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Site Allocation Plan Main Modifications 2017 - Consultation Responses

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Site Allocation Plan Main Modifications 2017 - Consultation Responses Site Allocation Plan Main Modifications 2017 - Consultation Responses Document Section 1. General comments Respondent Comment Comment Attached documents Name ID Backwell 1013153//1 Parish Council The Parish Council met last week and passed the following resolution: Backwell Parish Council supports the NSC Site Allocations Plan Proposed Modifications Natural 1018753//1 England Planning consultation: North Somerset Site Allocations Plan - Main Modifications Consultation Thank you for your consultation on the above dated 18 September 2017 which was received by Natural England on the same date. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development. European designated sites We have reviewed the proposed modifications to the Site Allocations Plan and while some changes are welcome we are concerned about its potential to result in adverse effects on the North Somerset & Mendip Bats Special Area of Conservation (SAC) and Page 1 of 439 9 Nov 2017 15:53:40 Respondent Comment Comment Attached documents Name ID on the Severn Estuary Special Area of Conservation (SAC) and Special Protection Area (SPA). We consider that our concerns can be addressed by further modifications to the Plan; however there is a risk that the current wording of the Plan is not sound or legally compliant. The following comments relate to the Schedule to Policy SA 1 Proposed large sites for residential development (over 10 dwellings): Nailsea: Land at Youngwood Lane; Land at North West Nailsea; Land at Engine Lane The plan proposes to allocate land at Youngwood Lane, in addition to land at Engine Lane and North West Nailsea and other smaller allocations. While we welcome the site specific details/notes for land at Youngwood Lane, which we understand will require ‘Ecological issues to be addressed on a strategic basis as part of any future wider development‘ we consider the need for a strategic approach to addressing ecological issues applies equally to land at Engine Lane and Northwest Nailsea. Birnbeck Pier The site specific details/notes advise that ‘should development take place on the island it will need to take account of the sensitivity of the location and the need for suitable mitigation measures’. While this is welcome; Birnbeck Pier and Environs (as shown on the emerging policies map) is immediately adjacent to the Severn Estuary and the need to take account of the sensitivity of the location and for suitable mitigation measures will apply to development here as well on the island itself. Page 2 of 439 9 Nov 2017 15:53:40 Respondent Comment Comment Attached documents Name ID Natural England recommends that the site specific details/notes for the above sites are amended as described, in order to provide sufficient confidence that significant effects on European Sites will not occur as a result of the Plan. Wrington 1019201//1 Parish Council This is a comment by Wrington Parish Council (the Council) in response to a public consultation on proposed modifications to the Site Allocations Plan issued by NSC 18 September 2017. We have considered the various proposed amendments, including the Main (MM) and Additional Modifications (AM), and offer the following comments and recommendations. Note that these are directed primarily to the Inspector. The comment is in two parts, the first concerning various items which we hope to have changed or corrected, the more substantive second part relates specifically to modification MM25 which concerns a proposed housing allocation on a site at Cox’s Green, Wrington. Please let us know if you require further information or clarification of any of the points made below. Section 1. Comments on the consultation document, other than housing: 2. Policy Context We note and support the statements under Policy Context, in particular the key objectives listed under para 2.8. We previously commented that we were pleased to see Page 3 of 439 9 Nov 2017 15:53:40 Respondent Comment Comment Attached documents Name ID the clear commitment to protecting the Green Belt and valued countryside, and to preserving the character of the existing settlements, strategic gaps and green spaces. Also the commitment to sustainable development in line with the principles set out in the NPPF. However, it seems that some of the sites now proposed for housing in and adjacent to the villages could not be considered to provide ‘sustainable development’. As a result, there appears to be a conflict between NSC’s declared commitment to sustainable development under the NPPF and its approach to these site allocations. This is a concern. 