Objection to Application 20/P/2990/Out - Development of Land West of Butts Batch

OBJECTION TO APPLICATION 20/P/2990/OUT - DEVELOPMENT OF LAND WEST OF BUTTS BATCH

View looking south-west from Mike Bush Paddock picnic area – bright green field (centre) is the proposed development site. Grade 1 listed church in foreground.

Introduction

We object in the strongest possible terms to this application. Keep Wrington as Wrington (KWaW), a group of residents against inappropriate development, regard this application as an example of just that, an inappropriate development of a rural setting. It fails to satisfy any of the criteria for developments set out by North Somerset Council or the National Planning Policy Framework, nor does it have any merit or offer any benefits to the community. It must be rejected for all the reasons set out in detail below.

We would like to also point out that the group are not against local development per se, and would point to the forthcoming proposal to re-develop the brownfield site of light industrial units at the old Gatcombe Farm site, as cited by Dr Liam Fox MP at our village meeting on 7th January 2021 and in the Parish Council objection (20_P_2990_OUT-12_01_21_-_OBJECTION_LETTER_- _WRINGTON_PARISH_COUNCIL_COMMENTS-3003687) as an example of a sustainable development.

It is also worth bringing to your attention, whilst canvassing the opinions of villagers about this development by going door-to- door between periods of covid-19 lockdown, it quickly became apparent how ineffectual the public consultation by the applicant had been. The assumption that everyone could see the proposal online was incorrect and the email exchanges between Jonathan Coombs, Steve Hogg and Barrie Taylor (Community involvement 20_P_2990_OUT-STATEMENT_OF_COMMUNITY_INVOLVEMENT- 2988490) shows how reluctant the applicant was to delay this application and push it forward, regardless of the on-going pandemic.

KWaW wish to raise the concern that a major development has been presented during a time when full public participation is not possible. These restrictions have resulted in a reduced Planning committee (13 councillors instead of 27) plus a number of other restrictive emergency planning measures; the over reliance of online content due to restricted travel movements to see plans at the Town Hall, instead of a presentation at the village hall; and the inability to have a public meeting in Wrington to allow all villagers to have a voice.

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The applicant has acknowledged the village population is elderly (Planning statement 20_P_2990_OUT-PLANNING_STATEMENT- 2988477) and yet failed to take this into consideration, leading to many residents without computers or sufficient IT skills being made aware of the full details and unable to object (as reported in Somerset Live). This cannot be right and does not reflect well on the applicant.

Executive summary of objections

1. Climate Change (North Somerset Council Core Strategy CS1, SPP DM2, Paragraphs 118b,148,151 and 170 NPPF)

2. Flooding and contamination of water systems (CS3, SPP DM1 – Flooding and Drainage and paragraph 175 NPPF)

3. Biodiversity and impact on protected species (CS4, DM8 and paragraph 175 NPPF)

4. Fails to meet Service village guidelines (North Somerset Council Core Strategy 32)

5. Adverse Visual Impact on village and landscape (CS5, SPP DM3, DM32, CS32 and North Somerset Landscape Character Area designated J2 'to conserve the peaceful, rural nature of the landscape with intact pasture and field boundaries….

6. Traffic and Road Safety will be affected with an increase in traffic by private vehicles on the narrow lanes that are the only access to the village and major commuting routes, affecting road safety for all users and increase risk of serious collisions at access points on to A38 and A370 (CS32, SPP DM24 Paragraph 102 and 103 NPPF)

7. Archaeology and historical finds around the site (CS5 and National Planning Policy Framework 126-141)

8. The land has not been brought forward in a North Somerset Strategic Housing Land Availability Assessment, as required for more than 25 dwellings (CS32).

9. Pedestrian safety to and from the village due to lack of footway, particularly people with a disability (DM24 and DM25).

The following report sets out in detail each of the points listed above, showing why this application is not sustainable and fails to reach the required standard for a major development. Therefore, it must be rejected by North Somerset.

1. Climate Change (North Somerset Council Core Strategy CS1, SPP DM2, Paragraphs 118b,148 and 151 NPPF)

The Wrington Parish Council report points out that this application only mentions the Climate Emergency in one brief sentence and nowhere in the report is there any reference to energy saving measures to enable this development of 71 houses to be carbon neutral.

Any proposal of this size should have these measures as a matter of course. Failure to do so means that the applicant has simply failed to address this problem and has therefore failed to meet the criteria set out in CS1 – (point 1) “development should demonstrate a commitment to reducing carbon emissions, including reducing energy demand through good design, and utilising renewable energy where feasible”.

The policy goes on to say - (point 4) “developments of 10 or more dwellings should demonstrate a commitment to maximising the use of sustainable transport solutions, particularly at Weston-super-Mare. Opportunities for walking, cycling and use of public transport should be maximised through new development and in existing areas emphasising the aim to provide opportunities that encourage and facilitate modal shift towards more sustainable transport modes”.

The developers attempt to fulfill this criterion is totally inadequate. There is much referencing of North Somersets aspiration to use the old Wrington Light Railway line (often referred to as the Strawberry Line) as a cycle way and yet is quick to point out that this is beyond its control. The applicant does not even have a right of way on to the old railway line despite informing some of its own consultees that it did (Transport, Drainage report et al). Therefore this ‘benefit’ to the local community can be discounted. As said by District Councilor Hogg at the village zoom meeting on 7th January 2021, ‘there is not a cat in hells chance of the Strawberry Line being opened anytime soon. It is not a realistic argument to say that this is going to be open. There are too many obstacles and too many hoops to jump through before the Strawberry Line becomes a reality… so I don’t think this carries much weight at all’ (Wrington village Zoom meeting 7th January 2021). All references to this alternative to private car use can then be discounted as irrelevant and cannot be allowed to influence a decision on this application.

