by adamboyden on 24 May, 2021
UPDATE 16th June: The Fair Homes project, and all sites proposed for development within it, including Selwood Crescent green, has been withdrawn in its entirety, following feedback from residents in the consultation – please see the statement from the project partners here. Thank you to everyone who responded. Your local open spaces are now safe. We now need to focus on the viable alternative and sustainable ways to increase the supply of social housing that do not involve building on green open spaces that are either valued by the community or for their ecological value (or both).
The Save Our Green Alliance local group has issued a statement that reads, ‘We are very pleased our voices have been heard and we thank the Frome Area Community Land Trust, Selwood Housing Group and Mendip District Council for listening to us and respecting our views. We consider that retaining and protecting the precious, biodiverse, health-giving, small green spaces within the town is the right decision both for now and in the long term. We would also like to thank Cllrs Adam Boyden and Drew Gardner for the support they have given us throughout. Individual and personal reasons expressing the importance of Selwood Crescent Green have often been moving, even upsetting, to listen to but the coming together of several of the green space communities to speak with one voice has been inspiring and we value the lesson learned for our children and young people who joined the campaign, that if you stand up and take part you CAN be heard. However, we are mindful that this does not resolve the pressing issue of a lack of social housing, a legacy of the poorly thought-out policies of previous governments. Nationally and locally a supply of social housing is needed and some of us will be putting in writing the suggestions we made verbally regarding where and how we think homes, both social and private, can be built to enhance, not fracture, our communities.’
Original article, 24th May:
Mendip District Council, Frome Area Community Land Trust and Selwood Housing Group have formed a new partnership, the Fair Homes Project, which aims to provide more social housing in Frome, offering fair rents for residents in most housing need. There is a pressing need for social housing in Frome. Over 500 families in the town are on the Somerset Homefinder housing register.
The partnership has identified 9 areas of land owned by Mendip District Council land it considers suitable, where up to 30 homes could be delivered. The project was announced on Monday 24th May here, and an initial online public consultation has been launched here to allow the community to have a say on whether each site is suitable.
In our area one site is included in the consultation: the green between Selwood Crescent and Mendip Drive, where four 3-bedroom houses are being proposed. This would mean the development of the public open space and removal of the large evergreen tree and several newly planted trees, but the mature oak and walnut trees would be retained, and the partnership has pledged a 3 for 1 replacement policy on trees.
The consultation website here is inviting views from local residents until 11th June. Residents’ views will be considered before any planning applications are prepared and submitted.
A proposed site plan for the four houses proposed at the Selwood Crescent site has been sent to residents with the official letter (This was delivered to residents in a small area around the green by the project team on Monday 24th May. I have asked that the letter be sent to residents in a wider area. If you do not receive this, please get in touch). It is also available at the consultation website, and is included at the end of this article.
The official letter also refers to intrusive ground site surveys being undertaken soon, to face-to-face consultations being planned once Covid restrictions are lifted, and that if the site shows development potential the project team will involve residents ‘in every stage of the consultation and planning stage’. It is also anticipated that the Fair Homes Project ‘will be presented to Mendip District Council’s Cabinet in July 2021’, for their consideration.
A resident’s campaign group the Save Our Green Alliance (SOGA) has now been started by a number of concerned residents, to help coordinate a campaign to retain the green for local people in perpetuity. All those concerned about retaining the green space can join by emailing firstname.lastname@example.org. Their first article expressing concerns about the plans has been posted here.
Drew and I support increases in social housing on suitable sites, but we are opposed to housing being developed on Selwood Crescent Green, due to the impact on this locally important open space. But what do you think? Here’s what you can do:
1. Firstly, it is vital everyone responds to the consultation in as much detail as possible including whether and how you value and use the green (if you do). Residents’ views will influence what happens next. Details of the site plan and the consultation are in the official letter (please get in touch if you do not have this).
You will need to submit your comments online in the Have Your Say section at the bottom of the Fair Homes project website here before 11th June. Alternatively you can write to: Fair Homes Project, Selwood Housing, Bryer Ash Business Park, Trowbridge BA14 8RT.
2. Come have a chat with us and your neighbours in a socially distanced manner on the green on Saturday 29th May at 10am, and again on Saturday 5th June at 10am. If more than 30 people are present, please be prepared to stand in groups of 30 or less, to ensure Covid safety rules are visibly maintained. Please also wear a mask. Children and animals are welcome.
