adjacent to Coalpit Lane

For comparison purposes, the same distances have been calculated for the site accessed off Coalpit Lane and available for development.

The majority of local facilities and amenities are located around the junction with Stoke Hill, Church Street and The Bridge – known as The Square. These facilities are located within a 5-minute direct walk from the site and would present residents with opportunities to fully benefit from the range of amenities that Stoke St. Michael has to offer without the need to use the car.

Table 2 summarises the same range of community facilities and their distance from the site in question.

434 7 – 24 April 20 19 Page 5

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Service/Facility Location Distance from Site

Primary School Moonshill Road 250m

Church Church Street 310m

Post Office Stoke Hill 430m

Shops (Londis, P&I Stores) Stoke Hill 430m

Public House Stoke Hill 460m

Table 2. Distance to Local Facilities – Coalpit Lane Site

This shows that the site accessed off Coalpit Lane is better positioned and offers considerably reduced walking distances to the main local facilities. Furthermore, the pedestrian routes avoid the use of carriageways (except for a few short section) and PRoWs and are considered to provide safer and more convenient routes for pedestrians.

Figures 4 and 5 show these distances in a graphic way.

Figure 4. Coalpit Lane Site – Distance to Primary School

434 7 – 24 April 20 19 Page 6

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Figure 5. Coalpit Lane Site – Distance to Village Centre

Pedestrian and Cycle Facilities

Land East of Frog Lane

Frog Lane has no pedestrian infrastructure during the entire section between the allocated site and the junction with Stoke Hill with a distance of approximately 250m and a further 150m on the western section of Stoke Hill up to the Eldmere House bus stop, with a total of 400m with no footways. Furthermore, this section of the road is subject to the 60mph (national) speed limit. The lack of frontage and destinations along this road makes walking unsuitable and unsafe, even more with the pinch point starting 100m to the north of the junction with Stoke Hill, and which does not allow for two vehicles passing each other.

The junction with Stoke Hill has restricted visibility splays and vehicles were observed to reverse when meeting each other. This would raise highway safety concerns, even more when considering children and people with mobility impairment walking along this section of road.

434 7 – 24 April 20 19 Page 7

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

An alternative option for pedestrians is the use of the PRoW footpath SM18/45 which intersects the playing field to the south of the site (and adjoins the PRoW SM18/14) allowing a segregated access to Stoke Hill (close to Stoke Crescent) to the south and Tower Hill (near the square) at 410m to the east.

The use of these footpaths is however not considered to be suitable for people with mobility issues owing to the lack of tarmac on the majority of these routes. Plate 1 taken from the SCC PRoW database shows footpath SM 18/14 looking west to the playing field.

The use of this route would also be unsuitable in bad weather for most of the people.

The existing conditions of the PRoWs (shown in Plates 1 and 2 as examples) would make it difficult for any improvements required to provide adequate and safe access for pedestrians. There would be a need to provide tarmac and street lighting and local landowners should grant permission for any improvements to be made.

Any change to PRoWs would also need to comply with policy standards, may bring about only very limited improvements in order to keep these routes as PRoWs and may raise significant issues in terms of costs and time.

The pedestrian accessibility to this site is therefore considered to be unsafe and not suitable to people with mobility impairment. There are legitimate reasons to argue that a safe and suitable access could be provided.

Plate 1. Photo of Connection of SM18/47 to SM18/45

434 7 – 24 April 20 19 Page 8

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

In addition, the connection of SM18/14 to Tower Close is indicated to have a steep gradient and is fitted with a handrail, as per the image extracted from the SCC Online PRoW interactive mapping platform.

Plate 2. The Gradient of the Westernmost Section of SM14/18

Land Adjacent to Coalpit Lane

Coalpit Lane forms a T-junction with Tower Hill (south), St. Michael’s Close (east) and Moonshill Road (west). North of the junction, Coalpit Lane has no pedestrian facilities for the short section of 50m that provides access to the site. To the south of this junction, there are 1.9m-wide footways present on both sides of the road.

65m to the south of this junction, the carriageway (now Tower Hill) becomes flanked by stone walls on either side. There is a short section of 45m with no footway provision even though on-street parking is allowed. Pedestrians were observed walking on the road to reach the footway on the opposing side of this section. Owing to the residential nature of this route, with multiple frontage, on-street parking, pedestrians walking and a 30mph vehicle speed limit applying on this section, walking on the carriageway was considered as safe.

The pedestrian facilities available to the south of the walled section on Tower Hill provide a connection to the rest of Stoke St. Michael’s footway network. Tower Hill continues 340m south to the centre of Stoke St. Michael, where it joins Stoke Hill running east-west and Mendip Road running north-south, meeting at a mini roundabout.

434 7 – 24 April 20 19 Page 9

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

The pedestrian infrastructure along this section is sporadic in nature, with the narrower sections of carriageway lacking in this provision, however, the low vehicle speeds resultant of the presence of these narrower sections and pedestrian movements create a safe environment for pedestrians and this was observed during the site visit.

Accessibility to Public Transport

Land East of Frog Lane

The closest bus stop from the site is located on Stoke Hill, at circa 400m from the site (Eldmere House/Veleathe). This stop supports the 469 School Service to Strode College. The closest bus stop supporting the main 162 service is located on The Bridge (as defined above) at 630m from the site via the SM18/14 PRoW to Tower Close or 735m via Stoke Hill. This distance is greater than that of the potential site off Coalpit Lane.

Pedestrian access to this bus stop is considered unsafe due to lack of footways along Frog Lane, lack of frontage and the 60mph speed limit that applies to this section. Any reduction in the vehicle speed limit would necessitate the approval of a Traffic Regulation Order. The following information has been extracted from the SCC website in their section “Apply for a new speed limit”:

“The standard speed limit in urban areas in 30mph, representing a balance between the mobility and safety of road users, especially more vulnerable groups. These are generally built-up areas where frontage development with individual accesses on both sides of the road exist, such as city streets, towns and residential areas. Hazards, such as junctions, inadequate visibility, pedestrian crossings, schools, recreation grounds and public amenities support the need for a 30mph limit and make it appear sensible to the motorist.”

It is clear that the existing conditions of Frog Lane do not comply with the general characteristics expected to apply a reduction to 30mph.

People are not likely to walk in the absence of improvements to either Frog Lane and Stoke Hill, or the PRoWs affected by the development, and this would result in the use of the car instead making the site unsustainable.

The use of the PRoWs surrounding the site are considered unsuitable for most people, especially those vulnerable and with mobility impairment.

434 7 – 24 April 20 19 Page 10

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Land Adjacent to Coalpit Lane

The closest bus stop from the site is located at Stoke Hill, at circa 400m from the site outside the Post Office. This stop supports the 469 School Service to Strode College. The bus stop located on the road named The Bridge, situated at 430m from the site, supports the 162 service from Shepton Mallet to Frome, at 4x daily intervals.

The bus stop is conveniently accessed by the footways provided along Tower Hill and Church Street.

Even though the footways are not continuous the walk is considered safe due to the low vehicle speeds of vehicles, pedestrian movements around this area and residential frontage on both sides of the road.

Highway Infrastructure

Land East of Frog Lane

On-site measurements were undertaken on the 05th March 2019. These were collected from the existing field access of the site up to the junction with Stoke Hill, at 20m intervals.

This showed that the carriageway has a variable width of between 3.9m and 5.9m (at a passing point). The critical section is the 100m-long section from the junction with Stoke Hill northbound with a carriageway width narrower than 4.1m, meaning that two cars are unable to pass each other following the MfS guidance as shown in Figure 6 below. This requires vehicles to stop and reverse at this section of road, sometimes back to the junction with Stoke Hill, as it was observed, and raising serious highway safety concerns.

Following this section, there is a maximum point 5.9m-wide which is a passing place located approximately 60m south of the sports ground access. 110m north of this location there is a pinch point of 4.4m in width which also restricts the passing of a car and a large vehicle. These measures are shown in Figure 7.

Figure 6. Carriageway Widths and Vehicles that Can Be Accommodated

434 7 – 24 April 20 19 Page 11

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Figure 7. Frog Lane Carriageway Measurements

434 7 – 24 April 20 19 Page 12

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Frog Lane meets Stoke Hill by a T-priority junction at 250m from the site. Visibility from this junction was measured as 35.2m to the west and 17.5m to the east from an ‘X’ distance of 2.4m. This would suffice for 85th percentile vehicle speeds of just 26.5mph for eastbound vehicles and 15mph for westbound vehicles as per the guidance in MfS.