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The references to walking to local employment and facilities is also deeply flawed (Residential travel plan 20_P_2990_OUT- RESIDENTIAL_TRAVEL_PLAN-2988493). This ignores the fact the only entrance to the proposed site is via Half Yard. This is outside the village boundary and therefore beyond any restrictive speed limits. It also requires anyone walking into the village to traverse the section of Butts Batch and Station Road where there is no footway (already detailed by many local objectors and will be covered in greater detail under Point 9). Suffice to say here, that we echo the Parish Council’s view that the whole submission lacks credibility. As an example, I would point to the entry for Wrington Vale Medical Centre in Table 2.1. Not only is the name incorrect, we would also point out the hazards created by the pavement-less narrow country lane (60mph speed limit) to Lower Langford, the single width humpback bridge on a blind bend at Black Moor, the narrow pavement-less lane in Lower Langford and the regular flooding of Half Yard highlighted by the applicant’s own consultant (Drainage 20_P_2990_OUT- FLOOD_RISK_ASSESSMENT_AND_DRAINAGE_STRATEGY-2988469).

In addition, the mention of Gatcombe Farm Industrial Estate in this table is intended to convey access to local employment. This is inaccurate and misleading, as this is the site due for imminent change of use to provide residential dwellings on a brownfield site (see Introduction).

We also wish to highlight a point about climate change that has been made by a long-time resident of the village. They correctly point out that the soil in this field has not been disturbed for centuries, due to the history of the village being used for grazing sheep belonging to the Abbot of Glastonbury. Recent studies and reports have drawn attention to the amount of carbon that is sequestered in soil and how it rivals forests for storing CO2 (Science for Environmental Policy Briefing for the European Commission - 24th June 2016). This approach to carbon storage is supported in paragraph 118b NPPF 2019.

Therefore, when the foundations for 71+ homes are dug at depths of at least one metre (Soil report 20_P_2990_OUT- GROUND_INVESTIGATION_REPORT-2988505) a huge amount of CO2 will be released, adding to the environmental damage this proposal will do and further exacerbating the climate emergency and the built-on land will no longer be able to store carbon through the breakdown of organic matter. Once again, it shows the importance of preserving greenfield sites across the county and prioritizing brownfield sites (like Gatcombe Farm).

Natural England’s map of Agricultural Land Classification shows the field to be in an area classified as Grade 2 and 3 (Good to Very Good). As such, paragraph 170. NPPF 2019 states “Planning policies and decisions should contribute to and enhance the natural and local environment by: a) protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with their statutory status or identified quality in the development plan); b) recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland”.

Agricultural Land Classification map (with key)

Our final point on climate change is the increased use of private cars this site will inevitably cause. This point is covered further in the report under Point 6, but in the context of the climate emergency, the lack of local infrastructure, employment or leisure facilities means that these houses are being built in the wrong place and the number of additional private vehicle journeys into neighbouring towns and cities will cause an increase in air pollution and carbon emissions. This is particularly so in Bristol, which will be the place of employment for at least 80% of residents (using the applicant’s data on the 2011 Census). Therefore, building in Wrington does have a detrimental effect on the residents right across the council’s area and so this affects everyone, not just the village. A holistic approach to sustainable planning is required, not piecemeal and speculative developments on land that has not been allocated in the Site Allocation Plan (Point 8 below).

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All these factors demonstrate this application fails to satisfy the standards to be called sustainable and so, with all the issues raised above, it is completely unacceptable that the council officer’s response was a one line “I have no objections to the above planning application” (20_P_2990_OUT-20_01_2021__ENVIRONMENTAL_PROTECTION-3006704).

It is noted that this is the same officer contacted by the applicant in March 2020 (email correspondence Appendix C). We feel that he has not considered, or is unaware of, the wider environmental and biodiversity impact this development would have on the environment, outside his area of expertise of soil contamination. We feel a fuller response is justified to uphold the council’s stated aims in its Climate Emergency statement.

2. Flooding and contamination of water systems (CS3, SPP DM1 – Flooding and Drainage and para. 175 NPPF)

The submitted document Drainage 20_P_2990_OUT-FLOOD_RISK_ASSESSMENT_AND_DRAINAGE_STRATEGY-2988469 mainly concentrates on drainage to the South and gives little information to the North of the site. It even goes as far to say that it did not wait for replies from Wessex water as to the suitability of the 375mm surface drain or the foul water drain. We can assure the council that had they waited they would have been informed that these drains are already at their maximum capacity (see below).

Flooding in Westward Close and by Wiltons, caused by the same 375mm drain referenced in the drainage strategy as being adequate for the increased surface water run-off from this development. Clearly it will not be, as rain-water already backs up, even with the field holding a vast amount of water in the soil.

Sewage water leaking from a drain inspection cover in a garden in Wiltons,

which then flowed and pooled in a lower section.

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Once again, we point out that the applicant should not have been in such a rush to get this proposal through the consultation phase (see Introduction) and taken the time for their own consultants to complete reports to a satisfactory standard.

Their report does note that the north east corner of the site floods, causing localized ‘ponding’. The conclusion states that this will not affect the new houses as they are not being built there. This simple assertion is crass and fails to take into account the two neighbouring properties in Westward Close or those in Wiltons. These properties are set lower than the site and would have additional ‘ponding’ from the extra surface water run-off caused by the field now being concrete and tarmac and therefore flooding will occur. This is obviously unacceptable and yet has been ignored in the report (see photograph below)

This photograph shows the gradient of the field falling to the north-east corner. The farmer has the area fenced off as it is so water-logged, demonstrating the ‘ponding’ referred to in the drainage report will increase the risk of flooding nearby houses.

The report goes on to warn that an extreme event could flood the only access from Half Yard and that all residents need to be aware and have a flood risk plan in place. Whilst this may be an extremely unlikely scenario, climate change has led to frequent extremes, as seen at Whaley Bridge during the summer month of August 2019. Such an event is classified in the report as ‘danger to all’ and to protect future residents this development should be rejected now.

A point not covered in the drainage report is the pollution that would be carried into the surrounding water systems and affecting the ecosystem. The Natural England guidance for Special Areas of Conservation designated under the Habitat Regulations 2017 (which this site is in Zone B) states ‘greater scrutiny of plans or projects that will increase nutrient loads (nitrates and phosphates) under the Dutch N resolution (Natural England advice to LPAs dated 20th August 2020). The drainage report acknowledges that SuDS are not an option on this site due to the soil type and so polluted run-off is inevitable, regardless of the water attenuation scheme that has been proposed.

