An outline planning application has been submitted for 96 houses, and some live-work offices, at Packsaddle Way and Innox Hill / Spring Gardens, on the site identified in policy FR6 of the Mendip District Pre-Submission Local Plan Part 2, planning reference 2018/0256/OTA: ‘Outline application with all matters reserved save for access, for a residential scheme of 96 mixed tenure dwellings, market & affordable, custom market & affordable, co-housing and live work dwellings with work units. – Land At Packsaddle Way, Frome, Somerset’.

The application documents are found here, including a site layout, and assessments of planning, design and access, transport, flood risk,  landscape, wildlife habitats, noise, air quality, and crime. Public consultation now runs until 2nd April 2018 (this was extended from 28th March due to the late installation of a site notice). The site is in Market ward, for which cllrs Des Harris and Stina Falle are ward councillors at Mendip, but the effects on the Packsaddle area and most of the affected residents are in College ward and so are my concern.

I reported on the proposed ‘Pre-Submission’ Local Plan site allocation for 100 houses here, and my objection to the allocation here. I wrote about the previous planning application for 107 houses (which I objected to, and which was then withdraw) here.  Having a Local Plan allocation for development will mean that planning permission is much more likely to be granted for such a development.

I have attended two meetings of the group of residents from Packsaddle Way and Spring Gardens which has formed in opposition to both the Local Plan allocation. I attended Frome Town Council’s Planning Advisory Group in March, and spoke on the application along with several residents (including Chris Hare), and a response from Market ward councillor Des Harris was also read out. The Panel unanimously agreed to object to the development – FTC’s objection can be found here.

As I said at the Frome Town Council planning meeting, I do not like being negative, and there are some good ideas here (the inclusion of live-work units to encourage home-working and reduce the need to travel, and the inclusion of custom build sites, for which there is a demand in Frome) but they are overwhelmed by the harm the application would cause. I am objecting to this development on the following grounds:

1. The application is premature, in advance of the examination and adoption of Part 2 of Mendip’s Local Plan. The development is outside the adopted Local Plan development limit and so could be refused on that basis alone. There is no urgent need for this development, as I understand that the Council has an adequate 5 year housing supply in accordance with the NPPF. The future decision on the Pre-Submission Local Plan Part 2’s policy F6 for site FRO061 (which proposes to allocate the site for up to 100 dwellings) would be rendered completely and utterly meaningless if the planning application was approved. The application should be refused on that basis.
2. As highlighted in the Council’s Local Plan Part 2 Sustainability Appraisal, this site is not suitable for this much development 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.  The site lies within an area identified as ‘Good quality land which is prominent and important in the setting of the town’ in the ‘Landscape Assessment of the Fringes of the Towns in the Mendip District’ (August 1996; Figure 8.1, ‘Landscapes at the edge of town’: zone 2B; and Figure 8.2a Frome Landscape Analysis, in Area 3: Cuckoo Hill, an area of ‘Prominently visible land at edge of town’), which forms part of and informs the Council’s Landscape Assessment of the district (1997) within the Local Plan evidence base; these qualities are also restated in the Mendip Local Plan Part 1’s Sustainability Appraisal, at Appendix 12, which also notes the site is ‘steeply sloping land’. The steeply sloping nature of the site means that it is highly visible from countryside to the north, west and east, and from residences to the south, as existing hedgerows do not screen the site, yet no structural landscape planting is proposed. The applicants’ submitted Landscape and Visual Assessment Report is dated April 2014, for a different development proposed on the site (MDC ref. 2013/2608/OTS) and no attempt has been made to update it or even refer to the new planning application within it. I also support Frome Town Council’s request for a fuller assessment of the landscape and visual impacts – for plans to be submitted clearly showing the height of the buildings on cross section plans of the site and landscape drawings, together with a photomontage and a plan showing the zone of visual impact. The development would be completely incompatible with the valued landscape character, and so does not meet the requirements of adopted Local Plan part 1 Policy DP4: Mendip’s Landscapes, for development proposals to ‘demonstrate that their siting and design are compatible with the pattern of natural and man-made features of the Landscape Character Areas, including cultural and historical associations, as detailed in the “Landscape Assessment of Mendip District’. The application also demonstrates that nearly 100 houses here is ‘overdevelopment’, and will be of higher density than nearby residential areas in a rural area, which is against the requirement of adopted Local Plan Policy DP7  for development ‘to be of a scale, mass, form and layout appropriate to the local context’. The application would create a sizeable intrusion of development into open countryside which would damage and erode its attractive rural character and have a serious visual impact, and should be refused on this basis.
3. As highlighted in the Council’s Local Plan Part 2 Sustainability Appraisal, it is not suitable for development due to its poor relation and distance to facilities which will only encourage car travel. Road and pedestrian access is poor and may be unsafe. Innox Hill may be too narrow for the expected additional traffic, and has no pavement along a section to the south towards the town centre (along which residents will be expected to walk), which the application will do nothing to rectify. The submitted Travel Plan will not effectively promote walking, cycling or public transport use.  The prospect of walking up a steep hill to Packsaddle Way will be offputting and will only encourage car use for many residents. Packsaddle Way is already a very long cul de sac. The application appears to fail the requirements of adopted Local Plan policy DP9 Transport Impacts of New Development, to maximise use of sustainable forms of transport, and to ensure a safe and satisfactory access for all means of travel. There appears to be insufficient space within the site for car parking, so this is likely to spill out on to Packsaddle Way and Innox Hill – although as parking details are reserved so it is not possible to tell. Further information should be requested to demonstrate that adopted Local Plan policy DP10 parking standards can be met.
4. It is unsuitable for this sloping edge of town site, and there are concerns over the viability of developing the site given the steep slope and hard ground conditions experienced at the neighbouring Packsaddle Way development many years ago.
5. The development would conjoin the town of Frome with the hamlet of Spring Gardens. This significant planning outcome should only be allowed after detailed examination and adoption of the site allocation in the Council’s Local Plan part 2.
6. Construction of the site, particularly custom and self build houses, would take many years to build out. Construction traffic and activity would be likely to affect the amenity of residents of Packsaddle Way, Innox Hill and Spring Gardens for years.
7. It may exacerbate surface water and sewage flooding downstream at Spring Gardens within Flood Zone 3, which have been highlighted by several residents, and will be of concern to the Environment Agency and the water company. Springs within the hillside within the site may excaserbate this.
8. The proximity to Frome sewage treatment works may bring hundreds of new residents too close to a recognised potential source of odour and fly nuisance. I support Wessex Water’s concerns on this issue.
9. There is very little ‘affordable’ housing proposed – only 3 units out of 96, which is well below the Council’s policy of 30%.
10. I support the concerns of Frome Town Council on the above issues.
11. I support the concerns of the Somerset County Council Ecologist and Natural England in relation to the inadequacies of the ecological surveys undertaken at the site, and the need for mitigation for bats and biodiversity, in accordance with adopted Local Plan policies DP5 and 6. However, there appears to be no room in the development for nature conservation.
12. No recreational open space is identified within the site for new residents, which goes against the requirements of adopted Local Pan policy DP16.  It is very similar in likely layout to the 2013 withdrawn application for 106 houses – and the applicants should withdraw again and await the outcome of the proper Local Plan process.

Residents in the area have a right to raise concerns, as expressed in the Frome Times and Frome Standard articles here and here.

Adam Boyden

Mendip District Councillor, Frome College ward