These splays are obscured by a hedge and wall respectively on either side of the junction. It was noted during the on-site survey that a vehicle (car) was observed creeping 1.5m into the carriageway in order to achieve full visibility. Lack of adequate visibility splays at the junction means that vehicles usually have to reverse to let the westbound and eastbound flows pass raising highway safety concerns.

There seems to be a significant restriction in the extent of land which could be used to undertake improvements in this sense. This is discussed further in the following pages of this report.

Due to the 60mph vehicle speed limit, visibility splays complying with DMRB guidance may be required, which could result in visibility splays of up to 215m which are not considered to be achievable. Therefore, a Traffic Regulation Order would be required to bring the legal limit down to 30mph, which may or may not be approved. Still, there are serious doubts that appropriate visibility splays at this junction could be achieved even following MfS standards.

Furthermore, it was noted that during both the traffic survey and manual measurements carried out this route is frequently used by larger goods vehicles, which required a number of vehicles to reverse when a conflict between two vehicles passing each other arose, compounded by the width of the road.

Land Adjacent to Coalpit Lane

Coalpit Lane forms a T-junction with Tower Hill (south), St. Michaels Close (east) and Moonshill Road (west). On-site measurements every 20m were also undertaken on the 05th March 2019.

North of the junction, Coalpit Lane has a width of 5.0m-5.5m which allows comfortably for a car and a large vehicle to pass each other following the MfS guidance (Figure 7.1). At 65m to the south of this junction, the carriageway (now Tower Hill) becomes flanked by stone walls on either side, with the carriageway measuring up to 6.3m in width.

Following this section, the carriageway generally measures circa 6.3m in width, which allows for two large vehicles passing each other, with a narrowing to 4.3m just north of Bentleys Restaurant.

434 7 – 24 April 20 19 Page 13

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

There is a second pinch point to 4.4m on Tower Hill just after the northern side of the car park entrance junction of the Knatchbull Arms, however both of these two pinch points would allow for two cars passing each other. Following this, the carriageway width progressively increases to 9.5m toward the mini roundabout.

Following the guidance in MfS, these widths would allow for 2 cars to pass each other along the entire length of Tower Hill/Coalpit Lane and, with exception to the pinch points, would allow for a car and a large vehicle to pass each other up to the site boundary.

The existing carriageway widths along this route are shown in Figure 8.

Figure 8. Carriageway Widths along Tower Hill/Coalpit Lane

434 7 – 24 April 20 19 Page 14

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Existing Traffic Conditions

In order to assess the present operating conditions on both Land East of Frog Lane and Land Adjacent to Coalpit Lane traffic counts were undertaken at the junctions closer to each of the sites on the 05th of March 2019 for the AM peak period (08:00 – 09:00) at the junction of Fosse Road/Frog Lane/Stoke Hill, and at the junction of Tower Hill/Moonshill Road/St Michael’s Close/Coalpit Lane respectively. These are shown in Tables 3 and 4.

Table 3. AM Peak Traffic Count at Frog Lane/Stoke Hill Junction

Table 4. AM Peak Traffic Count at Coalpit Lane/Tower Hill Junction

The above tables show a similar number of traffic flows at the two junctions, with a total of 112 movements in Table 3 and 139 in Table 4.

More importantly, this number is also similar for vehicle trips travelling northbound and southbound along Frog Lane and Coalpit Lane, with a total of 60 and 71 vehicles trips respectively.

However, it is noted that while only 1 heavy goods vehicle was counted travelling along Coalpit Lane, up to 7 were counted along Frog Lane, which represented 1.4% and 11.7% of all traffic flows respectively. These percentages emphasise the use of Frog Lane as a through route with a major impact caused by heavy traffic.

434 7 – 24 April 20 19 Page 15

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

It is considered that the existing traffic conditions along Coalpit Lane are more suitable for residential uses, owing to a significantly lower number of heavy vehicles using a comparatively wider carriageway.

Potential for Highway Improvements

The plan shown in Figure 9 identifies the land designated as Highways Maintainable at Public Expense for the relevant study area. This is included as Appendix A to this report.

Figure 9. Extent of HMPE in the Local Area

Trace Design obtained the HMPE plan from SCC for the site and surroundings in order to assess any constraints that could compromise appropriate delivery of access to the site due to the potential restrictions caused by third-party land.

Land East of Frog Lane

The HMPE Plan shows that Frog Lane is constrained by third-party land and that the main section with restricted carriageway width for approximately 100m leading to the junction with Stoke Hill would not be able to fit two vehicles passing each other. This would also result in the substandard visibility splays provided at this junction with no potential for improvement based on the availability of highways land.

434 7 – 24 April 20 19 Page 16

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

These findings have been corroborated by the registry titles obtained for the surrounding sites along Frog Lane. These are included as Appendix B to this report.

Land Adjacent to Coalpit Lane

Coalpit Lane and Stoke Hill present an adequate route taking into account the volume and nature of existing traffic flows, as well as those generated by the proposed development and no improvements would be considered as two vehicles can pass each other comfortably.

Potential for Improvements to Pedestrian Access

Land East of Frog Lane

The site accessed off Frog Lane has no footway connection to the rest of the village. The HMPE Plan shows that there is no highways land available to provide a footway along Frog Lane connecting the site to Stoke Hill. Furthermore, the 100m-long restricted section approaching the junction to Stoke Hill severely restricts any improvement in this sense.

There are also additional constraints on Stoke Hill, with no additional land available outside of the highway surface to provide a footway, which would, therefore, require narrowing in such an instance and would not be welcome as this is the main road providing access to the village.

In addition to this, the use of Frog Lane as a through route with large percentage of heavy traffic and the enforced limit of 60mph along this route would make the prevailing conditions unsuitable for pedestrians and cyclists and would represent a serious safety concern.

The only alternative would be the use of the PRoW SM 18/5, which would be highly unlikely to result in an appropriate access to people with mobility impairment, or to most pedestrians with bad weather and wet surface.

These findings are corroborated by the HMPE Plan and registry titles included as Appendices A and B to this report respectively and confirm the constraint related to highways land available to provide the necessary improvements that would allow the provision of a safe and suitable access as per Paragraph 108 of the NPPF, which also refers to the provision of appropriate opportunities to promote sustainable transport modes and which the proposed development not comply with.

434 7 – 24 April 20 19 Page 17

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Land Adjacent to Coalpit Lane

In the case of pedestrian access along Tower Hill/Coalpit Lane, the existing infrastructure is considered adequate to provide for pedestrians.

The existing highway verges located on the western side of Coalpit Lane leading to the site provide a potential for the provision of pedestrian footways connecting the site with the footway connections at the junction of Coalpit Lane with Stoke Hill.

The width of the carriageway on the walled section to the south of the junction of Coalpit Lane, Moonshill Road, Tower Hill and St Michael’s close is up to 6.3m wide. This allows for potential footway improvements along this section while allowing enough carriageway width for vehicles passing each other.

Furthermore, a PRoW SM 18/5 that crosses the site is linked to both Mill Lane and PRoW SM 18/22 providing alternative pedestrian routes, which further enhance the availability of pedestrian routes provided for this site.

434 7 – 24 April 20 19 Page 18

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

3 LOCAL POLICY ASSESSMENT

Mendip District Council Local Plan Part II (Sites and Policies): Sustainability Appraisal Report

Addendum to Sustainability Appraisal- Proposed Changes, January 2019

The following paragraphs provide relevant information extracted from this document (which is included as Appendix C to this report) regarding the suitability of the Land East of Frog Lane to accommodate additional residential housing based on highways and transport matters:

Site Reference SS1a: Land East of Frog Lane

“Land east of Frog Lane, north of the recreation ground

Capacity 30

The site is well related to the village and accessible to facilities. It is adjacent to the village school and the village recreation ground on 2 sides. Landscape impact would need to be assessed and mitigation measures put in place. The site could provide for the residual housing requirement in the village and some additional homes above minimum requirement. The deliverability of the site would need to be confirmed by on site investigation as concerns remain about the impact on wildlife and ground water protection.”

It has been clearly established in this report about the restricted carriageway width providing access to Frog Lane, with the significant pinch point on the proximity to the junction with Stoke Hill, with not enough width to accommodate two vehicles passing each other for at least 100m, and with substandard visibility splays at this junction. This has been confirmed by the HMPE Plan and Registry Title records for the surrounding sites.

The fact that this is within a 60mph vehicle speed limit would have a significant impact in terms of visibility splays from the site access and would need the approval of a Traffic Regulation Order to reduce vehicle speeds to 30mph. This could be rejected due to the lack of residential frontage along this road.

It has also been established that the PRoW present across the sports ground is only suitable for able-bodied individuals and during agreeable weather and that the distance to the local facilities and amenities is larger than that of Coalpit Lane.