On the subject of the water attenuation scheme, we would draw your attention to the on-going development at Cox’s Green. Two years after permission was granted, the developer has only just completed the drainage works for this. The intention was to have a pond and has now been forced to build an enormous lake (see photograph below).

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Cox’s Green flood water attenuation scheme, 2 years on and still not finished.

The current assertion that a small village style pond will be sufficient is ludicrous and is just another example of this application not meeting the high standards expected in a proposal of this magnitude (this point is further covered in Point 10).

3. Biodiversity and impact on protected species (CS4, DM8 and paragraph 175 NPPF)

CS4 point 2 - Seeking to ensure that new development is designed to maximise benefits to biodiversity, incorporating, safeguarding and enhancing natural habitats and features and adding to them where possible, particularly networks of habitats. A net loss of biodiversity interest should be avoided, and a net gain achieved where possible.

We would also draw attention to a study called ‘A review of horseshoe bats flight lines and feeding areas’ CCW Science Report No. 755. This report into Horseshoe Bats states, ‘Existing maternity roosts are of the utmost importance, where the reproductively active female bats for the colony gather to rear their young…’ and goes on ‘On average the young do not feed independently at all until they are 29 days old. At this point their diet normally consists of Aphodius rufipes, which is therefore a key prey species… Aphodius is a dung dependent insect. It utilises fresh dung which it leaves within a day or two therefore it is essential that grazing cattle be kept close to the maternity roosts, particularly as Aphodius is such a key prey item for juveniles and lactating females.’

This highlights the importance of the field as a supply of food for the Lesser and Greater horseshoe bats. Without it, there will be no night-flying dung beetles.

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A view of the field with grazing cattle, so important to the Horseshoe bats. (view from PRoW looking south-east September 2020). Note the downward gradient northwards towards Westward Close and Wiltons, covered in full under Point 2)

It will be noted in the Natural England reply, whilst seeming to forget that Wrington is in Zone B of the North Somerset and Mendip Bat Special Area of Conservation (SAC), that several roosts have been identified in the Wrington village locality and the applicant’s own Ecological assessment cites a record of a roost located within 300 metres of this site.

With maternity roosts in the immediate vicinity, this field falls within an area protected by the Juvenile Sustenance Zone (JSZ). The North Somerset Council Supplementary Planning Document (SPD) on horseshoe bats states ‘New build development on green field sites should be avoided in the Juvenile Sustenance Zones (JSZs) in view of their sensitivity and importance as suitable habitat as foraging areas for young bats, being within 1km of maternity roosts for Greater Horseshoe bats and 600 metres for Lesser Horseshoe bats’.

NSC Bat SPD Page 10 – flow chart - New build development on a green field site is unlikely to be acceptable.

In addition, the applicant has not carried out a full six-month study as stipulated by the NSC Bat SPD 2018 and recommended in its own ecology report, despite having all of 2020 to do so (Ecological appraisal 20_P_2990_OUT- PRELIMINARY_ECOLOGICAL_APPRAISAL-2988502 February 2020).

The council’s own guidance states

6.3 For proposals within bands A and B of the Bat Consultation Zone, full season surveys will be needed (unless minor impacts can be demonstrated) and must include automated bat detector surveys. Survey results are crucial for understanding how bats use the site, and therefore how impacts on horseshoe bats can be avoided, minimised or mitigated. Where mitigation is needed the survey results will inform the metric for calculating the amount of habitat needed (see Annex 5)

7.1 In some circumstances a developer may be able to clearly demonstrate (from their qualified ecologist’s site visit and report) that the impacts of a proposed development are proven to be minor and can be avoided or mitigated (or do not require mitigation) without an impact on SAC bat habitat, so a full season’s survey is not needed. This should be substantiated in a suitably robust statement submitted as part of the development proposals.

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The applicant has failed to carry out the stipulated survey and has failed to produce any report on the impacts, let alone that they are proven to be minor. In fact, the ecologist only undertook a desktop appraisal with a one-day site visit (19th November 2019) and has recommended the required survey, but this has not been carried out (One has to assume the applicant had a reason for not wishing such a report to be commissioned).

The Ecology report Executive Summary states there will be a 30% reduction in Biodiversity Net Gain (BNG), and this is using the DEFRA matrix rather than the recommended one (Natural England have highlighted this in their report). One assumes that even this figure was arrived at by including the 0.97 hectare set to the south of the plot if created to lowland meadow and orchard. However, both the Drainage report for the applicant, numerous references by local people and the objection by Wrington Parish Council clearly evidence that the south end of the proposed site is liable to flooding and in Flood zone 3.

The Parish Council objection correctly points out that due to this flooding, this offset site does nothing to replace lost habitat in the field and we would add that with no cows grazing the land then the important food source of Aphodius will be lost for the foraging bats. It is worth noting that the regularly flooded land will not permit habitat for the dormice, hedgehogs, badgers, deer and other recorded wildlife, which the applicant’s Design and Access statement has failed to appreciate and negates their claims (page 51). The fact it floods also raises suitability issues under the Planning Inspector report for Cox’s Green (see Point 11 below)

During the summer of 2020 there have been several sightings of otters in the stretch of the river Yeo that borders the south of the proposed site. One assumes that the ecologist did not note the presence of otters due to the lack of time spent on site and the report being rushed through to the application process. Therefore, no mitigation has been put forward and it is just one more reason that this site is unsuitable, and the application must be rejected under paragraph 175 NPPF “When determining planning applications, local planning authorities should apply the following principles: a) if significant harm to biodiversity resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused.

4. Fails to meet Service village guidelines (North Somerset Council Core Strategy 32)

The objection by Wrington Parish Council dated 14th January 2021 clearly sets out why this application fails to meet any of the necessary criteria set out in CS32. Our objections should be read in conjunction with these already excellent reasons for rejection made by the parish council.

