Site FRO 005, Land at Packsaddle, Frome: This site raises a number of concerns and questions. Somerset County Council have retained this site in order to build a new primary school for many decades. The site is divided into fields by a network of hedgerows, and is crossed by public rights of way, used by local people to access the countryside. The site is overlooked by residential dwellings to the west and east. Before residential development is considered suitable: (1) Somerset County Council will need to confirm in writing that the site is no longer needed for a school development to serve Frome’s growing population in the future; (2) The environmental effects of a residential development here will need to be determined as part of the Council’s legal requirements for Strategic Environmental Assessment, under the Environmental Effects of Plans and Programmes Regulations 2004. Information to allow the Council to undertake the Environmental Assessment of the proposed allocation needs to be obtained (either from the site promoter or by the Council itself), including appropriate surveys and desk studies to identify the ecological, landscape and heritage value of the field system and hedgerows, including their importance under the Hedgerow Regulations, and use by bats, and whether the site is a heritage asset, or within the setting of listed Selwood Lodge, to allow the Council to assess the suitability of the proposed allocation against Local Plan policies, including DP3 to DP8.

Any development allocation for this site must ensure no net loss of or harm to biodiversity, ecological networks, protected species, heritage assets, important landscape features, and retain public rights of way routes, in line with Local Plan policies DP3 to DP8.

The site also partly lies within the Frome Sewage Treatment Works Consultation Zone under Local Plan policy DP8, where development is not permitted unless it can be established that the environment of future residents will not be adversely affected.

This site raises many concerns, most of which were identified in my and others’ objections (including from Frome Town Council, the Environment Agency, and many residents) to planning application 2013/2608/OTS for this site (which was withdrawn) and a number of previous applications which have been refused, and I object to its inclusion for the following reasons:

(1) The site is outside the designated development limit of Frome; development outside the development limit is strictly controlled under Local Plan Core Policy 1, para 3, and Core Policy 6;

(2) The development of the steeply sloping hillside site is likely to lead to an unacceptable increase in flood risks at Spring Gardens (and Jeffries Lane and Iron Mill Lane), where existing flood risks are identified by the Environment Agency, and the previous planning application’s proposed surface water drainage attenuation solution, a large underground storage tank, does not appear to be workable; a flood risk assessment of the allocation should be undertaken to establish if a development here can reasonably be expected to incorporate sustainable drainage measures as required in Local Plan policy DP23(3);

(3) The site would bring residential development beyond the edge of town, at a great distance from the main public transport route of Bath Road and the nearest local facilities in Stonebridge and Fromefield. New houses on the steeply sloping hill would have poor accessibility to residents walking and cycling, meaning that the development is very likely to increase the need to travel by private car. Therefore it is very unlikely that any development of this site would be able to demonstrate how it will ‘improve or maximise the use of sustainable forms of transport (particularly by means other than the private car)’ as is a requirement of Local Plan policy DP9 ‘Transport Impact of New Development’ (paragraph 1);

(4) Access to the steeply sloping site for vehicles via the highway network along Packsaddle Way, is likely to lead to great difficulties in winter weather if as is likely snow and ice form on the steep roads in and out of the site; a highways health and safety assessment for the allocation is required to identify if safe and satisfactory provision for all vehicles (and particularly emergency services) can be provided to a development of the site as required under Local Plan policy DP9 (para 2);

(5) The landscape character of this area has been identified as important in the Sustainability Appraisal for the Local Plan Part 1 Examination (doc SD/43) which shows it in an area of ‘good quality land which is prominent and important for the setting of the town.’ and ‘steeply sloping land’. The landscape impact of the development of this exposed site would be significant (as identified in the Landscape and Visual Impact Assessment for the planning application) being on the top and down the side of a hill, would intrude on the rural character of the Mells River Valley, and have visual impacts on views from the countryside to the north, west and north east, which would be impossible to mitigate. The landscape and visual impacts of a residential development of this site would be unacceptable as the development would not be able to demonstrate that its ‘siting and design are compatible with the pattern of natural and man-made features of the Landscape Character Area…’, which is contrary to Local Plan policy DP4 (para 3);

(6) The development of this site would extend the development limit and lead to the coalescence of Frome with Spring Gardens and an adverse effect on the identity and distinctiveness of Spring Gardens;

(7) Following reasons 5 and 6 above, the development would not ‘contribute positively to the maintenance and enhancement of local identity and distinctiveness across the district’ or appreciate ‘the built and natural context

of their locality…’ as required under Local Plan policy DP1;

(8) The site lies within the Frome Sewage Treatment Works Consultation Zone under Local Plan policy DP8, where development is not permitted unless it can be established that the environment of future residents will not be adversely affected.

