One Planet Bruton CIC C/O Bruton Community Office 26 High Street Bruton Somerset BA10 0AA

One Planet Bruton CIC c/o Bruton Community Office 26 High Street Bruton Somerset BA10 0AA

Planning Team South Somerset District Council Brympton Way Yeovil BA20 2HT

By email only 8 October 2020

Dear Ms Gallagher

Planning Application 20/02297/OUT; Land North Of Brewham Road

Thank you for the opportunity to respond to this planning application. We gave our comments orally at an Emergency Bruton Town Council meeting on 28 September 2020. At this stage, we object to this application: • It does not adequately respond to the Climate and Ecological Emergency declared by both South Somerset District Council and Bruton Town Council. • The Flood Risk Assessment and proposed measures for flood management are inadequate. • There are inaccuracies in the information provided for sewage disposal. • There is no commitment to Biodiversity net gain. • The cumulative impacts of development in Bruton need to be assessed.

1. Climate and Ecological Emergency

Somerset County Council, South Somerset District Council and Bruton Town Council all declared a Climate and Ecological Emergency in 2019 and all commit to carbon neutrality. Bruton has set a target to be carbon neutral by 2030.

Zero Carbon development The Design and Access Statement simply states that the energy efficiency of the buildings will go beyond the requirements of Building Regulations and designs will be able to be adapted for renewable energy in the future. This is not good enough. Given South Somerset District Council and Bruton Town Council’s declaration of a Climate Emergency with Bruton Town Council committing to a carbon neutral by 2030 target, that housing built now will still be in place by 2050, and that climate change is predicted to have a significant effect on people and wildlife, we believe that all new development should mitigate and adapt to climate change and should be net zero carbon from the outset.

The development should support use of alternative methods of construction, especially those that 'lock up' or sequester carbon, to minimise the lifecycle carbon emissions of the new development. The

201008 OPB response to Brewham Road North 20-02297-OUT.docx Date printed: 08 October 2020 Page 1 of 5 construction industry needs to consider lifecycle carbon emissions in its activities and to minimise these, so embodied carbon needs to be considered alongside making new buildings as energy efficient as possible.

Building for the impacts of climate change The Design and Access Statement refers to orientating buildings to maximise passive solar gain. There are other impacts of climate change that need to be considered. Climate change is predicted to lead to greater intensity and frequency of rainfall, hotter drier summers, higher wind speeds. Buildings must be futureproofed for a changing climate1, e.g. avoid overheating through orientation of buildings, location of windows, and shade through tree planting; SUDS and increased size of guttering for increased rainfall; fittings attaching roofs and facades able to withstand higher winds. Building better- insulated, air tight buildings means that indoor air quality must be considered.

2. Flood Risk Assessment and mitigation measures

South Somerset District Council’s Infrastructure Delivery Plan stated that risk of flooding locally in Bruton means that the Environment Agency will prepare a surface water management scheme. We are not aware of this being publicly available. Bruton is a town that has been seriously flooded several times in the past and is protected by a substantial dam upstream of the dam. This proposed development is downstream of the dam and therefore has the potential to contribute to surface water flooding downstream of the development in Bruton.

The Design and Access Statement that “Surface water from the highways and roofs within the development will be directed into an attenuation basin which will drain into the River Brue via a piped connection to the ditch to the east of the Site. The rate of discharge will not exceed the rate of discharge from the existing, greenfield Site and will allow drainage of the development without increasing flood risk within the ditch and the River Brue. The attenuation basin will be designed with capacity to hold runoff from the extreme 1 in 100 year + 40% Climate Change storm and that this will prevent water from the site impacting on the surrounding land, even during extreme conditions.”

The Flood Risk Assessment states that “Surface water runoff from the development site will be managed on site for storms up to the 1:100 year +40% climate change event, without flooding.” It also states that “Should the onsite drainage system fail under extreme rainfall events or blockage; flooding may occur within the site. Any resultant floodwater will be routed along highway corridors in a south easterly direction following the natural topography, away from the proposed dwellings. The proposed pond is located in the south eastern corner of the site, downslope of the proposed development area, therefore design exceedance flows from the pond will not impact on the dwellings.”

While this may be in accordance with the National Planning Policy Framework and Environment Agency regulations, there is increasing awareness that this country’s approach to flood risk management simply isn’t fit for purpose, particularly given the increasing intensity and frequency of storms. The return period of flood events is increasing. A 1 in 100-year storm in flooding event now may be a 1 in 40, 30 or 20-year event in a few years’ time with a 1 in 100 event being far more extreme then. The relationship is not linear. Furthermore, Environment Agency projections for Somerset suggests that peak river flows are expected to increase of around 40% by 2080 (over and above 2013/14 levels), although under the more severe climate change scenario increases of 85%

1 https://www.arcc-network.org.uk/design-for-future-climate/

201008 OPB response to Brewham Road North 20-02297-OUT.docx Date printed: 08 October 2020 Page 2 of 5 (over and above 2013/14 levels) are possible by the same date, it is best practice to plan for this higher level."2 In this scenario, the provision in the current plans is inadequate and could lead to flooding in Brewham Road contribute to an increased risk of flooding downstream in Bruton during extreme weather events.

Reliance is being placed on a single attenuation basin in the south east corner of the site with development to the north and west of it. There is no mention of other SUDS measures being adopted to slow or attenuate water within the site. If the attenuation basin transpires to be under-sized, there is no scope to extend the size of it. Deepening it will not help because of high ground water levels at times of high rainfall. Residents will need to understand that the attenuation pond should be empty most of the time in order to accommodate water at times of high rainfall. We suggest a greater area is allocated at the south of the site to accommodate water and to enable it to be enlarged in the future.