This core strategy states –

New development within or adjoining the settlement boundaries of the Service Villages of Backwell, Banwell, Churchill, Congresbury, Easton-in-Gordano/Pill, Long Ashton, Winscombe, Wrington and Yatton which enhances the overall sustainability of the settlement will be supported where:

• It results in a form, design and scale of development which is high quality, respects and enhances the local character, contributes to place making and the reinforcement of local distinctiveness, and can be readily assimilated into the village

The types of housing being proposed are based on an assessment of ‘local urban form’. This assessment is fundamentally flawed because it seeks to suggest the new housing should be based on the style of housing that has evolved over centuries to fit within the existing village boundary. However, the applicant has chosen an elevated and visually exposed greenfield site that is set outside the village boundary. The North Somerset Landscape Sensitivity Assessment (2018) assessed this land as High, meaning that is it clearly visible and any development would be very detrimental to the surrounding landscape and the Grade 1 listed church (covered in greater detail under Point 5). Therefore, the proposed housing styles are wholly inappropriate, meaning this application cannot be granted.

• It has regard to the size, type, tenure and range of housing that is required.

There is no supporting evidence for this policy. The previously mentioned ‘urban form’ means the applicant will simply build a variety of dwellings that are market led and not locally needed.

The inclusion of 21 social housing dwellings, whilst welcomed, is limited with a village that has no bus service. The method of allocation by housing authorities rightly prioritises families most in need, not necessarily those with any local connections to the village. The lack of local services or employment in the village (set out in detail below) and without access to public transport, means these houses are not suitable to families who may not be fortunate enough to own one car, let alone the two that would be required to commute and do the daily running around to schools, shops, medical services and leisure facilities. Therefore, this proposed development has limited scope in providing suitable accommodation for families. The argument that increasing the size

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of the village population will make a bus service viable should be discounted, as the local infrastructure, geography and the narrow lanes to access the village restrict the size of any buses, making them commercially uneconomical.

• It will not cause significant adverse impacts on services and infrastructure and the local infrastructure is sufficient to accommodate the demands of the development

A development of 71 dwellings, added to the 59 being built at Cox’s Green, will overwhelm the existing educational and medical facilities. There is no capacity in the school at present and Cox’s Green residents will be adding to the shortage even before the 71 families from this development move in. The same will apply to the doctor’s surgery in Lower Langford. Not only will there be longer waiting times for appointments, but consideration must be given to the lack of car parking at the surgery, due to the practice being outside the village and not walkable (see above). The local shops cannot cater for such a large increase and the constraints imposed on building within the conservation area of the village mean these cannot expand with demand. The local road network is too narrow and access on to the major arterial roads to commute to Bristol is limited and already accounts for many life changing collisions (this point is covered further under Point 6).

• It results in high quality sustainable schemes which is appropriate to its context and makes a positive contribution to the local environment and landscape setting

As already outlined above in Climate Change and Biodiversity, by building outside the village boundary the Ecology Report assesses a reduction of 58% BNG and protected species will be adversely affected. The council’s Conservation Heritage officer has already stated the location of this site will have an adverse impact (20_P_2990_OUT- 08_01_2021__CONSERVATION___HERITAGE_OFFICER-3002085).

• It does not result in significant adverse cumulative impacts (such as highway impacts) likely to arise from existing and proposed development within the wider area

Wrington is unique in the Service villages as it does not have a major trunk road running through or along-side it. Access is via narrow lanes, two of which pass through adjoining hamlets (Redhill and Lower Langford). These lanes are narrow, often down to single width, and are hazardous for all road users. Access to the proposed development is only possible via Station Road to the north and Lower Langford to the south. These are extra narrow and have particular hazards that are covered below under Traffic and Road Safety. Suffice to say, the impact 140 extra private vehicles from this development and the 118 from Cox’s Green, all making a minimum of 4 journeys a day, will overwhelm these lanes.

• The location of development maximises opportunities to reduce the need to travel and encourages active travel modes and public transport

The location of this development does exactly the opposite and only encourages the use of private vehicles. There is no public transport as the bus service is being withdrawn in March, as it has been unviable for years. There is no train station. There is no employment locally and due to the narrow lanes (mentioned above and under Point 6) there are no pavements (detailed under Point 9). The applicant references the old railway line as a cycleway numerous times but admits it is outside their control. This issue has already been dealt with in detail above (Point 1), but it is worth repeating that Somerset Council first put this idea forward as an aspiration in 2007. To date only a few miles of the original Strawberry Line has been converted into a cycleway. It is also worth highlighting that this is funded under CIL agreements and therefore the council cannot ask for any contributions towards this from a developer (NORTH SOMERSET COUNCIL COMMUNITY INFRASTRUCTURE LEVY (CIL) REGULATION 123 LIST).

• It demonstrates safe and attractive pedestrian routes to facilities within the settlement within reasonable walking distance.

With the only access being outside the village boundary there is not a continuous and safe footway into the village. This point is covered in detail under Pedestrian safety in Point 9, demonstrating that it is not possible to build such a footway due to building lines in the conservation area.

• Sites outside the settlement boundaries in excess of about 25 dwellings must be brought forward as allocations through Local Plans or Neighbourhood Plans.

The Wrington Parish Council objection clearly states that this site has not been allocated and it is worth repeating their comments again – “This site is outside the settlement boundary and is greater than the 25 dwellings referred to above. The site has not been brought forward in NSC’s current Spatial Plan, adopted 2018 (in fact it was considered at an early stage but not adopted in the final document*) and nor is it put forward within any Neighbourhood Plan. The village is currently proceeding with the aim of completing adoption of a Neighbourhood Plan. The proposal to develop this site must therefore be considered as without foundation and purely speculative and failing to meet the fundamental criteria set out in Policy CS32”. Page 9 of 23 25/01/2021 Keep Wrington as Wrington – residents against inappropriate development. OBJECTION TO APPLICATION 20/P/2990/OUT - DEVELOPMENT OF LAND WEST OF BUTTS BATCH

*The applicant applied to have this site allocated, but was rejected in the North Somerset Allocations Plan: Proposed Modifications (November 2017)

Point 10.5 of The Landscape & Visual Impact Assessment Visual impact part 1 (20_P_2990_OUT- LANDSCAPE_AND_VISUAL_IMPACT_ASSESSMENT_-_PART_1-2988471) states “North Somerset Landscape Sensitivity Assessment (2018) provides an assessment of the sensitivity of landscapes to housing development on the periphery of selected settlements. The published assessment identifies the site within a land parcel idenitified as 'High' landscape sensitivity and states: The condition of the LCA J2 is described as 'Good' and the landscape strategy is 'to conserve the peaceful, rural nature of the landscape with intact pasture and field boundaries and to strengthen and enhance the area of weaker character'. Relevant landscape guidelines set out requirements to 'Conserve the rural, pastoral character of the area' and 'Consider opportunities for grassland, woodland and wetland habitat creation, particularly in areas which are marginal for farming”.

