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

FAO Stephen Bainbridge ([email protected]) [email protected] By email only 10 December 2019 Dear Mr Bainbridge

Planning Application 19/03103/OUT; Brewham Road North

Thank you for the opportunity to respond to this planning application. We submitted pre- application comments to Claremont Planning on 9 September 2019. 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. Our comments can be grouped in the following categories: • One Planet Bruton • Climate Change, flood risk and net zero carbon development • Biodiversity • Cumulative impacts of development in Bruton

1. One Planet Bruton

One Planet Bruton (www.oneplanetbruton.org) is a community-led response to Bruton Town Council's declaration of a Climate and Ecological Emergency. The environmental charity Bioregional (https://www.bioregional.com/) came up with the concept of One Planet Living (https://www.bioregional.com/one-planet-living i.e. leading happy lives within a fair share of the earth’s resources) 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 • Equity and local economy - Creating safe, equitable places to live and work which support local prosperity and international fair trade

191210 OPB response to Brewham Road North 19-03103-OUT.docx Date printed: 10 December 2019 Page 1 of 7 • 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 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 website has examples of where this has been done. Recent examples include Elmsbrook in Bicester, Oxfordshire, Springfield Meadows in Oxfordshire, and Mincing Lane, Chobham.

2. Climate change, flood risk and net zero carbon development

Zero carbon 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.

191210 OPB response to Brewham Road North 19-03103-OUT.docx Date printed: 10 December 2019 Page 2 of 7 The development should support use of alternative methods of construction, especially those that 'lock up' or sequester carbon, e.g. straw bale, hempcrete, to minimise the lifecycle carbon emissions of the new development. The 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.

Flood risk management 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 has the potential to contribute to surface water flooding 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. This will prevent water from the site impacting on the surrounding land, even during extreme conditions.”

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-year event in a few years’ time with a 1 in 100 event being far more extreme then. The relationship is not linear. Furthermore, the rate of discharge from the existing greenfield site currently leads to flooding on the Brewham Road at times. With development approved for the field immediately south of Brewham Road, this could lead to increased risk of flooding there.

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

191210 OPB response to Brewham Road North 19-03103-OUT.docx Date printed: 10 December 2019 Page 3 of 7 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.

3. 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). In our opinion, the target should be higher than 10%, set at 20%. This is consistent with Lichfield District Council which has introduced a supplementary planning document (SPD) that requires a 20% net gain in biodiversity in all new development projects2.

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.

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

2 https://www.lichfielddc.gov.uk/downloads/file/1112/supplementary-planning-document-biodiversity-and- development 3 https://www.wildlifetrusts.org/sites/default/files/2018-05/homes_for_people_and_wildlife_lr_-_spreads.pdf

191210 OPB response to Brewham Road North 19-03103-OUT.docx Date printed: 10 December 2019 Page 4 of 7 o More than compensating for any nature that is lost • All residents having lasting access to nearby nature”.

The table below (prepared by the Berkshire, Buckinghamshire and Oxfordshire Wildlife Trust) sets out features in developments to encourage biodiversity, and their associated benefits for people.

Biodiversity Reduces Reduces air Reduces benefits urban heat pollution water run- island effect off

Houses and Gardens: Gardens: Fruit trees in each back garden; Wildflower turf making up ✓ ✓ ✓ ✓ part of lawn in each garden; Log piles; Hedgerows making up at least one boundary; Garden walls with overwintering shelter for insects

Green roofs on garages and public buildings ✓ ✓ ✓ ✓ Green walls ✓ ✓ ✓ ✓

Built in bird boxes including swift bricks, swallow and house martin ✓ and garden birds. Built in bat boxes, bricks and lofts – suitable for crevice dwellers and ✓ roof void dwellers.

Street network and small green spaces: Street trees – tree lined streets; woodland copses. Development ✓ ✓ ✓ ✓ should have 25% canopy cover once trees mature Wildflower rich road verges and green corners etc. with loggeries, ✓ ✓ ✓ hibernacula, bug hotels Climbing plants on fences and walls ✓ ✓ ✓ ✓

Any shrubs chosen to maximise: berries for winter bird food; flowers ✓ for pollen and nectar. SUDS schemes including biodiversity ✓ ✓ ✓ ✓

Green Spaces (In addition to large scale habitat creation and management): Wildflower edging / shrubs around sports pitches, play equipment, ✓ ✓ ✓ kick-about areas. Hedgerows and buffers: management for wildlife ✓ ✓ ✓ ✓

Long grass / bare ground / rockeries / hibernacula for reptiles ✓ ✓ ✓

Clean-water wetlands / ponds / ditches with surrounding wildlife grass ✓ ✓ ✓ habitat for amphibians – can be part of SUDS and independent of SUDS. Woodland ✓ ✓ ✓ ✓ Network of green and blue corridors without lighting ✓ ✓ ✓ ✓

Food growing spaces / allotments ✓ ✓ ✓

Farmland birds The Planning Statement refers to the Phase 1 Habitat and Preliminary Protected Species Survey which identifies that the “habitat that is to be lost through the development of the site is of low ecological value, as arable farmland…”. Development of this site could have a significant impact on farmland birds which have experienced substantial declines in numbers over the past few decades. DEFRA has provided guidance to competent authorities (including local authorities) on how to comply with the legal requirements of the Conservation of Habitats and Species Regulations 2010 as amended in paragraph 9a of the Conservation of

191210 OPB response to Brewham Road North 19-03103-OUT.docx Date printed: 10 December 2019 Page 5 of 7 Habitats and Species (Amendment) 2012 Regulations). The guidance is available at: https://www.gov.uk/guidance/providing-and-protecting-habitat-for-wild-birds. The compensation proposals must provide sufficient evidence that they will “provide habitat that allows bird populations to maintain their numbers in the areas where they naturally live” in relation both to “wild birds in decline” and to “wild birds with healthier populations” (as required by DEFRA’s guidance).

Off-site compensation should be provided for farmland birds where these are impacted (and on-site compensation where this is possible; zoning to control public access would be needed since many farmland bird species are not suited to built-up areas or disturbance by people, dogs and cats) to ensure that populations are maintained in line with the above quoted legislation.

The most recent ecological records should be sought from Somerset Environmental Records Centre (SERC) in addition to ecological surveys being carried out in the right survey season.

Impacts on farmland birds will not be captured in the biodiversity metric for calculating net biodiversity gain and therefore need to be mitigated separately to this

Lighting If it goes ahead, this development will introduce lighting into an area that is currently unlit. The introduction of artificial lighting may affect bats foraging at night along the hedgerows. Steps must be taken to minimise light pollution, in terms of the type of lighting used, how much is used and where it is used, as well as design of routes to avoid light pollution into wildlife-rich areas of the sites, from fixed lights as well as vehicles, particularly where there are likely to be species of wildlife affected by light at night, e.g. bats and badgers. A key principle will be to keep dark corridors where bats are using lines of trees and hedgerows as flight paths. Lighting will have to be managed carefully to ensure it is of a low spill variety, a spectrum that minimises impacts on birds, bats and insects, and directed into the development. We suggest that there should be conditions or covenants to control the type, power of and direction of security and outside lighting that can be installed on homes and other buildings.

4. 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, the day before this Application was submitted, South Somerset District Council (SSDC)’s Regulation Committee in Yeovil overrode the 9 October 2019

191210 OPB response to Brewham Road North 19-03103-OUT.docx Date printed: 10 December 2019 Page 6 of 7 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.

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]

191210 OPB response to Brewham Road North 19-03103-OUT.docx Date printed: 10 December 2019 Page 7 of 7