NORTH SOMERSET LOCAL PLAN 2036: ISSUES AND OPTIONS DOCUMENT SEPTEMBER 2018

Comments from Diane Snape

My comments are submitted without prejudice to my objections in principle to strategic development at and Backwell and the delivery of significant transport infrastructure within the gap between Nailsea and Backwell. Please refer to my responses to the NSC Generating Ideas consultation and the JSP and JTP consultations.

This Issues and Options consultation seems premature given that the JSP has not yet been examined in public.

SECTION 2: NORTH SOMERSET WIDE ISSUES Question 3: Nailsea and Backwell (pages 12 - 13). Do you agree with these or are there other challenges or issues which we have not included and how might the Local Plan address these?

Key issue 1: “… the Local Plan needs to test the scale of development proposed...” The testing of the scale of development is the role of the JSP not the Local Plan as I understand it.

Please add another challenge/issue: “The impact of the proposed strategic road, metrobus and transport hub infrastructure on the quality of life of the many nearby residents, wildlife, the environment and the green belt, and whether this can be effectively mitigated”. Comment: This issue is particularly pertinent to the proposed road and metrobus link between Station Road and the A370 across the green belt, which if constructed would pass very close to many hundreds if not thousands of residents in South & East Nailsea and North Backwell/Backwell Common/Farleigh, with the pollution, noise and visual intrusion being magnified by the terrain, which necessitates the siting of the highway in the bottom of the valley (with incumbent flood risk) and most of the properties sitting above it - see section 8 of this document : transport issues: public health issues “...poor air quality as a result of congested roads…”.

Key issue 4: please reword as follows: “… the potential future site and role of the rail station… “. Comment: the purpose of my proposed re-wording is to include consideration of relocating the railway station to a new site further west, closer to the Nailsea and Backwell SDLs, where space is less constricted and it is more feasible to establish a transport hub. (Clearly this is relevant only if the proposal to develop to the South West of Nailsea is upheld.)

Key issue 7: The existing Nailsea town centre should remain the focal point. New developments should be located so as to facilitate access to the existing town centre and should not set up new local centres competing with the existing centre. Backwell residents also rely on Nailsea town centre for essential facilities such as supermarkets. Access routes between Nailsea and Backwell must not be impeded by new developments/infrastructure.

1 Key issue 10: Maintaining separation between the settlements of Nailsea and Backwell via green belt and strategic gap is another key issue which is important for quality of life, environment and wildlife.

Key issue 10: there is a need to address traffic issues throughout the area, not only on the A370 and not only in Backwell.

How the local plan might address these: The local plan must ensure that any infrastructure proposals include a thorough impact assessment and mitigation measures, with full prior consultation with affected residents including disclosure of projected traffic flows, noise modelling, and detailed traffic management plans including speed limits.

In relation to infrastructure, most of the proposals in this issues and options document do not appear to include any alternative options. Alternatives should be developed and consulted upon, so that the least damaging/most effective alternatives may be selected.

3. Local Housing Growth How will Neighbourhood Plans fit with the Local Plan? A reference to Town Visions would be appropriate in this section.

Question 5 (pages 14 - 15): Do you agree with these or are there other challenges or issues which we have not included and how might the Local Plan address these?

Please include consideration of extending the green belt between Backwell and Nailsea to include Backwell Lake and the strategic gap.

SECTION 4. GARDEN VILLAGES AND NEW COMMUNITIES (pages 28-61)

Nailsea and Backwell Transport Schemes (pages 30 – 31):

I strongly object to proposed new highway link between Station Road and the A370 [E3]. This route runs across green belt, sensitive landscape, prime agricultural land, wildlife habitat and very close to nature reserves (Backwell Lake, Backwell Common and Trendlewood Park). it runs right through the strategic gap between Nailsea and Backwell and in close proximity to established residential areas – the impact on local residents would be enormous. The intersection of the route with Station Road would lead to significant incremental congestion and pollution due to standing traffic waiting for right of way. The increased traffic, and the need to negotiate the junction, would substantially increase danger to pedestrians and cyclists, particularly students at Backwell primary and secondary schools and Nailsea commuters using the station. Please see my comments below on the concept diagram for Nailsea and alternative options.