The report then goes on in point 10.6. to ignore this rating and assert that this land could take residential development and only to be Medium sensitivity. This is ridiculous, misleading and purely self-serving.

The justification used is totally spurious, making comparison of land further south and west. At no point does it acknowledge that it is in front of a Grade 1 listed church, opposite Grade 2 Butts Orchard or adjacent to a Conservation area.

Part 2 of the report (Visual impact part 2 20_P_2990_OUT-LANDSCAPE_AND_VISUAL_IMPACT_ASSESSMENT_-_PART_2-2988472) includes some photographs of dubious quality (taken from behind trees or bushes and with a lens of unknown focal length). However, a consistent theme is how the red dotted line marked as ‘Approximate extent of site’ on pages 26, 28, 29 and 32 all extend beyond the scope of the photograph, giving a clear indication how large this site will be.

Previously, this objection letter has drawn attention to the inconsistent briefings given by the developer to its consultants. The photographs on pages 26, 29, 31 and most clearly on page 35 would appear to indicate this consultant was working off plans showing a far larger development than the submitted plans.

Fortunately, the Council’s own Conservation and Heritage Officer sets the record straight in his report (20_P_2990_OUT- 08_01_2021__CONSERVATION___HERITAGE_OFFICER-3002085) by stating “The development within this area will alter the wider rural landscape surrounding the approach to the conservation area and listed buildings into a wider urban area with will cause some harm to the character of the area and wider setting of these heritage assets”.

And goes on “The proposed application will be highly visible entering the village of Wrington from the South along Half Yard/Butts Batch Road and will affect the wider setting of Wrington Conservation Area” and again “Due the rise in land levels on the site the development will block certain view lines between the development and the Grade I listed Church of All Saints and harm the wider setting of the listed church with the change of rural landscape to a more urban area. Views of the landmark building when travelling down Half Yard towards the village will be most affected from the public realm”.

The officer’s concluding paragraph states “Overall the proposed development will harm the wider setting of the conservation area and the setting nearby listed church…… The current application is contra to policy DM4”.

The final paragraph also makes reference to Part I section 66 of The Planning (Listed Buildings and Conservation Areas) Act 1990 “In considering whether to grant planning permission [or permission in principle] for development which affects a listed building or its setting, the local planning authority or, as the case may be, the Secretary of State shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses”.

Put simply, any permission granted for this application will send the message that North Somerset Council are uninterested in preserving our heritage, or the rural areas of the county.

In considering the impact of this application on the local landscape, we feel that it is important to highlight an issue that we, KWaW, feel is very material to any decision to permit this development, namely that the Land Registry deeds for the whole of the field this site is part of (Title Deed ST282380 and attached as Appendix 1) show there is a Contract for Sale with the applicant as the Beneficiary. This contract, showing all the land in Flood Zone 1 and therefore eligible for planning permission, would cover a further 5 hectares, giving a potential development totalling 7.5 hectares stretching westwards from this development.

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To further support this, we would draw attention to the plan on page 35 of the applicants Design and Access Statement shown below. We have inserted the yellow text box to highlight our concerns.

Plan reproduced from Page 35 Design and Access Statement part 1. The blue arrow is unexplained but matches the key for ‘Secondary village street’ (The yellow text box has been added for ease of reference). Page 11 of 23 25/01/2021 Keep Wrington as Wrington – residents against inappropriate development. OBJECTION TO APPLICATION 20/P/2990/OUT - DEVELOPMENT OF LAND WEST OF BUTTS BATCH

These two issues are grouped together, as one is intrinsically linked to the other. It is noted that the applicant has submitted a Transport Statement generated by its own staff (Transport statement 20_P_2990_OUT-TRANSPORT_STATEMENT-2988492).

The applicant has attached a ‘Scoping email’ as Appendix 1, dated 17th March 2020. Unfortunately, it does not show the reply from H & T Development Management at North Somerset Council, so we are left uninformed if they found the scope of this Transport Assessment satisfactory. It is also worth pointing out that between 17th March 2020 and the date of the application on 1st December 2020, the number of proposed dwellings has increased by 11, so it is possible that the guidance is now incorrect. As Wrington Parish Council highlighted in their objection, the data provided has not been tested and requires verification by North Somerset Council.

That observation is pertinent to this Statement, as the data supplied by the TRICS database uses an algorithm that relies on data supplied by the user, so it cannot be relied upon until verified by an independent survey. Appendix 5 lists a lot of data and the choice of examples of ‘similar’ locations used to generate the figures on vehicle movements is highly subjective. A detailed study of the data reveals that the 52 studies chosen only record traffic during the working day (7am to 7pm, Monday to Friday). This is ridiculous enough, without then finding that only 4 of those samples represent a nearby population between 2,000 to 5,000, and only 2 represent a development where residents have 1.6 to 2 vehicles per household. This skewed dataset still produced an average of 4.5 journeys per day per household, amounting to 325 ‘two-way trips’ from future residents. The term used is ambiguous, does it mean a resident will take one trip in either direction during the prescribed hours or round trips? If the latter, then it would be 650 extra vehicle movements per day.

Whatever the answer, it must be stressed that the data does not include early morning traffic before 7am, evening traffic, after 7pm and weekends! We agree with the Parish Council, the whole application contains data that has not been verified and is misleading.

