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Dear Sir / Madam, Please Find Our Representations to the Main

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Dear Sir / Madam, Please Find Our Representations to the Main From: To: PlanningPolicy Subject: Response to Main Modifications - Landray Land Representatives [NLP-DMS.FID332475] Date: 02 March 2020 15:41:43 Attachments: image001.png image002.png Representations to the Main Modifications on behalf of Landray Land Representatives 02-03-2020.pdf 2019-11-06 Fosseway_Midsomer Norton - transport representations - full.pdf 31278 Site NRAD005 Additional Information 08.11.19.pdf LAND191037 SCM-01 P1.pdf Dear Sir / Madam, Please find our representations to the Main Modifications attached on behalf of our clients the Landray Land Representatives. We also provide additional information in relation to proposed allocation MN3 which was previously submitted to the Council on the 8th November 2019 – we would be grateful if it could also be provided to the Inspector. This includes a transport note prepared by Miles White, a design layout for the site demonstrating capacity for circa 152 dwellings and a letter providing additional information regarding delivery. Kind regards, Jenny Jenny Mitter Associate Director Lichfields, The Quorum, Bond Street, Bristol BS1 3AE lichfields.uk This email is for the use of the addressee. It may contain information which is confidential and exempt from disclosure. If you are not the intended recipient you must not copy, distribute or disseminate this email or attachments to anyone other than the addressee. If you receive this communication in error please advise us by telephone as soon as possible. Nathaniel Lichfield & Partners Limited is registered in England, no. 2778116. Our registered office is at 14 Regent's Wharf, All Saints Street, London N1 9RL. P Think of the environment. Please avoid printing this email unnecessarily. Planning Policy Mendip District Council Cannards Grave Road Shepton Mallet BA4 5BT SENT BY EMAIL Date: 02 March 2020 Our ref: 31278/01/AC/JMi/18266724v1 Your ref: Dear Sir / Madam, Local Plan Part II - Representations to the Main Modifications Our client, the Landray Land Representatives, have control of land allocated through Main Modification 62 (MM62) known as Land east of the A367 in Midsomer Norton. Our client supports the proposed allocation of the site for a minimum of 145 dwellings. Should the allocation be confirmed, it is intended to bring forward the development as quickly as possible. There has been significant interest in our client’s site to date from a number of the national housebuilders. If the site is allocated, our client would be keen to work with the Council to expedite the delivery of this site. Landray Land Representatives previously submitted an outline planning application on the site and while the majority of the technical reports prepared in relation to this application will require updating, it is considered that a new outline planning application could be submitted within 3-6 months. In our experience, submission of planning to first delivery should take circa 3 years for a site of this size and the site could be built out within 2-3 years. Alternatively, with an allocation, our client may choose to work with a housebuilder to bring forward a full planning application instead of an outline which would further expedite the planning process. In either scenario, it is considered that the site can make a meaningful contribution to the five year housing land supply within Mendip. In terms of capacity, a minimum of 145no. units is considered achievable. Thrive Architects prepared a layout for the site which was provided to the Council via email on 8th November 2019 which demonstrated that the site could comfortably accommodate 152no. dwellings. MM01 Landray Land Representatives support the Council’s intention to undertake a review of the Local Plan and for this new Plan to be submitted to the Planning Inspectorate within 3 years of commencement. The Local Plan Part 1 is now out of date and the Council is unable to demonstrate a 5 year housing land supply. It is therefore essential that the Council commence work on the Local Plan Review as soon as possible. It is hoped that the adoption of the Local Plan Part 2 can now be expedited to allow the Council to commence work on the new plan. Registered in England No. 2778116 Regulated by the RICS MM03, MM04, MM58 and the 505 Dwellings Background Paper Landray Land Representatives support the allocation of an additional 505 dwellings in the north east of the District, as set out in the Inspector’s Draft Schedule of Main Modifications. In order for the Plan to be found ‘sound’ these additional homes are required to be allocated in the north east of the District, in addition to the 9,635 allocated in the submission plan. The requirement for an additional 505 dwellings was originally included within Policy CP2 of the LPP1, with paragraph 4.21 stating that allocations should be focussed on the ‘north/north-east of the District, primarily adjacent to the towns of Radstock and Midsomer Norton’. Our