I support the removal of the previously proposed routing which passed close to the Tyntesfield estate to join the Long Ashton bypass near Flax Bourton. I believe this would have had a major adverse impact on this heritage site which could not have been adequately mitigated.

If despite concerns, the proposal for new highway [E3] is upheld, I believe the proposed timing within the first phase is massively premature. In view of the previously identified

2 challenges associated with [E3], coupled with the fact that the highway link within the Nailsea SDL [W3] is not to be constructed until the fourth phase, I propose that the highway [E3] should be moved to the fourth phase, to coincide with the highway link [W3], which will feed traffic into it. Metrobus services, if required prior to phase four, should use the existing highway via Station Road and the A370 and hence would act as a pilot scheme to test commercial feasibility of and consumer appetite for such a service before embarking on the challenges of constructing a new dedicated busway with all the challenges that this entails.

I do not support the development of the existing Nailsea and Backwell station as a transport hub. The current station is very small and basic and there is very limited scope to improve the facilities in its current location. If the proposal to develop to the South West of Nailsea is upheld, I support relocating the railway station to a new site further west, closer to the Nailsea and Backwell SDLs, where space is less constricted and it is more feasible to establish a transport hub, with appropriate walking/cycling and bus connections. This would also facilitate improvement of the rail service by providing longer platforms and lift/disabled access and extended parking.

I specifically oppose the development of a multi-storey car park at the existing Nailsea and Backwell station. This would result in unacceptable visual intrusion into the landscape, including light pollution. I do not believe the impact of this could be adequately mitigated.

I support the removal of the previously proposed highway link across the SSSI between Nailsea and the M5 at Junction 20, and the previously proposed link from the Nailsea SDL to the A370 west of Backwell. Both of these would have inappropriately funnelled through traffic into the constrainted and sensitive gap between Backwell and Nailsea.

In principle I support improvements to the existing highway network to the M5 at junctions 19 and 20 [N1 and W10]. However, improvements to Portbury Lane [N1] will need to be designed carefully so as to avoid adverse impact on the sensitive landscape through which this route passes.

Improvements to the T junction between Portbury Lane and the B3128 are already urgently required and the addition of traffic lights would be welcomed.

I support the proposal to add a new highway link between Hanham Way and the B3130 [W4]. However, given that the land off Causeway View and the land off Engine Lane are already allocated for development in the plan to 2026, it seems appropriate to bring this link forward from the second to the first phase. The alignment of this route and mitigation measures need careful consideration to avoid adverse impact on Tickenham Church and its setting.

I support the proposal to add a new highway link between the B3130 and junction 20 [W5]. This seems a relatively straightforward development which would have an immediate positive impact on traffic flows and local residents, so I would like to see it brought forward to the first or second phase.

This should link to the new road which I assume will be required through the development off Causeway View in the site allocations to 2026, emerging either onto Pound Lane or directly onto Road near the fire, ambulance and police stations (NB please add

3 this road to the concept diagram) and an onward link from Clevedon Road to the B3130 Nailsea to Wraxall road, which will also serve the industrial estates and improve the routings for fire appliances, ambulances and police vehicles, taking this inappropariate traffic away from Nailsea town centre.

I object to the proposed highway link within the Nailsea SDL [W3], particularly the section of the route which is proposed to pass through the gap between Nailsea and Backwell railway station and Backwell Lake. Space in this area is very constrained, so the route would inevitably run very close to the Lake, resulting in significant adverse impact on the setting of this nature reserve.

SECTION 4.3: BACKWELL (pages 50 – 53)

Q19. Do you have any comments on the proposed vision for Backwell?

Please add another sentence: “ New infrastructure will be located and designed so as to avoid detrimental impact on the environment, setting and surroundings of Backwell and neighbouring settlements.”

Proposed Vision for Development (Pages 50-52): Question 20 (page 52): Do you agree with the principles set out for Backwell and would you suggest any changes to these? We consider that establishing the principles is a fundamental step towards developing the detail for development in these areas.

I strongly object to the proposal for a new Station Road – A370 link and the proposed timing of such a link in the first phase. Please see my comments above on the Nailsea and Backwell Transport Schemes.

