FINAL Land Alloc MDC Feb 18 Millfield School STR003
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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 Neil Chapillon (Estates Manager) Agent Name: Lee Wright Organisation (if applicable): Millfield School Company Name: Wright Consult LLP Address: Bay Tree, Cooks Lane, West Cranmore, Shepton Mallet, Somerset Postcode: BA4 4RH Email: [email protected] Tel: 07778 747072 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 landowners Millfield School Please indicate the document to which your representation relates (e.g. policy, paragraph STR003 Land at Somerton Road, Street 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 No 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 STR003 Land at Somerton Road, Street Introduction & Summary This site (STR003) has been put forward in the current Pre-Submission Consultation tranche of the land allocation process, as a site that is suitable for up to 200 dwellings. The comments herein are provided on behalf of Millfield School, a significant local stakeholder and employer in Street and the surrounding environs. Millfield School is sympathetic of the national need to significantly increase housing; as well as the local need, where housing needs to be allocated in Street. Not at least, new housing has the potential to benefit the school in additional pupils and the provision of housing for staff and for parents of existing pupils. The school must however, first and foremost focus on child safety; and this forms the basis of this objection to housing in this location, lying adjacent to the school and having a direct impact on traffic movements on the highway network around the school. The comments provided herein firstly look at the issues of highway safety impacts relating to housing in this location; secondly as agent, we have looked at the wider Local Plan Part II issues in respect of the proposed methodology, as to the allocation of sites in Street and the wider Mendip District; and thirdly, mitigating policy that is requested to be incorporated into proposed Local Plan Policy ‘ST1: Land West of Somerton Road’, if this site is ultimately allocated. 1. The Impacts On Millfield School & Child Safety Proposed Local Plan Policy ST1, looks to allocate land for housing immediately west of the Millfield School campus in Street, with access anticipated to be off Somerton Road. Somerton Road (B3151) runs along the west boundary of the school and is one of three major tributaries into Street that feeds the south. The other two tributaries being the A39 feeding from the north (Glastonbury) and the west (Bridgwater and Taunton). 1 See our Online Guidance note on what these terms mean 2 Mendip Local Plan Part II: Sites & Policies - Issues and Options Consultation Somerton Road is already an extremely busy route, with traffic from local and regional conurbations to the south that include Yeovil, using this route. It is also used as a short cut for traffic using the A303 to access Clarks Village and Glastonbury. The proposed site lies immediately opposite the west end of Keen’s Elm Lane that in turn intersects the school grounds and provides vehicular access to the school sports fields and swimming pool. Keen’s Elm Lane is used for coach and bus access to these facilities, as well as providing a well used shortcut with Butleigh Road and with traffic regularly travelling in excess of the posted 40mph speed limit. In broad terms, the main campus has three adjoining roads, these being Butleigh Road that serves the main entrance as well as Somerton Road and Keen’s Elm Lane that serves other key access points to the campus. Children living in Street cross Somerton Road to access the school and many day children are dropped off and picked up in Somerton Road, as so to avoid the peak congestion of the main entrance in Butleigh Road. Since 2007, www.crashmap.com records 13 accidents on Somerton Road and 6 accidents on Butleigh Road; with 2 of the Butleigh Road accidents and 4 of the Somerton Road accidents, being located at the respective junctions with Keen’s Elm Lane. Crashmap does not record the many near misses that take place on a regular basis. Both Somerton Road and Keen’s Elm Lane do not benefit any traffic calming measures, traffic regularly exceeds the posted speed limit and the school has held recent meetings with the County Highway Authority regarding road safety and understand that speed testing has been undertaken, to further aid discussions regarding possible traffic calming measures. As a result of the already congested nature of Somerton Road and the lack of traffic calming or other safety measures, Millfield School objects to further housing on Somerton Road that can only serve to increase traffic movements on the highway network immediately around the school and thus, having a direct and negative impact on child safety. 2. Local Plan Part II – Land Allocation Methodology Comments MENDIP LOCAL PLAN PART II PRE-SUBMISSION CONSULTATION Housing and Employment Allocations Section 10. Mendip Towns 10.3 Street, states (italics): ‘10.3.7 Street is identified in Local Plan Part I as a principal settlement. Core Policy 8 (Street Parish Strategy) indicates 1,300 new homes are to be delivered over the plan period in the town. 742 homes were completed to March 2017 and total identified supply is 1,235 dwellings leaving a residual of 65 dwellings against the Plan requirement. This includes the strategic site allocated to the west of Brooks Road. 10.3.8 Since Plan adoption, there has been limited progress to develop a masterplan for the strategic site. With development on the Houndwood site nearing completion, further allocations are warranted to support supply over the plan period.’ The NPPF requires that each Local Planning Authority demonstrate that there is a five year supply of deliverable sites for housing development. It is therefore imperative the council only allocate 3 Mendip Local Plan Part II: Sites & Policies - Issues and Options Consultation sites that are ‘deliverable’ and ‘developable’, as this will provide the best chance of five year housing land supply targets being fulfilled. It is confirmed by the council that the strategic site west of Brooks Road is a stalled site and it is neither imminently ‘deliverable’ or ‘developable’ and as a result, the council should be investigating the reasons as to why the site is not being moved forward and be putting pressure on the landowner and/ or developer to develop the site. However, allocating yet further housing such as STR003 on large sites, distant from town facilities that are likely to be difficult to bring to development, will do little to fill any imminent shortfall in housing sites and particularly so with this site; that has wide ranging issues relating to landscape, ecology and flooding: as identified in proposed ‘Policy ST1 Land West of Somerton Road’. Furthermore, the proposed site looks to develop some 11.6ha of land at a very low density of 17.2 dwellings per hectare, which presents a very uneconomic and underuse of land in a town location where a much higher density, anywhere upwards of double the density proposed, would normally be expected. We contest that the council approach in allocating such a high proportion of required housing to the market towns and using larger sites, is flawed.