client, whose site abuts the southern boundary of Midsomer Norton, therefore welcomes the Council’s revised commitment to bring forward these additional homes. It is recognised that BANES submitted a letter to the Council in November (Appendix 2 of the 505 Dwellings Background Paper) and further in December (Appendix 5 of the Second Addendum to the Sustainability Appraisal) which objected to the 505 additional dwellings being located in the north east of the District. This is on the basis that there was no absolute requirement for the development to be in the north east and instead LPP1 states (para 4.21) this ‘may include land in the north/north-east of the District primarily adjacent to the towns of Radstock and Midsomer Norton’ [Lichfields’ emphasis]. Mendip District Council have now undertaken this sustainability analysis and have concluded that three sites are suitable for allocation on the edge of Midsomer Norton. Our client supports the methodology which underpins the location choices for the 505 dwellings and considers that the additional growth as now proposed is entirely logical and has been shown to be the most sustainable option available and is in accordance with the LPP1 inspector’s original intentions. BANES points out that detailed and comprehensive work has not been undertaken to understand the effects on social and transport infrastructure as a result of these allocations. In response, we highlight that there is no requirement for detailed work to be undertaken prior to allocation. The detailed work will be prepared in support of the planning applications which will come forward and which will be subject to scrutiny by the highways teams of both local authorities. To provide some comfort, initial work prepared by a Miles White transport consultants on the impact of c.150 dwellings at the site indicates the development can be accommodated within the network at present with some additional work required on the impact on junctions to the north within the urban area of Midsomer Norton. In addition, Landray Land Representatives has also contacted the agent for the White Post site (proposed allocation MN01) to consider whether there is scope to work with this landowner and the LPAs to undertake the required cumulative traffic modelling to BANES’ satisfaction. This requirement can be adequately controlled through the proposed policy text. It is further noted that the six Preferred Options total a minimum of 536 dwellings which exceeds the 505 dwellings by circa 6%. We consider this a prudent allocation size given the Council have applied a 5% non- implementation rate to other allocated housing sites in the five year housing land supply analysis. MM62 and MM08 (Allocation MN03) Cross Boundary Traffic Impact Assessment It is recognised that there is a requirement for additional work on the capacity of the local highway network to accommodate growth. Our client has commissioned a Technical Note which was submitted to the Council on 8th November 2019 and which provides an assessment of this site’s impact and the further work which is required to understand traffic flows travelling north into the Bath and North East Somerset authority area (BANES) – this is appended for information. The technical note, prepared by Miles White, sets out that a wide range of sustainable transport options are available from the site, and can be promoted through the development, but that further detailed modelling of the junctions to the north in the urban area of Norton Radstock needs to be undertaken as part of any planning application at the site. Pg 2/4 18266724v1 In addition, our client has contacted the agent of the adjacent site which has also been allocated in draft through the Main Modifications (Land at White Post – MM60 – for 250 dwellings) to ascertain whether there is opportunity to work together and with the LPA’s, to scope and prepare the necessary cumulative traffic assessment. Our client is committed to understanding and addressing highways issues with the site. BANES’ objection is recognised but given the initial work undertaken by Miles White, there is significant confidence that the highways impact of the proposal can be effectively addressed through consultation with both authorities prior to the submission of an application on the site. Indeed, our client would be pleased to work with BANES, MDC and other landowners in order to understand the cumulative impact of the developments on the transport network and to bring forward a solution to the satisfaction of the LPAs. Further, the highway effects from circa 450 dwelling (395 to the south of Midsomer Norton) will not be severe under the terms of NPPF and will be capable of mitigation. Connectivity The requirement for improved connectivity is recognised, with potential solutions offered in the Technical Note which was submitted to the Council along with a supporting letter. This note identified that the accessibility of the site is good with a wide range of services, facilities and public transport available within appropriate walking and cycling distances.
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