No detail of the proposed modifications to Station Road has been provided and this is needed in order to comment fully. I strongly object to the possibility of closing or restricting Station Road to through traffic. The settlements of Nailsea and Backwell, whilst separate, are interdependent and this is the main arterial route between the two. To close it would isolate Backwell from the services of Nailsea town centre, and risk diverting traffic trying to reach Nailsea from Backwell onto narrow, unsuitable country lanes.

SECTION 4.4: NAILSEA (page 54 – 61) Question 23 (page 55): Do you have any comments on the proposed vision for Nailsea?

I do not support the vision that expansion will be focused on the South West of Nailsea. I support developing a number of new sites around the North and West peripheries of the existing town. This will maximise utilisation of the existing town centre, facilitate the improvement of existing transport infrastructure, for metrobus and private vehicle, serving the development sites to the West and North West of Nailsea already allocated within the local plan to 2026 and the industrial areas to the West and North of Nailsea, as well as the new developments to 2036, and deflect traffic from the Nailsea developments away from the congested centre of Backwell, avoiding the massive infrastructure complexity, cost and lead time to deliver a new link road. It will also maintain the separate identity and character

4 of Nailsea and Backwell by avoiding the construction of a major link road in the strategic gap and green belt between the settlements.

I do not understand the reference to providing some higher density development close to the railway station. I assume this must be a drafting error, as no development is proposed in Nailsea close to the railway station.

Question 24 (page 56): Do you agree with the principles set out for Nailsea and would you suggest any changes to these?

I do not support the vision that expansion will be focused on the South West of Nailsea. I support developing a number of new sites around the North and West peripheries of the existing town. Please see my comments, above, on the vision for Nailsea.

I do not support the proposal for a new highway between Hanham Way and Station Road [W3], or a connection to an onward route to provide a direct access to the A370 beyond Backwell to [E3]. Please see my comments above on the Nailsea and Backwell Transport Schemes.

Please add a reference to improvements to rail services (frequency, routes, reliability, passenger experience).

I support retaining the current extent of the strategic gap and redesignating it green belt, including Backwell Lake and its environs.

Alternative Scenarios (pages 57 – 61):

Question 25 (page 57): Do you have any comments on the concept diagrams and alternative scenarios set out?

The concept diagram is an improvement on the one shown on the interactive map in the previous Generating Ideas consultation, in that the proposed development is more tightly wrapped round the existing periphery of Nailsea and does not extend into the surrounding countryside to the same extent.

However, this still shows the development concentrated in the South West of Nailsea. I do not support expansion focused on the South West of Nailsea. I support developing a number of new sites around the North and West peripheries of the existing town. Please see my comments, above, on the vision for Nailsea.

Key Feature 2: I support retaining the current extent of the strategic gap and redesignating it green belt, including Backwell Lake and its environs.

Key Feature 1: If the proposal to develop to the South West of Nailsea is upheld, I support locating the employment area further west than is shown on the concept diagram. This brings it closer to the new residential areas, outside the strategic gap, which would be a more suitable location – see the interactive map in the previous Generating Ideas consultation. The employment location shown on the current diagram is too close to the strategic gap and Backwell Lake.

5 Key Feature 4: I do not support the proposal for a new highway between Hanham Way and Station Road [W3], or a connection to an onward route to provide a direct access to the A370 beyond Backwell to Bristol [E3]. Please see my comments above on the Nailsea and Backwell Transport Schemes.

Key Feature 7: I support the retention and safeguarding of existing designated wildlife areas to the west. Please add reference to the retention and safeguarding of the existing wildlife areas of Backwell Lake, Backwell Common, Trendlewood Park and Kenn Hedge.

Alternative scenario 1: I do not support this scenario. It has all the same disadvantages as the concept diagram, and, in addition, the concept of a new distributor road round the edge of the development would intrude significantly more into the surrounding countryside, with a significantly greater impact on the environment and wildlife habitats. This proposal has much more of the appearance of a trunk road, which would attract through traffic to the detriment of the local environment and the quality of life of the residents. If despite objections the development and the road are approved, running the road through the development which it is intended to serve makes much more sense.

Alternative scenario 2: I do not support this scenario, as it involves greater intrusion of the development into the surrounding countryside, with a significantly greater impact on the environment and wildlife habitats.