3. Evidence Base We note the reference to the evidence base and key documents. It states under para 3.6 that a Sustainability Appraisal is a legal requirement. However, while there is further reference to a Scoping Report produced in 2007 and to a Main SA Report, we cannot locate the relevant Sustainability Appraisal. Habitat Regulations Assessment At the last consultation stage, October 2016, we commented: In the previous consultation we commented that we were disappointed that the Habitat Regulations Assessment (HRA) hadn’t been made available. We note the statement under para 3.10 that the HRA ‘will be submitted at the Publication Plan stage’, which might be expected to be now, or at least it should be if it’s to be made available for comment. It seems that the wording here has been carried over, with no explanation provided as to why the HRA hasn’t already been completed. We question why there is still no HRA available for comment. Page 4 of 439 9 Nov 2017 15:53:40 Respondent Comment Comment Attached documents Name ID Policy SA2 – Settlement Boundaries We very much support the retention of defined settlement boundaries and the principle of this policy. However, at the previous consultation stage we objected to the policy statement wording, which was felt in part to be unnecessary. From our experience settlement boundaries are accepted by residents and other landowners as an acceptable and defined limit on certain development. Any attempt to extend beyond the boundary generally results in strong objection, and not just from the immediate neighbours. We have noted that it is stated in para 4.13 ‘For the purposes of the Plan, ‘countryside’ is defined as all otherwise unallocated land outside defined settlement boundaries’. Hence, what is proposed here is potential development in the countryside, which appears to conflict with the policy aims elsewhere. While development might be allowed outside the curtilage of residential property it should not be outside the settlement boundary. As a result the policy wording should be amended to read: ‘The extension of a residential curtilage will be permitted provided that it does not extend outside the settlement boundary and would not harm the character of the surrounding area or the amenities of adjoining occupiers.’ Also, as it stands the policy wording and its probable interpretation are too subjective, particularly so as there is no limit proposed for any ‘extension into the countryside’. An alternative would be to set a defined physical limit to any extension outside the curtilage, and certainly if it’s to be outside the settlement boundary, with this always requiring a planning application so that neighbours, parish councils and other interested Page 5 of 439 9 Nov 2017 15:53:40 Respondent Comment Comment Attached documents Name ID parties are always provided with the opportunity to comment. This should not be considered to be permitted development. Policy SA5 – Local Green Space This policy is strongly supported. However, we were disappointed to find that two sites previously recommended for designation as Local Green Space have not been included since these fit with para 77 of the NPPF. Our view is that these sites should be designated as Local Green Space and we ask that they are reconsidered. These are: i. The Mike Bush Paddock, Wrington Hill This is a grass space surrounded by hedging, trees and fields, providing extensive views over Wrington Vale to the south and south-west. This is well used as a picnic area, for general recreational purposes and as a stop-off for people walking both up and down Wrington Hill and further afield. Site area 0.25Ha. ii. Glebe Field extension: We requested that the Local Green Space designation for the Glebe Field, which is located between Church Walk and the Glebe, Wrington, is extended to include the green public amenity area which has recently been created on the site of the old surgery car park under planning application 16/P/1423/F, ref ‘Change of use of land to public open space’. This amenity area is considered to be an extension to the Glebe Field and mirrors it in character and layout, with this stated in the land management plan submitted with the planning application and agreed by NSC. Page 6 of 439 9 Nov 2017 15:53:40 Respondent Comment Comment Attached documents Name ID Note that this proposed designation was referred to in the planning application and subsequent permission Environment 1020673//1 NSC letter 21-8-2017-site allocations Agency Thank you for referring the above Site Allocations Plan, which was received on 11 plan.rtf (101 KB) September 2017. The Environment Agency has no comments to make, in addition to those contained in its letter dated 21 August 2017, which has been attached for your information. Fisher German 10397985//1 CONSULTATION_plan.pdf (1.4 MB) (E Pattison) Thank you for your email to CLH Pipeline System Ltd dated 20 September 2017 regarding the above. Please find attached a plan of our clients apparatus. We would ask that you contact us if any works are in the vicinity of the CLH-PS pipeline or alternatively go to www.linesearchbeforeudig.co.uk our free online enquiry service.
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