3. Sewer capacity

The appendices to the Flood Risk Assessment include an email exchange between the consultant and Wessex Water that refers to a proposed development of 50 dwellings, not 70 dwellings. Confirmation should be sought from Wessex Water for the actual number of homes (up to 70) that permission is being sought for.

4. Biodiversity

Biodiversity net gain Paragraph 170 of the National Planning Policy Framework 2019 states that "Planning policies and decisions should contribute to and enhance the natural and local environment by ... d) minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures. The draft Environment Bill contains a specific target of 10% biodiversity net gain (measured using the Defra or other locally-approved metric).

The application refers generally to improving biodiversity. Measurable biodiversity net gain will need to be demonstrated for this site, together with details for managing green infrastructure and habitats and monitoring the extent to which biodiversity net gain is achieved, and how any shortfalls will be met.

Biodiversity in the built environment In our opinion, all new development should be exemplary in terms of integrating biodiversity features. Climate change will bring warmer summers and increased frequency and intensity of storms and rainfall. As well as providing biodiversity benefits and helping to reduce air pollution, incorporating natural features into developments will help to adapt to a changing climate by reducing the urban heat island effect and water run-off.

2 https://www.adaptingthelevels.com/climate-impacts-somerset

201008 OPB response to Brewham Road North 20-02297-OUT.docx Date printed: 08 October 2020 Page 3 of 5 The Wildlife Trusts published ‘Homes for People and Wildlife: How to build housing in a nature- friendly way’3 which sets out what a good, nature-rich housing development looks like. According to this, “All housing developments must result in: • A measurable improvement for wild species and habitats, which means: o Avoiding any loss or damage of wildlife sites o Designing in existing habitats o Creating new habitat o More than compensating for any nature that is lost • All residents having lasting access to nearby nature”.

5. Cumulative impacts of development in Bruton

The 2019 South Somerset District Council Local Plan Review included the following housing numbers for Bruton for the period 2016 to 2036:

• 152 new homes (net) required o of which 87 are completed or committed (as at 31 March 2018) o 65 to be delivered

On 19 November 2019, South Somerset District Council (SSDC)’s Regulation Committee in Yeovil overrode the 9 October 2019 rejection from local Area East Councillors, and voted to approve the 60- home Brewham Road southside development in principle, together with its dangerous pedestrian access proposals. The Brewham Road South site was not identified in the Local Plan Review.

We are concerned that if the Brewham Road North development is approved, the cumulative impacts of development in terms of flood risk, traffic, air quality will have a negative impact on Bruton. We recommend that the cumulative impacts of development in Bruton be assessed and an air quality assessment be carried out.

6. One Planet Bruton

One Planet Bruton4 is a community-led response to Bruton Town Council's declaration of a Climate and Ecological Emergency. The environmental charity Bioregional5 came up with the concept of One Planet Living6 (i.e. leading happy lives within a fair share of the earth’s resources, leaving space for wildlife and nature) in response to the fact that if everyone in the world lived as we do in the UK, we would need three planets to support us. We are working with Bioregional's One Planet Living framework which consists of ten principles and has been used by organisations large and small, developers, London 2012, cities and local authorities in the UK and around the world. The ten principles are: • Health and happiness - Encouraging active, social, meaningful lives to promote good health and wellbeing

3 https://www.wildlifetrusts.org/sites/default/files/2018-05/homes_for_people_and_wildlife_lr_-_spreads.pdf 4 www.oneplanetbruton.org 5 https://www.bioregional.com/ 6 https://www.bioregional.com/one-planet-living

201008 OPB response to Brewham Road North 20-02297-OUT.docx Date printed: 08 October 2020 Page 4 of 5 • Equity and local economy - Creating safe, equitable places to live and work which support local prosperity and international fair trade • Culture and community - Nurturing local identity and heritage, empowering communities and promoting a culture of sustainable living • Land and nature - Protecting and restoring land for the benefit of people and wildlife • Sustainable water - Using water efficiently, protecting local water resources and reducing flooding and drought • Local and sustainable food - Promoting sustainable humane farming and healthy diets high in local, seasonal organic food and vegetable protein • Travel and transport - Reducing the need to travel, encouraging walking, cycling and low carbon transport • Materials and products - Using materials from sustainable sources and promoting products which help people reduce consumption • Zero waste - Reducing consumption, reusing and recycling to achieve zero waste and zero pollution • Zero carbon energy - Making buildings and manufacturing energy efficient and supplying all energy with renewables

We have set up One Planet Bruton CIC. It is a Community Interest Company limited by guarantee. Its objects are to carry on activities which benefit the community and, in particular, to work with Bruton's residents, businesses and other organisations to enable current and future residents to live happy, healthy lives within the limits of the planet, using Bioregional's One Planet Living framework. Our specific objects are to support, develop, initiate and manage community projects and interactions in line with the ten One Planet Living principles.

If , and it is a big if, this site is to be developed for housing and this application is approved, we urge that next design phase uses the One Planet Living framework to embed sustainability in the development. Bioregional’s website7 has examples of where this has been done. Recent examples include Elmsbrook in Bicester, Oxfordshire, Springfield Meadows in Oxfordshire, and Mincing Lane, Chobham.

Thank you for the opportunity to respond to this. If you require any further clarification or information, please get in touch.

Yours sincerely

Jane Durney Co-director and co-founder, One Planet Bruton CIC Chair, Bruton Climate and Ecological Emergency Working Group Member, Bruton Community Partnership [email protected]

7 www.bioregional.com

201008 OPB response to Brewham Road North 20-02297-OUT.docx Date printed: 08 October 2020 Page 5 of 5