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. Page 1 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 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). 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 (paragraph 11d NPPF) 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. Page 2 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 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).