(9) Local residents living adjacent to the site have reported sightings of Barn Owl on site, which are protected from disturbance under Schedule 1 of the Wildlife and Countryside Act 1981. In line with the NPPF and Local Plan policy DP5 an appropriate survey would need to be undertaken for this species and mitigation measures identified to enable the requirements of legislation and planning policy to be met.

In conclusion, the allocation of this site would go against a wide range of Local Plan policies – DP1, DP4, DP5, DP8, DP9, DP23, and CP6, and lead to flood risk impacts on Spring Gardens. There are too many serious concerns about this site being allocated which would need to be overcome for it to be classed as a suitable development site. Alternative acceptable development sites are available in and around Frome to meet the district’s housing requirements without it.

All sites identified as OALS in Frome still warrant designation.

New areas should be designated as OALS and/or Local Green Spaces for the following reasons:

1.    The Old Showfield green space between the Frome Community Hospital/ Frome Health Centre, Selwood Academy, Berkley Road, Rodden Road, Bath Road: for its landscape value in between residential areas and urban developments, its views from its high points across the cricket pitch to Frome town centre and key landmark buildings in the town, its value for formal recreation in the cricket pitch and Collegians football pitch, and for informal recreation by walkers, dog walkers, for children’s play at the playground and potentially across the whole area, and as a large green space and corridor between the residential areas of Stonebridge, Berkley Road and Fromefield.

2.    The stream corridor between the Old Showfield, Lime Close, Linnet Way, Nightingale Avenue and Forest Road, Frome: for its value as a tranquil green corridor between residential areas, for the stream as a natural environmental feature, and for wildlife.

3.    Packsaddle open space and playground, on the corner of Packsaddle Way and Pedlars Grove: for its value to the community as a playground and green open space used for informal recreation, and for its value as an elevated green space with views across the edge of Frome and open countryside.

4.    The Mendip Drive green space corridor, between Mendip Drive, Eastleigh Close, Tankeys Close and Fairfield Close, for its value as a green corridor and informal recreation space in between residential areas.

5.    The green space on the corner of Mendip Drive and Selwood Crescent, valued as a green space for informal recreation and which breaks up the residential street scene.

6.    The Brunel Way green open space, between the south side of Brunel Way, Charterhouse Drive and Collett Way, as an informal tranquil large green space in between residential areas and value for informal recreation.

7.    Rodden Meadow;

8.    Millennium Green;

9.    Mary Bailey Recreation Ground and Victoria Park;

10. Bath Road verges adjacent to Bath Road Heights development;

11. Tower View park;

12. New Road park and woodland;

13. The Dippy;

14. Rodden Lake Stream Meadows, a ‘green lung’ which separate residential areas in Frome at Rodden Road/New Road from the Styles Hill area.

Local Plan policy DP3 requires that the impacts of development on the significance and setting of built heritage assets is considered before planning permission is granted. However, the Council’s own Validation Requirements for Planning Application (updated August 2015) does not require a Heritage Assessment of planning applications; instead it only refers to an Archaeological Assessment being potentially required, but includes reference to other aspects of heritage assets. To make it clear that the council does require the impacts of development on the significance and setting of all heritage assets to be assessed by the applicant and considered by the council, rather than only buried archaeology, Local Plan Part 2 (or a further update to the Validation Requirements) needs to include suitable clarification. If it does not, there is a significant risk that the setting of heritage assets will be overlooked and not assessed by developers or officers. It should also be clarified that Historic England need to be formally consulted in law for certain types of planning application, and Local Plan Part 2 could add a useful reminder to all parties. I can elaborate further if required, in light of a recent case in Fromefield where shortcomings have been identified.