434 7 – 24 April 20 19 Page 19

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

Required improvements for the PRoWs to be able to provide adequate pedestrian access would need the permission of a number of land owners, the provision of street lighting and tarmac plus additional works and facilities which may not be able to be delivered because of the nature related to PRoWs.

Mendip District Council - Planning Application 2016/3122/OTS

The following paragraphs provide relevant information extracted from this Planning Application (which is included as Appendix D to this report) regarding the suitability of the Land Adjacent to Coalpit Lane to accommodate additional residential housing based on highways and transport matters:

Site Reference: Land Adjacent to Coalpit Lane

This was an outline application (all matters reserved except access) for residential development for up to 36 units with associated open space and infrastructure.

Highways Authority Consultation Reply

The Highways Authority issued his comments on the 08th of February 2017 for the proposed residential development of Planning Application 2016/3122/OTS for the same site (which is included as Appendix D to this report) in which the Highways Authority stated that had no objection to the proposed development. His response was also clear about the site location being acceptable and that the traffic generated by the site would not have a severe impact on the local highway network and that it would not cause a highway safety concern.

The assessment into the distances between the two sites and the local facilities and amenities has shown that the site accessed off Frog Lane is located between 200m and 500m further away from the local facilities and amenities than the site accessed off Coalpit Lane. It was found that the site, on the whole, is a large degree more accessible due to the existing footways, linear route and surrounding residential environment. It should be considered that the Frog Lane site is in a more peripheral and less-accessible location overall.

This report has also shown that, as per the findings in the HMPE plan, there is scope to provide a more connected footway arrangement by the use of highway verges up to the junction with Tower Hill and hence provide a connection to the local pedestrian infrastructure.

434 7 – 24 April 20 19 Page 20

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

It has been established from the traffic survey undertaken as part of this assessment that the existing traffic flows along Coalpit Lane are relatively low at the AM peak hour and just slightly larger than those along Frog Lane. It was observed that the traffic flowed freely and no congestion or safety concerns were identified.

Only 1 heavy goods vehicle was counted at this traffic survey, which resulted in a 1.4% of the total traffic flows. This percentage was significantly smaller than the 11.7% counted along Frog Lane.

The existing carriageway widths and visibility splays were assessed and compared. These showed that the routes to the site accessed off Coalpit Lane were much more suitable to accommodate the additional traffic than the routes providing access to Frog Lane.

Finally, the PRoW Officer was also consulted for the same Planning Application and, it stated that there were no objections to the proposed development on his comments issued on the 16th of January 2017.

434 7 – 24 April 20 19 Page 21

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

4 SUMMARY AND CONCLUSION

Land East of Frog Lane

This report has shown that the site SSM009, which has been allocated under Policy SS1a of the Mendip District Council Local Plan II “Land East of Frog Lane” is not suitable in transport and highway terms. The proposal for development of the site does not comply with Paragraph 108 of the NPPF, which states the following:

“108. In assessing sites that may be allocated for development in plans, or specific applications for development, it should be ensured that:

a) appropriate opportunities to promote sustainable transport modes can be – or have been – taken up, given the type of development and its location;

b) safe and suitable access to the site can be achieved for all users; and

c) any significant impacts from the development on the transport network (in terms of capacity and congestion), or on highway safety, can be cost effectively mitigated to an acceptable degree.

In order to reach the local facilities people would need to walk on PRoWs for more than 500m, which would not be suitable for people with mobility impairment and would not be suitable at all at dark or in bad weather; or use the carriageway for over 600m, of which at least 400m have no footway and people would need to walk on sections of road with pinch points, substandard visibility splays at junctions and with speed limits of 60mph. Both options raise serious safety concerns. It is clear that the site does not provide a safe and suitable access for all users and it would not promote the use of sustainable transport modes.

In terms of vehicular access the southern section of Frog Lane leading to Stoke Hill has a 100m-long section with a carriageway width narrower than 4.1m, meaning that two cars are unable to pass each other following the MfS guidance. This requires vehicles to stop and reverse at this section of road, sometimes back to the junction with Stoke Hill, as it was observed, and raising serious highway safety concerns. The visibility at the junction Frog Lane and Stoke Hill is also sub-standard with visibility splays obscured by a hedge and wall respectively on either side of the junction and vehicles were observed creeping 1.5m into the carriageway in order to achieve full visibility.

434 7 – 24 April 20 19 Page 22

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

The HMPE Plan and the Registry Titles for the surrounding sites show that there is a significant constraint raised by the lack of highways land that could be used to provide the necessary improvements that would be required in terms of provision of pedestrian facilities and wider carriageway width with adequate visibility splays. This is contrary to point c) of Paragraph 108 of the NPPF as the impact from the development could not be cost effectively mitigated to an acceptable degree, especially on highway safety.

Furthermore, any changes to speed limits and improvements to PRoWs would require Traffic Regulation Orders and other matters which would be conditional and would likely comprise a long time and high cost to achieve.

This shows that the proposed development will not comply with Paragraph 109 from the NPPF, which states that “Development should only be prevented or refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.” It is therefore considered that the site is not suitable for development based on the NPPF and as it has been shown in this report.

Land Adjacent to Coalpit Lane

The site accessed off Coalpit Lane, and which is available for development, has been shown the following:

• The site is in a sustainable location, within close distance to the local facilities, which can easily and conveniently be reached by adequate pedestrian facilities provided on residential environment with low vehicle speeds.

• The site is accessed by a wider highway network, which allows for two vehicles to pass each other at all times, and with ample capacity to accommodate the new traffic generated by the proposed development. Coalpit Lane also has a significantly lower volume of heavy goods traffic compared to Frog Lane.

• The site has the potential to provide adequate pedestrian facilities which would complement those already provided locally. The land would also provide adequate carriageway width and visibility splays.

434 7 – 24 April 20 19 Page 23

Comparison Assessment with Site Accessed off Coalpit Lane, Stoke St Michael Transport Analysis of Draft Site Allocation SSM009

The development of the site would comply with Paragraphs 108 and 109 as it would:

• Provide a safe and suitable access to everybody

• Promote the use of sustainable modes of transport

• Show that the impact from the development can be cost effectively mitigated due to the location of the site on a local and highways context and availability of land to provide the necessary improvements.

• Show that the residual cumulative impacts of the development would not be severe on the road network.

434 7 – 24 April 20 19 Page 24

APPENDIX A

Extent of HMPE Land

Stoke St Michael

Somerset County © Crown copyright and database rights 2019 OS 100038382. You are granted a Council 1:2500Scale: non-exclusive, royalty free, revocable licence solely to view the Licensed Data County Hall Centre:366467, 147182 for non-commercial purposes for the period during which Somerset County Taunton Council makes it available. You are not permitted to copy, sub-license, distribute, TA1 4DY Date produced:2019-03-06 13:19:12 sell or otherwise make available the Licensed Data to third parties in any form. 0300 123 2224 Third party rights to enforce the terms of this licence shall be reserved to OS.

APPENDIX B

Copy of Registry Titles on Surrounding Sites along Frog Lane

Title Number : WS27025 This title is dealt with by Land Registry, Weymouth Office. The following extract contains information taken from the register of the above title number. A full copy of the register accompanies this document and you should read that in order to be sure that these brief details are complete. Neither this extract nor the full copy is an 'Official Copy' of the register. An official copy of the register is admissible in evidence in a court to the same extent as the original. A person is entitled to be indemnified by the registrar if he or she suffers loss by reason of a mistake in an official copy. This extract shows information current on 14 DEC 2015 at 15:32:01 and so does not take account of any application made after that time even if pending in the Land Registry when this extract was issued.

Title Number : WS27025

Address of Property : land on the east side of Frog Lane, Stoke St Michael, Radstock

Price Stated : Not Available

Registered Owner(s) : HERBERT JIM FRANCIS, MARGARET LORRAINE FRANCIS, CHRISTOPHER JOHN FRANCIS and JAMES ROBERT FRANCIS of Manor Farm, Hemington, Bath Somerset.

Lender(s) : None

1 of 3 Title number WS27025 This is a copy of the register of the title number set out immediately below, showing the entries in the register on 14 DEC 2015 at 15:32:01. This copy does not take account of any application made after that time even if still pending in the Land Registry when this copy was issued. This copy is not an 'Official Copy' of the register. An official copy of the register is admissible in evidence in a court to the same extent as the original. A person is entitled to be indemnified by the registrar if he or she suffers loss by reason of a mistake in an official copy. If you want to obtain an official copy, the Land Registry web site explains how to do this.

