Mendip District Council’s Draft ‘Pre-Submission’ Local Plan Part 2 public consultation ended on 12th February. Some 300 responses have so far been added to the council’s website here and there are more to be added.

Policy FR6: Land at Innox Hill (Packsaddle Way)

There are many objections from local residents and other councillors to policy FR6 and the allocation of site FRO061 at Innox Hill/ Packsaddle Way for 100 houses.

This follows the decision by Frome Town Council’s Town Matters Committee at its meeting on 7th February (and following its Extraordinary Planning Advisory Group meeting on 22 January) to not support the allocation (see FTC news here).  FTC are a consultee on the Local Plan and do not make the final decisions.

My objection to FR6, submitted on 12th February 2018, is below.

“I am concerned that Policy FR6 which promotes site FRO061 for the development of 100 dwellings, is unsound. It goes against the Council’s own Sustainability Appraisal (Appendix 5 to the Local Plan Part 2). The Sustainability Appraisal has analysed all the proposed development sites in the Plan against 13 ‘sustainability criteria’. The appraisal for site FRO061 concludes clearly: ‘Site not suitable for development: Site is unsuitable for allocation due to its landscape impact, primarily due to its location beyond the ridge line north and west of Frome, in an area of rural character. It is also poorly related to the settlement form and is distant from many facilities and services’. The site scores ‘very poorly’ against the sustainability objectives ‘Maintain and enhance the distinctive character of settlements’ and ‘Protect and enhance the district’s landscape’, and ‘poorly’ on ‘Protect and enhance the district’s built environment’ and ‘Improve access to facilities and services’.  The supporting text for Policy FR6 states that ‘The site is not a preferred option arising from the sustainability appraisal but the nearest alternative site (FRO005) may be needed to meet medium to long term educational needs in Frome. This site provides an opportunity to deliver self-build and address specific housing needs which meet objectives in the Frome Neighbourhood Plan. The allocation is also justified through local evidence and work undertaken by the Town Council to promote self-build and co-housing in Frome.’ The site does provide an opportunity for self-build homes, as for other sites. However, the potential unavailability of site FRO005 does not mean that site FRO061 is therefore acceptable, as the sustainability credentials of FRO005 are not transferred to FRO061.

The text for Policy FR6 also identifies issues of landscape/visual impact, wildlife and protected species, highways access, and flood risk downhill, and states they will need to be addressed in any development proposals, but these are issues which were highlighted by the previous planning application (MDC ref. 2013/2608/OTS) as difficult or impossible to mitigate with this scale of development. Paragraph 2 of the policy FR6 states ‘The site should be designed sensitively to ensure no harm to its sensitive location and northern escarpment slopes and any design should take account of long range views and the setting of the town.’ but it must be clear that the scale of development proposed – 100 dwellings, likely to be 2-3 storeys and spread across the whole site – will only cause permanent harm to its sensitive location and the northern escarpment slopes and setting of the town, and that it will not be possible to ensure no harm to these aspects. Paragraph 3 states ‘Have particular regard to site layout, building height, and soft landscaping, to minimise the visual impact of the development in this edge of town location.’ but this is a weak and meaningless statement as it is not clear what to ‘minimise the visual impact’ in the context of building 100 dwellings on this sloping site can ever mean.  Para 5 states ‘The site should be designed to safeguard the amenity of nearby residential properties.’, presumably referring to the adjacent residents of Packsaddle Way, but this statement is meaningless without further elaboration and detail, and the impacts on residential amenity from construction and long-term operational traffic (as all highways access is proposed to be from Packsaddle Way) will be difficult to safeguard with this development. Para 6 states ‘Proposals include measures to mitigate any impacts on the Mells Valley SAC including an appropriate level of replacement habitat.’ – if this is to include on site habitat retention, it is unlikely to be possible to retain anything other than the boundary hedgerows; if off-site requirements this should be made clear. Para 7 states ‘Drainage issues should be carefully evaluated’ but gives no indication of any on-site requirements. Policy FR6 therefore contains a number of internal contradictions, and statements that are or may be impossible to satisfy.

Site FRO061 should therefore be recognised as ‘not suitable for development’, as stated in the Council’s own Sustainability Appraisal, and should not be taken forward in the Local Plan Part 2 as a proposed development site.”

Other responses: There are many other issues raised in the responses published so far:

Lilleys Cider have submitted a response (see here) which requests the land between Cuckoo Lane and the Packsaddle estate is allocated for mixed (employment and housing) use and outlines their plans for two new houses (off Packsaddle Way and Leys Lane) and a new purpose built cidery, along with a café/farm shop/community space (accessed off Cuckoo Lane) and apple and pear orchards there. I will be seeking a meeting to discuss their plans.

Old Showfield: The proposal in the Local Plan part 2 to allocate the old Showfield as a Local Green Space has not been universally popular as Frome Cricket Club, Frome Collegians FC and Frome & District Agricultural Society have all objected to the LGS allocation covering their leased and owned land.

The next steps are as outlined here: Mendip DC considers the responses in February/March, which will all be published here. In April the Council will consider if changes should be made to the Plan before submission. In May the Plan, supporting evidence and details of representations will be submitted to the Secretary of State, and will be considered by an independent planning Inspector at a public Examination hearing in July. But it remains to be seen whether this timetable will be affected by any reconsideration of housing allocations for Frome, in light of the emerging proposals by developers (with NVB Architects) for 2,000 homes on land south of Frome right up to the A361 bypass (see here for the Somerset Live / Frome Standard report).