Mendip Local Plan Part II: Sites & Policies – Pre-Submission Consultation Consultation Response Form Please use this form to respond or make representations on Local Plan Part II and associated consultation documents. For information or advice, please contact the Planning Policy Team by email at [email protected] or phone (0300) 303 8588. Contact Details If you have appointed somebody to act as your agent, please give their contact details. All correspondence will be sent to the agent Name: Mssrs Bunn (landowners) Agent Name: Lee Wright Organisation (if applicable): Company Name: Wright Consult LLP Address: Bay Tree, Cooks Lane, West Cranmore, Shepton Mallet, Somerset Postcode: BA4 4RH Email: [email protected] Date Completed: 02.02.2018 Do you wish to be notified of future stages of Local Plan Part II (tick box) Ö Öaa We will contact you by e-mail only unless you confirm here (tick box) Data protection – please read - The information collected as part this consultation will be processed by the Council in accordance with the Data Protection Act 1998. The purposes for collecting this data are: to assist in plan making; and to contact you, if necessary, regarding the planning consultation process. Please note that representations must be attributable to named individuals or organisations at a postal address. Representations and contact names will be published on the Mendip website but no other personal information Copies of this form are available from Council Offices and Access Points or can be downloaded from www.mendip.gov.uk/localplanpart2 . If you require this document in another format such as Braille, large print or another language then please contact us. Please use a separate form for each site or main issue you wish to make. You can also attach one contact form to a group of representations. Please make sure any separate documents include your name –so they can be clearly identified. Please return your response by 5pm Monday 12th February 2018. By post to: Planning Policy, Mendip District Council, Cannards Grave Road, Shepton Mallet, Somerset, BA4 5BT By email to: [email protected] By hand to: The Council offices in Shepton Mallet (address above). Mendip Local Plan Part II: Sites & Policies - Issues and Options Consultation Details of Objection/ Comment/Representation Name /Organisation: Lee Wright of Wright Consult LLP, on behalf of landowners Mssrs Bunn Please indicate the document to which your GLAS005 – Land At Pear Tree Farm & representation relates (e.g. policy, paragraph GLAS093 – Land Off Old Wells Road number, HELAA site reference) Do you consider the Local Plan is Legally Do you consider the Local Plan is Sound 1 ? 1 Compliant? Yes Ö No Yes No. Ö Do you consider it necessary to participate at examination hearings? (eg present oral Yes evidence) Please provide details below of why you consider the Local Plan is not legally compliant or is unsound. Please be as precise as possible. If you wish to support the legal compliance and soundness of the plan, please also use this box to set out your comments. HELAA Site Number GLAS005 - Land At Pear Tree Farm & HELAA Site Number GLAS093 - Land Off Old Wells Road 1. Introduction & Background These sites were submitted in the earlier stages of the Local Plan Part II Land Allocation and have been discounted. HELAA GLAS093 was it appears discounted at Issues & Options Stage, as it would appear consent is believed to have been granted. In reality, consent was granted for development on 3 June 2016, under planning reference 2013/1444; however, this only related to the western part of the field and there appears no reason why the eastern part of the same field should not be allocated. Comments at Issues & Options stage, stated: Issues & Options Consultation - October 2015 To January 2016 Glastonbury Section Sites Under Discussion ‘In addition to the above, there are a number of sites without permission where consultation has already taken place on specific planning applications. • GLAS093 - Land north of Uppingstock Farm and east off Old Wells Road – approved in principle.’ HELAA GLAS005 was discounted in the current Pre-Submission Consultation tranche of the land allocation process through the sustainability appraisal that alleges adverse landscape impacts and this stated: Local Plan Part II: Pre-submission stage Sustainability Appraisal - December 2017 Appendix 3: Sites screened out at Initial Assessment ‘GLAS005 The site lies within the Glastonbury Tor Special Landscape Feature therefore the landscape impact of development is likely to be significant. There is also likely to be an impact upon the 1 See our Online Guidance note on what these terms mean 2 Mendip Local Plan Part II: Sites & Policies - Issues and Options Consultation setting of the town from development in this location. Development in this location is also likely to have a significant impact upon the Holywell Fields Local Wildlife Site which lies directly adjacent to the south of the site.’ 2. Site Specific Issues These sites lie adjacent one another and are located on the northern edge of Glastonbury east of The Old Wells Road and south of the West Mendip Hospital site. GLAS093 is the northernmost parcel of land and GLAS005 is the southernmost parcel of land. Both sites lie in an area of low Flood Risk (Flood Zone 1) and have a gentle gradient falling from high ground in the south to low ground in the north and are well contained with well established native hedgerows to all boundaries that would be retained. GLAS005 (the southernmost parcel of land) contains a number of farm buildings and lies on the very northern edge of the Tor Special Landscape Feature (MDLP DP4) and has been discounted for this reason. Nevertheless, the site appears a very logical place for residential development to take place, given that this area lies on the very northern edge of that feature and is an area less valuable than other more open areas closer to the Tor. Whilst such a location may not ideally be considered, due to the significant constraints around Glastonbury in respect of Flooding and Special Landscape Features its allocation should be considered further. The site lies within 400m of other housing at Wells Road and Windmill Hill and adjacent the recently approved developments immediately to the north. Whilst already partially developed with a range of farm buildings, a more extensive area of development is likely to have some degree of negative impact upon the integrity of the Special Landscape Feature and the local wildlife site to the south. However, in mitigation it should be noted that this site is more contained by the landscape and by pre-existing tree coverage. On balance, the site is considered suitable in principle however any scheme would need to be heavily informed by a more detailed landscape sensitivity/impact assessment. • Please Note that the landowner also farms nearby from Appledawn Farm, Wick BA6 8JS where they have invested and wishes to focus their farming operation there, thus leaving this site available for development. GLAS093 This site lies outside of the special Landscape features and is well contained by the landscape and pre- existing tree coverage with development already approved in the same field and immediately to the north. There are no other constraints and there appears no reason why this site should not be allocated. A Landscape & Visual Impact Assessment has been undertaken and is provided with this submission to demonstrate the impacts. 3. Housing Land – Demand & Supply Local Plan Part II – Land Allocation Methodology Comments Note: (underline added by author to key policy points for emphasis) Housing Demand The National Planning Policy Framework (NPPF), paragraph 158 states: ‘Each local planning authority should ensure that the Local Plan is based on adequate, up-to-date and relevant evidence about the economic, social and environmental characteristics and prospects of the area. 3 Mendip Local Plan Part II: Sites & Policies - Issues and Options Consultation Local planning authorities should ensure that their assessment of and strategies for housing, employment and other uses are integrated, and that they take full account of relevant market and economic signals.’ Mendip District Local Plan Part II: Sites & Policies Section 3 Housing Land 3.1 Confirms the starting point for considering the delivery levels to be obtained from sites is identified in Part I of the Local Plan. 3.2 Confirms the Part I Plan established a requirement for 420 dwellings per annum and this was tested through the Local Plan examination; however, what it fails to acknowledge is that the inspector confirmed that 420 dwellings per annum should be treated as a ‘minima’. 3.5 Confirms that since the adoption of the Local Plan Part I, the council have undertaken a Strategic Housing Market Assessment (SHMA) and this provides an ‘objectively assessed need’ for housing. Section 3.6 considers it reasonable and justified within a range of 411-491 dwellings per annum and recommends that ‘as a starting point, a level towards the higher end of the range would be more robust’. The starting point for the calculation of ‘objectively assessed need’ is demographic calculations based on the most recent, available population projections. This is made clear in NPPF paragraph 159, which states that the SHMA should be used to establish realistic assumptions about the availability, suitability and the likely economic viability of land to meet the identified need for housing over the plan period, taking