So, ignoring the figures produced from this database it is more realistic to anticipate there will be 140+ vehicles queuing to get out through the one egress point on to Half Yard as cars wait for a gap in traffic, leading to more congestion as these vehicles join the already long queues at the small, badly-lit and poorly signed junctions with the main arterial routes into Bristol and Weston (A38 and A370).

This is yet another point that this applicant has failed to acknowledge, namely Wrington is unique in the Service villages as it does not have an access road that is a designated A or B road. The Somerset Cycling route map (referenced in the statement) does indeed designate all the roads around the village as “Minor roads suited to most cyclists”. This means that bottlenecks are created at the major junctions and this leads to unnecessary air pollution, global warming, wasted fossil fuels and ultimately serious collisions.

The applicant stated that Wrington village does not have any collisions recorded on Crashmap. Whilst this is true, the website does issue the following statement on the veracity of its data “The records relate only to personal injury accidents on public roads that are reported to the police, and subsequently recorded, using the STATS19 accident reporting form”.

It is also self-serving for the report to state “the local highway network is generally operating safely” (paragraph 7.3), as the map below indicates:

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Crashmap data, as recorded on 19th January 2021, showing the past 5 years

This map clearly shows that whilst the village may not have ‘reportable’ collisions there are plenty at the junctions used to access the major routes to the many facilities not available in Wrington. Therefore, it is inaccurate to say that “the local highway network is generally operating safely”.

In addition, there is plenty of anecdotal evidence that the lanes are hazardous, and the map shows there are two recorded collisions in West Hay Road, one of the main commuting routes to the A370. This lane, and Long Lane to the A38 from north of the village are so narrow that they both have bans of vehicles over 7.5 tonnes.

The Transport Statement also states that the area is safe for cycling “There are no cycleways within the vicinity of the site however the roads are generally identified as minor roads that would be suitable for cyclists. North Somerset Council identifies Butts Batch as a minor road suitable to most cyclists on North Somerset’s Interactive Cycling Map on their website”.

Again, this is selective data, as illustrated below:

Interactive cycling map from North Somerset council website, showing all the local area.

The interactive map quoted clearly shows that whilst the lanes in the immediate vicinity of Wrington might be safe for most cyclists, within 3 kilometres it is advised that the ‘main roads/connecting routes are for experienced cyclists’ and the arterial routes are in red with no suggestions on using them.

This clearly illustrates that whilst one could ride for about 9 minutes in any one direction (using the applicants own data of “an average cycling speed of 320 metres per minute”) the surrounding wider local highway network is clearly unsuited to most cyclists and therefore not a suitable alternative to one of the family’s private cars, either to commute, shop or even as a leisure activity.

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The applicant makes several references to the Strawberry Line being made a cycleway (covered in detail above) but it does not appear in the Transport Statement, so is discounted.

Paragraph 7.2 states “It is concluded that the site is located in an accessible location with a range of local services and facilities, which are typically required on a daily basis, located within walking and cycling distance of the site. This was affirmed by the Planning Inspector during the appeal for the Cox’s Green site located nearby.”

The whole application is quick to draw parallels with Cox’s Green, using that site as a precedent, and the Planning Inspector’s report is included as Appendix 3. Therefore, the pertinent points regarding differences in transport will be addressed here. A site visit would clearly establish the differences. In relation to the Transport issues, Cox’s Green does have direct access on to the A38 via Havyatt Road. This proposed site at Butts Batch only exits on to Half Yard and to access the A38 one can either turn north and drive approximately 3 kilometres north east through the village conservation area, negotiating the very narrow Station Road and out along the aforementioned narrow and restricted Long Lane. Or turn south and drive about 2.5 kilometres through Lower Langford, via the narrow, single-width humpback bridge on a blind corner and through Black Moor, which is also a single-width road between the cottages and in the Conservation area, negotiate the small T junction, a further narrow section and eventually reach the A38. So, this location has no easy and quick access to or from any of the major roads and will turn Lower Langford into a ‘rat-run’ for commuters. This is why so many objections have highlighted the traffic issue and is why this development will “overwhelm the highways infrastructure” as set out in CS32.

From the above description of the traffic issues, resulting in queuing, commuting delays, shortage of local facilities due to recent closure and no public transport services, this application does not satisfy paragraphs 102 and 103 NPPF criteria for sustainable development.

7. Archaeology and historical finds around the site (CS5, DM6, and paragraphs 199 NPPF)

The applicant has made only a token effort to discover what the archaeology of this site might be in a village that has seen settlement since Roman times (Archaeological 20_P_2990_OUT-ARCHAEOLOGICAL_DESK-BASED_ASSESSMENT-2988470), using just a desktop assessment. Put another way, that is a quick internet search from the office. Just another example of an ‘in-house’ report to tick a box on the application form.

Point 4.2 asserts “There have been no previous archaeological investigations within the Site itself, and no relevant proximate investigations”. It is not clear what the author of the report defines as close, as he has not considered the local Roman, and other finds listed in the Council’s own Senior Archaeologist’s report, worth mentioning.

Fortunately, the Senior Archaeologists’ report (20_P_2990_OUT-22_12_2020_-_COMMENTS_FROM_THE_SENIOR_ARCHAEOLOGIST- 2999013) sets out the importance of this site as being a significant part of the Medieval village landscape.

We would also point out that in gardens adjacent to the site, a recent search by a metal detectorist discovered a book clasp that has likely come from a bible in the Middle Ages and a small block of lead. This latter find, not far from the traces of lead and beryllium recorded in the applicant’s own Soil Report (Soil report 20_P_2990_OUT-GROUND_INVESTIGATION_REPORT-2988505), suggests that there may have been further activity on this site, in addition to the ridge and furrow farming further to the south.

The name itself, Butts Batch, could indicate a historical connection with the requirement, circa. 12th Century, for longbow men to regularly practice on this hill at butts (archery term).