B: Proprietorship Register This register specifies the class of title and identifies the owner. It contains any entries that affect the right of disposal. Title absolute 1 (17.05.2004) PROPRIETOR: HERBERT JIM FRANCIS, MARGARET LORRAINE FRANCIS, CHRISTOPHER JOHN FRANCIS and JAMES ROBERT FRANCIS of Manor Farm, Hemington, Bath Somerset. 2 (17.05.2004) RESTRICTION: No disposition by a sole proprietor of the registered estate (except a trust corporation) under which capital money arises is to be registered unless authorised by an order of the court.

C: Charges Register This register contains any charges and other matters that affect the land. 1 (26.11.2001) The land in this title is subject to the rights reserved by a Conveyance thereof and other land dated 19 June 1920 made between (1) Daisy Susan Green and (2) Ellen Emery.

NOTE 1: Neither the original Indenture dated 6 December 1899 nor a certified copy or examined abstract thereof was produced on first registration

NOTE 2: Copy filed. 2 (07.05.2003) The parts of the land affected thereby are subject to the following rights granted by a Transfer of the land tinted pink on the filed plan dated 17 April 2003 made between (1) Herbert Jim Francis and others and (2) McIntosh Homes Limited.

"The following right is granted for the benefit of the Property

The right to enter upon the Retained Land upon giving reasonable notice to the occupiers of the land entered (save in the case of emergency) for the purpose of constructing maintaining repairing and renewing the fence mentioned in this transfer making good damage caused and paying

2 of 3 Title number WS27025 C: Charges Register continued compensation."

NOTE: The fence referred to affects the northern and western boundaries of the land transferred.

End of register

3 of 3 This is a copy of the title plan on 14 DEC 2015 at 15:32:02. This copy does not take account of any application made after that time even if still pending in the Land Registry when this copy was issued.

This copy is not an 'Official Copy' of the title plan. An official copy of the title plan is admissible in evidence in a court to the same extent as the original. A person is entitled to be indemnified by the registrar if he or she suffers loss by reason of a mistake in an official copy. If you want to obtain an official copy, the Land Registry web site explains how to do this.

The Land Registry endeavours to maintain high quality and scale accuracy of title plan images.The quality and accuracy of any print will depend on your printer, your computer and its print settings.This title plan shows the general position, not the exact line, of the boundaries. It may be subject to distortions in scale. Measurements scaled from this plan may not match measurements between the same points on the ground.

This title is dealt with by Land Registry, Weymouth Office. The electronic official copy of the register follows this message.

Please note that this is the only official copy we will issue. We will not issue a paper official copy. Title number WS14110 Edition date 20.12.2018

This official copy shows the entries on the register of title on 10 APR 2019 at 14:34:03. This date must be quoted as the "search from date" in any official search application based on this copy. The date at the beginning of an entry is the date on which the entry was made in the register. Issued on 10 Apr 2019. Under s.67 of the Land Registration Act 2002, this copy is admissible in evidence to the same extent as the original. This title is dealt with by HM Land Registry, Weymouth Office.

A: Property Register This register describes the land and estate comprised in the title. SOMERSET : MENDIP 1 (26.11.2001) The Freehold land shown edged with red on the plan of the above Title filed at the Registry and being Moons Hill Farm, Edford Hill, Stoke St Michael, Shepton Mallet. 2 (26.11.2001) There are excluded from this registration the mines and minerals excepted by the Conveyance dated 19 June 1920 referred to in the Charges Register. 3 (28.07.2006) The land edged and numbered in green on the title plan has been removed from this title and registered under the title number or numbers shown in green on the said plan. 4 (28.07.2006) The land has the benefit of the rights reserved by but is subject to the rights granted by a Transfer of the land edged and numbered WS37167 in green on the title plan dated 28 April 2006 made between (1) Margaret Lorraine Francis Herbert Jim Francis Christopher John Francis and James Robert Francis and (2) John Scott Builder (Somerset) Limited.

¬NOTE: Copy filed under WS37167

B: Proprietorship Register This register specifies the class of title and identifies the owner. It contains any entries that affect the right of disposal. Title absolute 1 (26.11.2001) PROPRIETOR: HERBERT JIM FRANCIS, MARGARET LORRAINE FRANCIS, CHRISTOPHER JOHN FRANCIS and JAMES ROBERT FRANCIS of 278, Hemington, Radstock BA3 5XX. 2 (26.11.2001) RESTRICTION: No disposition by a sole proprietor of the land (not being a trust corporation) under which capital money arises is to be registered except under an order of the registrar or of the Court.

1 of 2 Title number WS14110 B: Proprietorship Register continued 3 (26.11.2001) The value stated as at 26 November 2001 was £110,000. 4 (20.12.2018) RESTRICTION: No disposition of the part of the registered estate shown tinted blue on the title plan by the proprietor of the registered estate is to be registered without a written consent signed by the proprietor for the time being of the Charge dated 18 December 2018 in favour of HSBC UK Bank PLC referred to in the Charges Register. 5 (20.12.2018) The proprietor's address for service has been changed.

NOTE 1: Neither the original Indenture dated 6 December 1899 nor a certified copy or examined abstract thereof was produced on first registration

¬NOTE 2: Copy filed under WS27025. 2 (26.11.2001) The parts of the land affected thereby are subject to the following rights granted by a Conveyance of the land tinted brown on the filed plan dated 25 July 1989 made between (1) Douglas Walter Lydford and others (Vendors) and (2) Fernley William Roch and Linda Muriel Roch (Purchasers):-

"TOGETHER WITH the easements rights and privileges mentioned in the Second Schedule hereto

THE SECOND SCHEDULE before referred to

Rights and easements granted to the Purchasers

(a) A right of way at all times in connection with the property until the Purchasers shall have constructed an alternative access directly to and from the property from and to the highway to pass and repass over the adjoining land of the Vendors shown coloured green on the said plan on foot with animals and with agricultural equipment and vehicles

(b) The passage and running of water to the trough on the property through the water pipes laid under the adjoining land of the Vendors subject to the Purchasers paying to the Local Water Authority for the water supplied to the trough and repairing and maintaining (jointly with the Vendors where the same serve troughs on the Vendor's adjoining land) the water pipes leading to the said trough

i. Maintaining a reasonable surface upon the land coloured green on the plan

ii. Inspecting repairing maintaining and renewing the pipes leading to the water trough upon the Property making good damage thereby caused"

NOTE: No green colouring referred to was shown on the plan lodged on first registration. 3 (20.12.2018) REGISTERED CHARGE of the land tinted blue on the title plan dated 18 December 2018 affecting also other titles. NOTE: Charge reference WS14110. 4 (20.12.2018) Proprietor: HSBC UK BANK PLC (Co. Regn. No. 9928412) of Securities Processing Centre, P.O. Box 6304, Coventry CV3 9JY.

End of register

2 of 2

Mendip Local Plan Part II: Sites & Policies – Pre-Submission Consultation

Consultation Response Form Please use this form to respond or make representations on Local Plan Part II and associated consultation documents. For information or advice, please contact the Planning Policy Team by email at [email protected] or phone (0300) 303 8588.

Contact Details If you have appointed somebody to act as your agent, please give their contact details. All correspondence will be sent to the agent Name: Mr MW Francis (landowner) Agent Name: Lee Wright c/o Mr W Francis (son) Company Name: Wright Consult LLP Organisation (if applicable):

Address: Bay Tree, Cooks Lane, West

Cranmore, Shepton Mallet, Somerset

Postcode: BA4 4RH

Email: [email protected]

Date Completed: 02.02.2018

Do you wish to be notified of future stages of Local Plan Part II (tick box) Ö Öaa We will contact you by e-mail only unless you confirm here (tick box)

Data protection – please read - The information collected as part this consultation will be processed by the Council in accordance with the Data Protection Act 1998. The purposes for collecting this data are: to assist in plan making; and to contact you, if necessary, regarding the planning consultation process. Please note that representations must be attributable to named individuals or organisations at a postal address. Representations and contact names will be published on the Mendip website but no other personal information Copies of this form are available from Council Offices and Access Points or can be downloaded from www.mendip.gov.uk/localplanpart2 . If you require this document in another format such as Braille, large print or another language then please contact us.

Please use a separate form for each site or main issue you wish to make. You can also attach one contact form to a group of representations. Please make sure any separate documents include your name –so they can be clearly identified.

Please return your response by 5pm Monday 12th February 2018. By post to: Planning Policy, Mendip District Council, Cannards Grave Road, Shepton Mallet, Somerset, BA4 5BT By email to: [email protected] By hand to: The Council offices in Shepton Mallet (address above).