Alternative scenario 3: This scenario has most of the same disadvantages as the main concept, however if despite objections, the development in South West Nailsea is approved, I strongly prefer this scenario to the main concept, provided that it can be achieved without alternative 2 (expansion further west). My reason is that it provides greater protection for Backwell Lake and its environs than the main concept. The current strategic gap can then be redesignated green belt.

Question 26 (page 57): Are there any other options you would add for accommodating strategic growth within Nailsea?

I support developing a number of new sites around the North and West peripheries of the existing town. This will maximise utilisation of the existing town centre, facilitate the improvement of existing transport infrastructure, for metrobus and private vehicle, serving the development sites to the West and North West of Nailsea already allocated within the local plan to 2026 and the industrial areas to the West and North of Nailsea, as well as the new developments to 2036, and deflect traffic from the Nailsea developments away from the congested centre of Backwell, avoiding the massive infrastructure complexity, cost and lead time to deliver a new link road. It will also maintain the separate identity and character of Nailsea and Backwell by avoiding the construction of a major link road in the strategic gap and green belt between the settlements.

Infrastructure improvements to include: Improvements to the B3130, providing access to the M5 J20 at Clevedon and link to the Long Ashton bypass via Wraxall. Metrobus route from Clevedon to Nailsea along the existing B3130 via Tickenham and from Nailsea to the Long Ashton bypass along the existing B3130 via Wraxall.

6 Metrobus link to the railway station from the B3130 Nailsea High Street via Station Road. Metrobus route Bristol-Backwell along the existing A370, suitably upgraded. Possibly add a metrobus-only route (not road) from Backwell SDL to West Nailsea. From West Nailsea the route should then proceed along Queens Road in Nailsea (this is a wide 40mph road which is substantially underutilised and could accommodate a metrobus lane with some upgrading) to join Station Road and thence to the railway station. Possibly upgrade Mizzymead Road in Nailsea (also a wide road) to route the metrobus to the town centre.

If necessary, a new road/metrobus to the north of Nailsea could also be considered. Create a new road and metrobus route from the Backwell SDL, around the West and North of Nailsea, serving the development sites to the West and North West of Nailsea already allocated within the local plan to 2026 and the industrial areas to the West and North of Nailsea, as well as the new developments to 2036.

Q38. What are your thoughts on the four proposed options for a policy in the new Local Plan 2036? Do you have a preferred option?

I prefer option 1 - retain the existing policy, for the reasons listed as Advantages.

Section 8, Transport, pages 80-84 Q39. Are there any transport issues or challenges that have been missed? How can they be addressed in the Local Plan?

Transport issues:

Public health issues: add a reference to nitrogen dioxide as a major contributor to poor air quality. Expand the statement to include noise, dust and vibration from congested roads and noise from air traffic as public health issues.

Shift in behaviour: add a reference to increased frequency of air travel.

Port and airport: proposals for improved transport system must mitigate impact on public health, environment and quality of life in local areas.

How will the local plan address these challenges:

Second bullet point - encourage public transport: add a reference to improving the frequency, routes, connectivity, reliability, passenger experience and pricing of bus and rail services.

Third bullet point – support new technologies: add a reference to maximising access to reliable superfast broadband for homes and businesses. This will promote increased telecommuting, thereby reducing congestion and pollution.

Rail (p83):

Provision of rail access to the airport. Is it suggested that this could be achieved within the plan period to 2036? If so, please expand on the proposals for this. It is assumed that this refers to a new link to the railway line through Bedminster, but it is unclear why this would

7 be required in addition to the Mass Transit. Connectivity to rail network via the Mass Transit, as described under Bristol South West Economic Link Study, fourth bullet point, seems much more feasible. There is no viable route for a new railway line between the airport and Nailsea and Backwell railway station, mainly due to the terrain. A new line between the airport and Yatton railway station might be feasible but would have to follow a circuitous route at massive cost and with massive impact on the environment and landscape. Total journey times to get to or from Bristol Temple Meads via this route would almost certainly rule it out.

Park and Ride South Bristol. I support the proposed park and ride facility close to the A38/South Bristol Link roundabout.

Sustainability Scoping Report: page 32, map 6, National and Local Nature Reserves:

Stockway North Nature Reserve in Nailsea is missing from the map.

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