As the Senior Archaeologist’s report notes, due to a survey not being carried out before the Soil Report the opportunity to carry out a thorough geophysical survey has been lost and now trial trenching will have to be relied upon. This is yet another example of the applicant being in a rush to get this proposal through the planning process without proper consultations and surveys.

8. The land has not been brought forward in a North Somerset Strategic Housing Land Availability Assessment, as required for more than 25 dwellings (CS32).

The site was not brought forward in North Somerset Council’s current Spatial Plan, adopted 2018, having been rejected by the council in North Somerset Allocations Plan: Proposed Modifications (November 2017). This makes this application purely speculative (as admitted by the applicant when addressing the Parish Council on 22nd September 2020).

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Instead, the developer has sought to link this site to the one at Cox’s Green in order to rely on the Planning Inspector’s Report as a precedent. We have therefore set out the differences between the two sites in greater detail below, under Point 10.

9. Pedestrian safety to and from the village due to lack of footway, particularly people with a disability

The proposed location not only makes for narrow and awkward access for cars, but also shows the difficulties that the amount of construction traffic will encounter, over many months/years of building in phases (as set out in the application). This is a serious issue and before any application could be granted on this matter, a full Construction Method Statement needs to be submitted (paragraph 86 Planning Inspector’s report on Cox’s Green).

The Transport Statement goes on to describe the footways to and from the site, both existing and proposed. Unfortunately, these are inaccurate and misleading. Starting from the proposed site entrance, the applicant intends to put in a 2 metre footway along the hedge line. This would necessitate removing the grass verge and the hedge, which is to be protected due to the presence of dormice, nesting birds and horseshoe bats.

Then paragraph 3.1 states “there are footways along the whole route which can be accessed by crossing the road”. This is inaccurate as Butts Batch has a stretch without a footway and so does Station Road. The reference to “crossing the road” actually refers to having to walk along the road from the west footway and then reach the east footway after about 20 metres. During that time the pedestrian is relying on drivers to slow and stop as the road is single width only. Due to the narrow confines of this section of road in the village conservation area, a pavement cannot be provided. This makes it very hazardous for everyone and even more difficult for parents with small children or a disabled person. Attempting to add more pedestrians with 71 new families would greatly increase the danger and so this application fails to be able to provide safe pedestrian access to the few facilities in the village or the Primary School (contrary to CS32), all of which are beyond the 8oo metres considered as a reasonable walking distance (MfS) :

Movement for Streets (MfS) 1.1.6 MfS discourages the building of streets that are: • primarily designed to meet the needs of motor traffic; • bland and unattractive; • unsafe and unwelcoming to pedestrians and cyclists; • difficult to serve by public transport; and • poorly designed and constructed.

This guidance clearly demonstrates all that is wrong with this application in relation to design and access.

In addition, Figure 3 shows footway provision and is incorrect. The map shows “Available footway provision” along Butts Batch when much of the footway shown is not in existence. It also assumes that it is possible to build a 2 metre wide footpath along the hedge line. This would only be possible by removing the hedge and that is contrary to the applicant’s pledge not to do so in the interests of biodiversity. The light blue line also shows the non-existent piece of footpath in Station Road, as mentioned above.

10. This application cannot rely on the Planning Inspectorate judgement on Cox’s Green, due to changes in policy and recent reductions in services and local employment opportunities (Planning Inspectorate Appeal Decision 23rd November 2017 (Appeal Ref: APP/D0121/W/16/3166147 https://www.gov.uk/planning-inspectorate 9))

The applicant appears to be using the ‘carrot and stick’ method of persuasion in their submission for development.

The ‘carrot’ being dangled is the statement in the section 106 Heads of Terms document (106 Heads of Terms 20_P_2990_OUT- SECTION_106_HEADS_OF_TERMS-2988476) which states on page 3 “Contributions towards the strawberry line extension are anticipated to come via the CIL. No details could be ascertained of any scheme for this beyond the allocation itself. The applicant would be happy to discuss this further as relevant”.

The ‘stick’ is the inclusion of the Planning Inspectorate Appeal Decision 23rd November 2017 in Appendix 3 of the Transport Statement (Transport statement 20_P_2990_OUT-TRANSPORT_STATEMENT-2988492).

The reasons the carrot can be discounted as a benefit have been set out in detail previously in this document. It is merely an enticement to try and mitigate the devastating impact this proposal would have on the village.

So, to the stick. The applicant appears to have included it in the Transport Statement in order to cover the short fall of a safe footway into the village. The lack of footway and the disingenuous way the Statement refers to it has already been covered under Traffic and Road Safety, as has the differences in the siting between Cox’s Green and this field in Butts Batch in the context of the village.

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To expand on this further, paragraph 33 states that the Local Highway Authority could build a footway within the adopted highway, but this is not physically possible to achieve on Station Road.

Paragraphs 26 to 32 deal with the services and facilities within the village. Since this time, there have been significant changes in Wrington, namely the A2 bus service was withdrawn (despite the Inspector’s aspiration that it would not!) and the replacement A5 service is finishing in March 2021; the garage no longer sells fuel; the opticians has closed; along with the Gatcombe Farm Industrial Estate and the manufacturing company P.J. Hare Ltd. on the Havyatt Road Industrial estate. This reduces the scope of new residents to walk, cycle or use public transport to obtain daily sustenance or employment.

Paragraphs 46 to 58 deal with the flood risks on Cox’s Green. The villagers have seen how this has turned out! Two years of disruption and no houses, just a massive amount of earth moved, a huge lake (covered above in Flooding and Drainage) and months of closed roads.

A crucial point about the effect of development and flooding is made in paragraph 47 “There is no evidence that either this area or the land where the proposed flood attenuation basins would be sited has been subject to past flooding. Hence, the residential development would not be located in an area at risk of flooding…”.

As has been pointed out already by the Parish Council and others (see above) the area this applicant wishes to place water attenuation systems in already regularly flood, whether this is on the north or south side of the batch (hill). As shown in the photograph below:

Flooded field in area marked for future ‘flood mitigation’ (right).