Mendip Local Plan Part II: Sites & Policies - Issues and Options Consultation For office use

Details of Objection/ Comment./Representation

Name /Organisation: Lee Wright of Wright Consult LLP, on behalf of landowner Mr MW Francis

Please indicate the document to which your representation relates (e.g. policy, paragraph SSM008 – Land West Of Frog Lane number, HELAA site reference)

Do you consider the Local Plan is Legally Do you consider the Local Plan is Sound 1 ? 1 Compliant? Yes Ö No Yes No. Ö

Do you consider it necessary to participate at examination hearings? (eg present oral Yes evidence)

Please provide details below of why you consider the Local Plan is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance and soundness of the plan, please also use this box to set out your comments.

HELAA Site Number SSM008 - Land West Of Frog Lane, Stoke St Michael

1. Introduction & Summary This site has been allocated in the Pre-Submission Consultation, having previously been put forward by the landowner.

The Mendip Local Plan Part II Pre-Submission Consultation, Housing and Employment Allocations Section 11. Primary and Secondary Villages; states:

‘11.24.3 Local Plan Part I designated Stoke St Michael as a Primary Village. It is expected to deliver a minimum of 45 new homes and to date, 12 houses have built and a further 3 granted permission or under construction. Given the residual requirement for 30 houses in the village, it is considered that an allocation would be appropriate.

• Site SSM008 to be allocated for residential development for up to 17 homes under Policy SS1.’

In addition: The Local Plan Part II: Pre-submission stage Sustainability Appraisal, Appendix 5: Results of Sustainability Appraisal of sites in settlements where an allocation is required; states:

‘Site suitable for development. Whilst this site was put forward during the issues and options consultation and therefore not published for comment, the Parish Council state that it is the west side of the village which is served by the wider road network and although this is not an ideal solution it is the option with the least practical limitations for the village. It is relatively well located to village facilities and could potentially link to footpaths across the recreation field to the Primary School. It would impact on the setting on the eastern edge of the village to a certain extent, although the site is currently bounded by tall mature trees and hedging and the site is very flat, so potentially not as significantly intrusive as development in other parts of the village. However, there are a number of additional concerns and considerations relating to this site which will need to be addressed, including impact

1 See our Online Guidance note on what these terms mean 2

Mendip Local Plan Part II: Sites & Policies - Issues and Options Consultation on protected species and nearby wildlife sites, surface water flooding and impact on heritage assets.’

2. Comments The landowner who is a long time resident of the village and who lives and farms adjacent to the site, wishes to confirm that they still wish for the land to be allocated and are pleased to see the council put the site forward in the Pre-Submission Consultation.

The landowner has noted the suggested policy through SS1 that underlines sensible design principles of which they are supportive; and also note a positive Sustainability Assessment. Through these design principles, development impacts such as ecology, flooding and groundwater protection can be addressed.

Development in this location is favourable to the Parish Council who wish to see development on the west of the village and this is logical given highway network and traffic considerations and it will ‘round off’ development with existing housing and the recreation ground and present limited impacts on the wider village. END OF COMMENTS – TOTAL 3 PAGES

These are the notes referred to on the following official copy

The electronic official copy of the title plan follows this message.

Please note that this is the only official copy we will issue. We will not issue a paper official copy.

This official copy was delivered electronically and when printed will not be to scale. You can obtain a paper official copy by ordering one from HM Land Registry.

This official copy is issued on 10 April 2019 shows the state of this title plan on 10 April 2019 at 14:01:18. It is admissible in evidence to the same extent as the original (s.67 Land Registration Act 2002). This title plan shows the general position, not the exact line, of the boundaries. It may be subject to distortions in scale. Measurements scaled from this plan may not match measurements between the same points on the ground. This title is dealt with by the HM Land Registry, Weymouth Office . This official copy is incomplete without the preceding notes page.

APPENDIX C

Mendip District Council Local Plan Part II (Sites and Policies): Sustainability Appraisal Report – Addendum to Sustainability Appraisal, Proposed Changes, January 2019

Mendip District Council Local Plan Part II (Sites & Policies)

Sustainability Appraisal Report

Addendum to Sustainability Appraisal- Proposed Changes January 2019

Contents Page 1. Introduction

2. Assessment of additional sites in Proposed Changes

3. Proposed Changes to Policies and Local Green spaces

4. Representations relating to the SA

5. Review of SA of Housing numbers options 1 and 2

6. Conclusion

Appendix 1 – Sustainability Appraisal Objectives

Supporting Documents (published separately)

Revised - Appendix 6; revised following representations

Introduction

1 Sustainability appraisal (SA) is a systematic process undertaken during the preparation of the plan. The role of SA is to assess the extent to which emerging policies and proposals help to achieve relevant social, economic and environmental objectives. It provides an opportunity to consider ways in which the plan can contribute to improving social, economic and environmental conditions and as well as a means of identifying and addressing any adverse effects.

2 The SA process is iterative and informs the development of the plan. It is therefore appropriate to update the SA in the light of changes suggested to the plan following pre-submission consultation. Several comments have also been received as a result of pre-submission consultation concerning the SA methodology. These are also addressed in this document.

Assessment of additional sites put forward in Proposed Changes

3 Local Plan Part 2 is primarily concerned with allocating sites to deliver the housing and employment land outlined in Local Plan Part 1. It therefore focusses on the SA of potential sites. As a result of pre submission consultation the following additional land or housing has been put forward.

Table 1: changes to sites which result in additional land or housing, following pre-submission consultation

Settlement Site ref Site address Change Glastonbury GL4 Lintells Garage Increase site area to include workshops and increase housing numbers from 8 to 25 Street ST1 West of Somerton Increase housing numbers from 200 Road to 280 Wells WL2 Wells Rugby Club Increase housing numbers from 60 to 80 Wells WL5 Elm Close Include site as a housing allocation rather than as a FGA Draycott DR1 Land at Westfield Include 2 bungalows off Cross Farm Lane Road to allow a route for access Nunney NN1 Land at Green Pts Increase housing numbers from 50 lane to 70 Stoke St Michael SS1a Lane east of Frog New site replacing land West of Frog Lane/north of the lane recreation ground

It is also proposed to delete the sites show in the following table;

Table 2; sites it is proposed to delete following pre-submission consultation settlement Site ref Site address Reason for Change Frome FR6 Land at Innox Hill The draft allocation promotes this site for an ‘exemplar’ self and custom build development which was judged to outweigh against the poor sustainability assessment of the location. However the site is subject to an in principle objection from Wessex Water relating to nuisance from the sewage treatment works which cannot be overcome. In addition, the extent to which the ‘exemplar’ scheme can be achieved is compromised by the sensitivity of the site in terms of landscape, biodiversity impacts and site characteristics. Although self and custom build is strongly supported by the Town Council, they have objected the suitability of this site. Deletion of this site would also accord with the sustainability appraisal assessment Croscombe CR1 Land at Fayreway Independent Highways advice at site CR1 is that the access put forward for the site does not have sufficient width to accommodate an adoptable carriageway. There is no indication that third party land would be available.

The site does not have a satisfactory vehicle access and should be deleted. Doulting DU1 Land at Doulting The site presents a significant risk of sterilising an active minerals permission. Residential development (on any scale) is not compatible with quarrying activity and close proximity is likely to give rise to complaint under typical reasonable quarrying operations. As such, this puts the quarrying activity at considerable risk of sterilisation. Restrictions on quarrying operations are most likely to occur if users of a new development find cause to complain about noise. Stoke St Michael SS1 Land west of Frog The site adjacent to the playing fields lane was put forward at pre-submission consultation stage. The site is better related to the village, has better access

to the footpath network, making it more accessible to village facilities on foot and is larger, so is able to accommodate a higher proportion of the village's residual requirement. It represents a better option to meet the village's housing requirements within a plan led system. It is proposed to delete site SS1 and allocate site SS1a east of Frog Lane and north of the playing fields.

4 A number of small adjustments or reductions in size of housing or employment sites have also been put forward, but these are not of such significance that they are likely to alter the conclusions of the SA and are not included here.

5 Appendix 5 of the SA sets out the results for settlements where allocations are needed. In order to update Appendix 5 each of the sites where additional land or housing is proposed have been reassessed. The SA results are below. The reassessment resulted in only minor changes to the assessment for GL4. The rest remain unchanged. Site SS1a is a new site.

Definitions of the SA objectives are included as Appendix 1.