Further, in paragraph 48 the ecology report says “land in the north west corner of the site falls to the north rather than to the south. However, if the public open space were to be located in this part of the site as now proposed, that land would be largely free of buildings and hard surfaces”. This is not the case in this application and is further grounds for this application to be denied (see Point 2 above).

When comparing the locations of each site, attention must be drawn to paragraphs 58 to 65 ‘Landscape and visual effects’, the Inspector notes that the view of Cox’s Green was limited and would only be seen locally and on the south-east side of the village the boundary is defined by the small industrial estates. The Inspector was convinced that the site could be screened by the hedging. This is in direct contrast to this application as this field is an significant local feature, in that it is on a prominent hill (hence the name batch) and is visible from all points of the compass around Wrington, including the local picnic area set up on Wrington hill in memory of Mike Bush. It is also this view that is used on the home page of Wrington Parish Council website, so it is iconic, and very different to Cox’s Green development site, so will have a significant harmful effect upon the character of the village.

In paragraph 62 it also notes “the landscape effects of the appeal proposal would not be substantially different to those that would occur through the development of that part of the site which the Council has proposed as an additional housing allocation in the SAP. This is a material consideration of significant weight”. Again, this highlights the differences of these two sites, as Butts Batch has not been allocated in the SAP (covered in detail previously) and therefore this should be a material consideration of significant weight in deciding against the application.

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Given the differences above the following paragraph (64) would read in the negative and this proposal at Butts Batch would fail to comply with SPP Policy DM10 and would have an unacceptable adverse effect on the designated landscape character of the district and would not be integrated into the natural and built environment. In addition, it would not comply with SPP Policy DM32 and the first criterion of CS32.

The issues of Highway Congestion in paragraph 67 have been dealt with in the section above, under Traffic and Road Safety. Suffice to say, access directly onto the A38 from Cox’s Green are significantly different to this site’s location.

Foul Water drainage is covered in paragraph 68. By way of contrast to Cox’s Green, the council needs to take account of the objection letter that points out the flooding that has been caused from the drains backing up in Wiltons, flooding the resident’s garden.

Paragraph 71 deals with ecology on the site. The contrasts have been made in great detail already, but it is worth repeating that the field in Butts Batch is very likely within a Juvenile Sustenance Zone (only a full study will establish that) and it should be noted that since the Inspectorate report North Somerset Council have set out tighter restrictions in the North Somerset and Mendip Bats Special Area of Conservation (SAC) Guidance on Development: Supplementary Planning Document in January 2018.

In addition, since the application for Cox’s Green was approved in 2017 much has changed in the guidance from government and how many houses need to be built in North Somerset. The 5 year Housing Land Supply plan for the supply of houses is often used by developers to push through unwanted and unnecessary planning permissions. Given that North Somerset Council have granted applications for enough land to build 8,000 homes in 2018 and of those 8,000 potential homes, developers had only supplied 863. This clearly shows that it is the developers who are responsible for not supplying the required number of houses, not the council. In the words of Liam Fox “Builders should be required to build out on their existing permissions before applying for further permissions in the same area” (Village zoom meeting 7th January 2021). This applicant is one of those builders he was addressing.

All the points outlined above clearly demonstrate that this application cannot use the Planning Inspectorate decision as a precedent, as already pointed out in the Parish Council response.

Conclusion

For the reasons outlined above, this application must be rejected as it fails to meet the requirements or standards required by an application for major development on land that has not been allocated in the SAP; to be sustainable; or meet set out by North Somerset Council’s planning guidelines. The damage and disadvantages this proposal would cause far outweigh any possible potential benefits.

We also draw attention to paragraph 6 of the National Planning Policy Framework (NPPF) 2019 which states “Other statements of government policy may be material when preparing plans or deciding applications, such as relevant Written Ministerial Statements and endorsed recommendations of the National Infrastructure Commission”.

Therefore, the Housing Minister’s policy speech of 16th December 2020 must be taken into consideration, in which he states that the government housing targets are being reviewed and rewritten. The Gov.uk website summarises it as “More homes in urban areas - tackling unaffordability and making the most of brownfield land with £100 million of funding”. This was also referred to by Dr Fox MP in his address to the village on 7th January 2021, indicating that until such time as the new policy is decided, the council should use this space to put on hold developments on greenfield sites, like this one.

Also, Paragraph 11d (i and ii) NPPF covers Special Areas of Conservation and habitat of protected species:

“d) where there are no relevant development plan policies, or the policies which are most important for determining the application are out-of-date7, granting permission unless:

i. the application of policies in this Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed6; or ii. ii. any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”

The adverse impacts of this development would significantly and demonstrably outweigh any benefits, especially given that none have been identified.

Given that this major development will destroy greenfield land in an SAC for endangered species; increase the danger on the local roads and create rat-runs through neighbouring villages; add to congestion and air pollution by commuters to Bristol; and affect an area of high visual amenity adjacent to a conservation area and Grade 1 listed church, this application is inappropriate and unsustainable. Page 17 of 23 25/01/2021 Keep Wrington as Wrington – residents against inappropriate development. OBJECTION TO APPLICATION 20/P/2990/OUT - DEVELOPMENT OF LAND WEST OF BUTTS BATCH

It is clear that a major development, such as this, should follow recent Government advice and be built in urban areas and make the most of brownfield sites. Rather than permit this development we would point to the council’s own Climate Emergency strategy (updated January 2021) - “Aim to focus new mixed-use development on brownfield land, in town centres with public transport and proximity to major employment hubs”. In this way, the planning committee can empower future residents to actually be able to support the Climate Emergency initiative by cycling and walking to local amenities, rather than driving. This proposal for 71 homes on a greenfield site offers none of these goals and aspirations and we urge that it be rejected by the council.

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Appendix 1

Title Deeds, with map, covering the site outlined in this application, together with the remaining 5 hectares of land to the west. All this land is shown as having a Contract for Sale and the Beneficiary is the applicant (Strongvox) under Section C: Charges Register.

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Map of ST282380 following page

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(NB – The area marked in yellow is covered by another deed and has a separate owner) Page 23 of 23 25/01/2021 Keep Wrington as Wrington – residents against inappropriate development.