GL4 - ± + ± ± ± ± + + + + ± + + Lintells Garage and workshops Potentially suitable for redevelopment. to the rear, The site is well integrated with the existing urban form and lies in very close proximity to bus stops on Glastonbury Wells Road and within a reasonably close proximity to the town centre and amenities. In fact, well- designed redevelopment of this site may actually enhance the street scene here. The site is currently in employment use and so the impacts of the loss of this space should be considered, however, the occupier currently has permission for a showroom and workshops on an alternative site. Likewise, the site is designated as contaminated land and noise mitigation measures will need to be considered as the site adjoins a haulage yard.

Capacity 25

ST1 ± ± - - - - ± ± - + ± + + - Land to west of Somerton Site potentially suitable for development. Road Subject to consideration of the identified constraints. This site would not impact on segregation between Walton and Street Villages and is reasonably well related to the existing built up area of Street and close to bus links. That said, the site does lie some distance from core facilities and appropriate linkages will need to be considered. Likewise, whilst adjacent to existing development, this land would need to be developed sensitively to the rural nature of this edge of Street and be sensitive to the landscape character of the neighbouring conservation area. Capacity 280

WELLS084 ± - - - - ± - ± + - - ± + + ± + Land south of Site suitable for development Elm Close, The site is potentially suitable for development, although it is on the edge of Wells and not as accessible as Wells other sites to town centre facilities. Development would represent an extension into the countryside although there are opportunities to provide some community gain through affordable housing and Capacity 145 provision of land to extend the cemetery.

WL2 ± ± ± - ± ± ± - + + + + - Wells Rugby Site suitable for development Club This is a greenfield site within the urban area which is accessible to the town centre and local facilities, The land is suitable for housing subject to the re-provision of club and pitches. A traffic impact assessment will be needed and may constrain the overall capacity of the site as it is accessed through surrounding Capacity 80 residential areas

DR1 ± ± - ± - - ± ± + + ± + + + Westland Site suitable for development. House, The site is well related to the village and accessible to most village facilities. It is enclosed by development Westfield Lane on 3 sides and is visually well contained and is not prominent in the landscape. The site could provide for the residual housing requirement in the village. Traffic generation and access will need to be carefully considered and the removal of one or two buildings will be needed to gain access.

Capacity 32

NN1 ± - - ± - ± ± ± + ± + + ± Land at Site is suitable for development. Green Pitts Suitable subject to consideration of the identified constraints. The site would form a logical continuation of Lane, Nunney development to the south of the village, although the site would be relatively removed from village facilities. That said, the village has a historic core with a number of Listed Buildings, a Conservation Area, Area of High Archaeological Potential and Scheduled Ancient Monument (Nunney Castle) and so this site’s relatively peripheral position is positive in terms of the limited impact upon the village’s heritage assets. However, consideration will need to be given to the appropriate scale of development in relation to the size and context of settlement and likewise provision of adequate safe access onto and into the site by various modes of transport will be important. Concerns have also been raised about drainage and protection and Capacity 70 easement of the existing sewer will also be needed.

SS1a ± - - ± - - - - ± ± + ± + + + Land east of The site is well related to the village and accessible to facilities. It is adjacent to the Frog Lane, village school and the village recreation ground on 2 sides. Landscape impact would north of the recreation need to be assessed and mitigation measures put in place. The site could provide for the ground residual housing requirement in the village and some additional homes above minimum requirement. The deliverability of the site would need to be confirmed by on site investigation as concerns remain about the impact on wildlife and ground water Capacity 30 protection.

Assessment of Proposed Changes to Policies

6 Changes to 2 policies setting criteria for self-build housing and employment sites are put forward.

Policy ref Policy subject Change put forward DP24 Self build housing Clarify that policy is an affordable housing policy and introduce additional flexibility in resale value. Clarify that this policy does not apply in towns. Include reference to AONB. DP25 Established Exclude freestanding supermarkets. employment sites Revisions to policy wording to encourage other employment sites to come forward

7. The Sustainability Appraisal is intended to be used as a tool for determining the relative sustainability merits of options around the ‘big decisions’ of a Plan, and these policies were not initially subject to Sustainability Appraisal. This is in accordance with the approach that was followed for Local Plan Part I.

8. In the case of DP24 a number of representations were received as a result of pre-submission consultation which raise issues of relevance to the Sustainability Appraisal. The issues raised included the impact on rural areas, the landscape and biodiversity, the role of local connection, restriction of resale values and limits on size. A number of pre-submission changes are proposed as a result of these representations. An appraisal of the policy, as amended by pre-submission changes, is included here.

SA of policy DP24 After Pre-Submission Changes SA Overall Comments [reasons for impact] Objective Impact SAO1 ± This policy aims to provide for self-build housing in rural areas and is unlikely to impact directly on the local economy SAO2 ± The policy specifies that development must be in harmony with the character of the area, of a suitable design which is appropriate to its location. The impact of any scheme would therefore be mitigated. SAO3 ± The policy says that self-build homes will not be acceptable in isolated rural locations and that any scheme must be acceptable in terms of landscape impact. A pre-submission change has been proposed to ensure there is no adverse impact on the AONB. The potential for landscape impact is therefore minimised as unacceptable schemes will not be permitted. SAO4 ± Policies in LPP1 clearly indicate that vulnerable development in areas prone to flooding will not be acceptable. This policy does not change that stance.

SAO5 ± Policies in LPP1 clearly indicate that biodiversity and ecological networks will be safeguarded. This policy does not change that stance. SAO6 ± Policies in LPP1 clearly indicate that the quality of water resources will be safeguarded. This policy does not change that stance. SAO7 - This policy will not have a particular impact on the use of renewable energy. However, it does allow for small scale development in hamlets and small villages where everyday facilities may be more difficult to access sustainably on foot or by cycle or bus. There is likely to be some negative impact on the use of sustainable modes of transport. SAO8 ± The policy includes safeguards to protect the District’s built environment including a requirement for any scheme to be of a suitable design which is appropriate to its location. The impact of any scheme would therefore be mitigated. SAO9 - The policy allows for small scale development in hamlets and small villages where it may be more difficult to access everyday facilities by sustainable means. However, the policy is limited to those with a local connection and this should reduce the need to travel for everyday activities. There may never-the-less be some negative impact on sustainable travel patterns. SAO10 ± This is policy restricted to small rural settlements and it will not impact on town centres. SAO11 ++ The policy will allow for the development of additional housing in rural areas to meet local need and ensure that dwellings remain affordable in perpetuity. Whilst these rural locations may be less sustainable in terms of travel patterns, occupants must demonstrate a strong local connection, which might be expected to lessen the need to travel to carry out daily activities. SAO12 ± Rural locations might be expected to have good access to footpaths and the countryside. However, access to formal sporting and recreation provision may be more limited. SAO13 + Small scale development in rural areas might be expected to make a small contribution to supporting rural facilities and services.

9 In the case of DP25 representations were received relating to the identification of established employment sites and site specific comments on Future Employment Growth sites. The Future Employment Growth sites have been the subject of Sustainability Appraisals. The established employment sites relate to the identification of existing uses on the proposals map. These sites do not therefore raise new sustainability issues. An SA of policy DP25 is not therefore included here.

10 A number of changes have also been proposed to sites designated as Local Green Spaces. These sites have been the subject of their own process of assessment for designation, details of which can be found in the Local Green Space Topic Paper. As such these have not been the subject of a separate Sustainability Appraisal and the changes will similarly not be subject to Sustainability Appraisal.

Challenges to the SA at Pre-Submission Stage

11 A number of representations were made as a result of pre-submission consultation concerning the SA. Many of these relate to specific sites and will be treated as site specific issues. However, the representations in table 3 below relate to the SA methodology. The table sets out a summary of these representations and the response to it.

Table 3; pre-submission representation about the SA methodology and the Council’s response

Objection Summary of objection Response reference

081-6090-1 The consideration of SAO9 only references bus SA09 assesses whether a site will services and makes no assessment of SAO9 encourage more sustainable frequency of bus services. There is no travel patterns including minimising consideration of walking or cycling. The the need for travel by the private potential role of cycling from new developments car and promoting cycling, walking needs to be assessed as it is the ideal form of and use of public transport. transport for trips of 0.5km - 5km. The advent Assessments have been carried of Ebikes also makes it more feasible for less out of the accessibility of sites by able people and those in hillier areas. footpath, pavement or multiuser path and the accessibility of the site to a range of basic services, as well as public transport. A indication of the frequency of bus service is assessed, as well as whether it allows a journey to work. SA adequately assesses whether a site will encourage more sustainable travel patterns. No change to the plan.

682-6092-2 The suitability of each site should be A general assessment of sites considered with respect to access to key accessibility to a range of basic services such as secondary schools and town facilities and relationship to the centres on foot and for peripheral sites by urban form is included in the SA. cycle, not just proximity to bus routes. No change to the plan. 581-1797-1 A requirement to "retain and enhance habitat Policy DP6 of LPP1 sets out and features of value to horseshoe bats requirements for sites within the wherever possible and to ensure replacement Bat Consultation Zone. Site put habitat is optimal for the affected species. forward in LPP2 have been subject to HRA and issues concerning bats highlighted. No change to the plan. 581-1797-2 SA demonstrates a reasonable understanding Support is noted. of the plan in relation to the natural environment and provides and adequate assessment of potential effects on designated sties, habitats, species, landscape and geology Impacts on landscape assessment are likely to Policy DP4 of LPP1 sets out 581-1797-3 be more severe for Wells and the rural areas, criteria in relation to landscape and anticipates that cumulative impacts will be designations, including the AONB. relatively significant. Mitigation measures are The AONB has been included in suggested. Where development might affect Sustainability Assessment of sites the AONB that abuts Wells the Council should where appropriate. No change to seek advice from the AONB partnership / staff the plan. at an early stage.

581-1797-4 Not clear how soils and ALC have been ALC has been included in considered in the SA. Local plan should give sustainability appraisals under appropriate weight to the role performed by the SAO11 for each potential site and areas soils. They are a finite multifunctional regard had to paras 109 and 112 resource which underpins wellbeing and of NPPF in weighing up the prosperity. Development has a major and suitability of sites. However, the usually irreversible adverse impact on soils. SA summaries included in Mitigation should aim to minimise soil Appendix 6 do not fully reflect the disturbance and retain as many ecosystem regard had to ALC earlier in the services as possible through careful soil assessment process. Amend management through the construction process. Appendix 6 to more fully reflect the NPPF refers to soils at paras 109 and 112. weight attached to ALC where Plan policies should take account of the impact sites include land of grades 1, 2 or on land and soil resources, such as 3a. safeguarding the long term capability of the best and most versatile agricultural land, to avoid development that would affect soils of high environmental value and ensure soil resources are conserved and managed in a sustainable way. 581-1797-5 To safeguard best and most versatile Best and most versatile agricultural agricultural land strategic scale ALC maps are land has been assessed using the available and some other more local data is best information available, using available for some locations. The LPA should both strategic and local maps. In ensure that sufficient ALC survey data is some cases it has not been available to inform decision making. Where no possible to distinguish between reliable information is available it is reasonable grade 3a and grade 3b land. As to expect developers to commission an ALC this is only 1 factor in the site survey for site put forward for local plan selection process is would not be consideration. reasonable or proportionate to require on site survey of the agricultural land classification to distinguish between these grades.

Amendments to the SA

12 The Options Appraisal at section 7 has been carefully considered. No changes are suggested to tables 6-9 appraising the allocation of all preferred options sites in Frome, Glastonbury, Street and Wells.

13 It is proposed to delete a site in Frome (FR6). This site was not included as a preferred option in the SA as it scored poorly and was included as an allocation in the pre-submission consultation for other reasons. It’s proposed deletion will not therefore require any amendments to the Options Appraisal at Section 7.

14 In Glastonbury site GL4 scored negatively for SAO1 in the updated SA. Table 7 already has the following entry which addresses this concern within the SA process.

SA Overall Comments [reasons for impact] Potential mitigation Objective Impact measures SAO1 - - 636 houses have either been completed or are Allocation of other committed against the target of 1,000 houses. sites for employment Therefore 142 houses remain to be delivered. use which are unsuitable for All but one of the sites considered to be preferred housing freeing up options are currently in employment use or former these sites. employment sites and in total can deliver 167 houses. Therefore development of all of the sites is likely to have a significant impact upon this objective due to the loss of employment land through redevelopment.

15 In Street site ST1 scored negatively for SAO 3, 4, 5, 8 and 13 in the updated SA. Table 8 already has the following entries which address these concerns for the town as a whole within the SA process. SAO13 is neutral overall across the town, despite ST1 scoring a negative as an individual site.

SAO3 - The landscape character surrounding Street is not considered to be of the highest quality however the Ivythorn Hill Special Landscape Feature does lie to the south of the town.

Therefore it is not considered that the additional development arising from allocation of all of the Preferred Sites would have more than a slight negative impact upon the landscape character surrounding the town.

However the impacts on development of land adjacent to the future growth area (WAL022b) would need to be ascertained once the scale and layout of the FGA has been masterplanned. SAO4 - All but one of the sites suitable as a preferred option is considered to have a neutral impact on flooding & flood risk. Site ST1 has an anticipated minor negative impact however this is likely to be able to be mitigated against with use of SUDS/attenuation ponds etc and the site is large enough to be able to accommodate these. SAO5 - - Street is in relatively close proximity to the internationally protected Somerset Levels & Moors Special Protection Area & Ramsar site. Increased housing numbers could have significant impacts upon the integrity of this site due to further pressures from recreation uses. The degree of

impact from the increased housing number on the Levels & Moors would need to be determined with advice from the County Ecologist.

Those sites which are considered suitable as preferred options all have some issues that have been flagged up around presence of protected species or proximity to designated sites. Therefore whilst the option does not represent a significant increase in housing numbers its accommodation on any of the sites is likely to have some negative impact upon biodiversity.

SAO8 - Although the allocation of all Preferred Sites does not result in a significant amount of additional development to the town one of the sites considered suitable as a preferred option is considered to be sensitive in terms of heritage assets. As such although the impact upon this objective is not anticipated to be very significant, a slight negative impact is recorded. SAO13 ± The majority of sites considered to be suitable as preferred options are in accessible locations therefore impact upon the objective is likely to be neutral.

16 In Wells site WL2 scored negatively for SAO4, 8 and 13 in the updated SA process. Site WL5 scored negatively for SA0 2,3,5,8 and 9 in the updated SA. Table 9 already has the following entries which address these concerns within the SA process. Results are for the aggregate impact across the City. SAOs 9 and 13 score neutral overall despite WL2 being negative for SAO13 and WL5 being negative for SAO9.

SAO2 - Although the Preferred Option sites individually are not considered to be particularly sensitive, cumulatively the impact is anticipated to be negative, but not to a significant extent. The FGA site is considered to be more sensitive. Overall the impact is considered to be negative but not significantly. SAO3 - - The Preferred Option sites are not considered Inclusion of policy individually to have an anticipated negative impact criteria to ensure upon landscape character. The FGA site is sensitive design considered to be more sensitive. within any allocation policies. As the allocation of the Preferred Option sites will have a cumulative impact upon the landscape

character surrounding the city, particularly to the west the overall impact is considered to be significant. However the negative anticipated effects are considered to be able to be mitigated against. SAO4 - The majority of the preferred sites have flooding Improved drainage issues to some extent. Therefore development of Attenuation Ponds these to meet the uplift is likely to have some SUDS negative impact. However it is likely that any negative impacts could be mitigated against. SAO5 - There are issues relating to Protected Species, Include intention in specifically bats in the majority of the sites however policy to take advice from Ecologist indicates that any negative opportunities to impacts could be mitigated against by the inclusion maintain or enhance of relevant measures in allocation policies. biodiversity.

Include requirement for provision of replacement habitat if necessary. SAO8 - Development of all of the Preferred Option sites does represent a substantial increase in houses for the City therefore it is likely there may be some cumulative impact of assimilating a number of sites into the built environment. Overall the impact is considered to be slightly negative. SAO9 ± The 2011 Census showed that Wells continues to be a net importer of workers therefore the uplift in housing may have a slight positive impact upon rebalancing this by increasing the number of homes in the City. Those sites outside the settlement limits are likely to have a more negative impact. Overall the impact upon this objective is considered to be neutral. SAO13 ± Allocation of the preferred option sites is unlikely to have a significant impact upon this objective as the sites considered to be suitable as preferred options are in accessible locations.

Review of SA of Housing numbers options 1 and 2

17 In the SA report an appraisal was undertaken on two options around housing numbers. Option 1 was delivering the housing targets outlined in the adopted Local Plan Part I. Option 2 was the allocation of all the preferred sites in Frome, Glastonbury, Street and Wells and sites in the Primary and Secondary villages to meet the outstanding requirements. Tables 10 and 11 show the results of the Sustainability Appraisal of these two options respectively. These tables have been reviewed to assess whether changes are needed as a result of pre-inquiry changes.

18 The pre-submission changes have broadly retained the approach to the distribution of growth. Revised Table 4 (below) sets out the planned uplift in housing numbers, including updating ofnumbers arising from incremental change and proposed amendments to allocated sites following the pre-submission changes. All settlements show an uplift, with Frome and Shepton increasing by 1% each and Glastonbury increasing by 2%. Street and Wells increased by 8% and 6% respectively, largely due to changes in the treatment of sites designated as Future Growth Areas. In the villages and rural areas the uplift above minimum requirement increased from 25% to 36% largely due to windfall sites coming forward which are included in the updated housing tables put forward as pre-submission changes.

19 Excluding the windfall allowance quoted in the pre-submission Plan there is no significant overall change on the level of planned housing delivery in settlements as a result of the Proposed Changes (10,968 in Pre-submission plan and 10,987 in revised Table 3).

20 Table 10, assessing the sustainability impacts of delivering the housing targets outlined in the adopted Local Plan Part I, has not been affected by the pre-submission changes and is not reviewed here.

21 Table 11 assessing the sustainability impacts of Option 2, the allocation of all the preferred sites in Frome, Glastonbury, Street and Wells and sites in the Primary and Secondary villages has been

reviewed below to take account of pre-submission changes to sites and the planned uplift in housing numbers .

Table 11: Revised Results of SA of Option 2 After Pre-Submission Changes SA Overall Comments [reasons for impact] Objective Impact SAO1 ± The majority of sites are greenfield sites which are unlikely to have an impact upon this objective. In those areas where there is an issue there are alternative areas where employment land could be delivered, including at Lintells garage where a pre-submission change is proposed to include some employment land, which is being replaced on an alternative site. SAO2 - This option is likely to have some degree of negative impact upon local distinctiveness in all areas. Perhaps most noticeably in the rural area where the level of completions/commitments in some villages has been quite dramatic. However all the Preferred Option sites are considered to be acceptable in terms of the level of impact that may arise. Proposed pre- submissions changes remove 2 sites in rural areas (CR1 and DU1) reducing the potential for an impact on the distinctive character of these settlements. SAO3 - - For the majority of the towns the impact upon landscape character is not expected to be significantly negative. However for Wells and the rural area the impact is likely to be more severe. Cumulatively looking at the option as a whole the anticipated impact is likely to be relatively significant. However this impact can be mitigated against by including policy criteria to ensure sensitive design within the allocation policies. Proposed pre-submissions changes removed 2 sites in rural areas (CR1 and DU1) reducing the overall impact on landscapes around these settlements. SAO4 - It is not anticipated that this option is likely to have a significant negative effect upon this objective. The Preferred Option sites are not considered to have any significant issues relating to flooding. Any negative impacts could be mitigated against using improved drainage systems, attenuation ponds, SUDS etc. SAO5 - Some of the sites have some issues around biodiversity and presence of protected species. However the HRA indicates all the Preferred Option sites are capable of development albeit allocation policies for some sites may need to include specific criteria relating to provision of habitat etc. SAO6 ± Implementation of this option is not considered to have any anticipated impact upon water quality across the district. SAO7 ± There are no known specific opportunities for renewable energy projects around the district. Allocation and development of all the preferred option sites does present an opportunity for integration of renewable technologies but current housebuilding practices favoured by the volume housebuilders are unlikely to incorporate these. SAO8 - This option including pre-submission changes does represent a reasonable uplift in housing from the minimum figure adopted in LP P1. Therefore there are likely to be some impacts on the built environment although these are mainly anticipated to be around assimilation of new development into the

built environment rather than direct impacts to heritage assets. Therefore any impacts are considered able to be mitigated with careful and sensitive design and the overall impact is likely to be relatively minimal across the district. Pre-submission changes propose increased densities on sites in Wells, Street and Nunney and this is likely to increase the impact on the built environment in these settlements. However, sites are proposed to be deleted in Croscombe and Doulting and this is likely to reduce the impact on the built environment in those settlements. It is considered that any impacts from increased densities can be satisfactorily mitigated. SAO9 - The majority of development is still directed to the five main settlements in the district under this option which are considered to be the most sustainable locations for new development in Mendip.

However pre-submission updating and changes show an uplift in the rural area of 36%, increasing from 25%. The rural areas are less sustainable locations, although development is mainly focused in primary and secondary villages where a range of everyday needs can be met sustainably. Land is not put forward for allocation away from the primary and secondary settlements.

Overall the impact is considered to be negative but not substantially. SAO10 ± Overall the anticipated impact upon this objective is considered to be neutral. Additional housing to the towns could result in extra footfall in the town centres which would have a positive impact upon this. However some town sites have a more neutral impact due to their close proximity to the town centre. SAO11 + This option represents an uplift in housing from the minimum figure adopted as part of LP P1 therefore any additional housing is considered to have a positive impact on this objective. Pre-submission changes and updating of the housing tables has resulted in delivery of or provision for an extra 459 homes, reinforcing the positive impact. SAO12 + The majority of the Preferred Sites which will be allocated under this option are greenfield sites which are able to make provision for some open space. Therefore the impact upon this objective is considered to be positive. Best and most versatile agricultural land is protected across the District unless other considerations outweigh the benefits. SAO13 + The majority of extra development under this option will be in the principal settlements, considered the most sustainable locations in the district for new development. The option also represents a 36% uplift in housing in the rural area, principally directed to the most sustainable villages which may have a positive impact upon this objective due to more potential use of village facilities.

Conclusion

22 The Sustainability Appraisal process is iterative, and the appraisal has been reviewed in the light of suggested changes as a result of pre-submission consultation and comments made on the SA process itself.

23 Changes resulting in additional housing or additional land being used for development have been subject to SA and suggestions made as to how possible negative effects can be mitigated where appropriate. Sites where a pre-submission change is proposed to delete an allocation are also noted.

24 This addendum to the SA report has reviewed the SA of broader options for growth across the District and assessed any amendments needed as a result of the pre-submission changes to sites and housing numbers. No changes to the overall impacts resulting from Option 2 were noted, despite the proposed changes. Mitigation measures identified will be monitored by the framework set out in the earlier report to monitor the long term effects of the adopted Local Plan Part II on sustainability in Mendip.

Appendix 1; Sustainability Appraisal Objectives

SA Objective Decision-aiding questions: Would development of the site….? SAO1 Promoting a strong, thriving  Contribute to the provision of sufficient employment land and diverse local economy to meet the district’s requirements  Encourage and support the diversification of the district’s economy  Ensure provision of sites for small start-up businesses  Support farm diversification and rural enterprise Protect jobs on employment sites from loss to residential uses where appropriate SAO2 Maintain and enhance the  Adversely affect or result in the loss of features or scenes distinctive character of which are recognised as being distinctive settlements SAO3 Protect and enhance the  Protect AONBs district’s landscape  Protect the special landscape features of the district that contribute to local distinctiveness  Adversely affect landscape character  Avoid unacceptable visual impact  Preserve and where possible enhance landscape character  Be integrated into existing landform and landscape features SAO4 To avoid, reduce and  Avoid inappropriate development on the floodplain manage flood risk  Put properties at risk of flooding  Promote the use of Sustainable Urban Drainage Systems SAO5 Protect, maintain and  Protect those habitats and species of international, national where possible enhance, and local importance the district’s native  Ensure all new development is integrated with, and makes a biodiversity positive contribution to, biodiversity  Protect and enhance Somerset’s Ecological Network, allowing for improved species migration and movement SAO6 Maintain & improve water  Promote good river quality quality  Improve the district’s water habitats  Avoid development in areas with little water available SAO7 Promote renewable sources  Increase the number of renewable energy projects across and encourage a reduction the district in consumption  Promote sustainable construction methods and energy efficiency  Encourage the use of more sustainable transport methods SAO8 Protect and enhance the  Ensure good quality design that contributes positively to district’s built environment local distinctiveness  Protect and conserve listed buildings, their settings and conservation areas  Ensure the integrity of Local Green Spaces

 Be well integrated with the existing urban form, townscape and landscape  Relate well to adjoining land uses  Contribute to improving the quality of the public realm SAO9 Encourage more sustainable  Minimise the need for travel by the private car travel patterns  Promote cycling, walking and use of public transport SAO10 Maintain and enhance the  Ensure retail offer within the town centres meets local need vitality of town centres and an improved offer is encouraged where viable  Direct leisure, retail and employment uses to town centre locations SAO11 Meet housing needs whilst  Meet Local Plan Target providing suitable housing  Provide affordable housing and a suitable mix to meet the for all in appropriate, need sustainable locations  Make best use of PDL  Protect best and most versatile agricultural land  Ensure housing is directed to the most sustainable locations SAO12 Promoting healthy and safe  Improve access to open space for future residents communities SAO13 Improve access to facilities  Ensure key community facilities are provided in locations and services easily accessible by public transport, cycling and walking  Protect the loss of rural facilities and services

APPENDIX D

SCC HA and PRoW Officer Comments on Planning Application 2016/3122/OTS