3. To find out more and get involved, please join our online community meetings on Zoom (https://zoom.us/join):
– Thursday 3rd June at 7.30pm, Meeting ID 851 2569 8430, Passcode 082043, and
– Thursday 10th June at 7.30pm Meeting ID: 895 3581 0593, Passcode: 881874 (the Fair Homes Project partners have been invited to speak on the 10th).
4. If you agree with us please put the poster (see below) up in your window.
5. Let us know what you think:
– comment on the article at www.adamboyden.mycouncillor.org.uk/
– by email: email@example.com and firstname.lastname@example.org
– by phone: 07809 284817 (Adam) and 07860 288624 (Drew)
– Facebook: Drew Gardner, Mendip District Councillor, Twitter:@cllradamboyden.
Adam Boyden and Drew Gardner,
Liberal Democrat Mendip District Councillors for Frome College ward
Update 11th June 2021:
After two leaflets delivered, two meetings on the green and two zoom meetings with residents, I have submitted my response to the consultation below:
‘Consultation on social housing development at Selwood Crescent Green: Response from Mendip District Councillor Adam Boyden
I write to object to the inclusion of the land at Selwood Crescent in the Fair Homes project as a potential housing development site.
Please see below for a comprehensive list of objections which relate to the landscape character, community, recreation, public health, biodiversity, arboricultural, local and national planning policy and design elements of the proposed development, and the need for a more effective strategy for social housing provision.
Selwood Crescent Green is not allocated for development in the Adopted Local Plan Part 1 or the emerging Part 2, and never has been proposed for development. The green was not obtained by Mendip District Council as a potential building plot, but was created intentionally as a landscape feature and public open space for the community as part of the approved plans for the development of the Northcote Estate, when planning permission was granted by Frome Urban District Council (FUDC) in January 1964. The green would then have been transferred to the new Mendip District Council when FUDC was abolished in 1974.
The Frome Town Design Statement notes that the Northcote Estate was facilitated by FUDC in order to help attract key workers to Frome. Many of the original residents are still living here. To fill in nearly all of the green for housing now would remove a significant element of the landscape scheme implemented for this now-established residential area, and would seriously harm the character and appearance of the area. This is entirely contrary to the original intentions of the District and Town Councils’ predecessor, and the commitments made to residents over 50 years ago.
It is most unusual and unexpected for any organisation to propose to build on the green, as it shows a lack of appreciation of the historical development and character of this part of Frome.
2. The consultation has revealed that Selwood Crescent Green is valued and used, actively and currently, for recreation by members of the community of all ages, and has been used for large communal gatherings.
The consultation materials do not give the reasons for Selwood Crescent green being chosen as a suitable potential housing plot for four homes, but it is assumed that the project team considers it ‘under-utilised’ Council-owned land and therefore suitable to build on. The many and detailed responses to the consultation include testimonies from a large number of local residents which clearly demonstrate that this is far from the case.
I also now understand from comments from the project team at meetings that there has been no consideration of the use of the area by the community, and that the site was identified purely due to its size and potential for development, considering the general need for social housing.
Residents’ responses reveal that the green is valued and used, actively and currently, by members of the community of all ages – young children, teenagers, adults and senior residents, local families, for quiet reflection and recreation, to help recover from illness, and to play football, rounders and cricket, host informal social gatherings, parties, and meet with friends and family. It is a place where parents and grandparents can have confidence that children can play safely very close to where they live, with their friends, parents and grandparents, as originally intended over 50 years ago. There is also no MDC sign prohibiting ball games, unlike several other open spaces in the area.
The green’s nature and location also means it has served as a meeting place for major communal gatherings, including carol singing, street parties and fundraising events. It can do so again once Covid restrictions are lifted; residents are now planning a street party to celebrate the Queen’s Platinum Jubilee in 2022.
To remove such a valued green space is clearly unacceptable to local residents. I have received over 30 responses, with all but one objecting to the development. I have asked every respondent to respond using the official consultation website or by email or post, so you will have received many more. Residents have put a banner up on the green, and many residents including children have added their thoughts and photographs – showing evidence of use and how much they value the green. Responses I have received and photographs from the green are attached to my emailed response. A number of residents have also said they would lie down in front of bulldozers to stop any building development, such is the strength of feeling.
I understand this is a genuine consultation which aims to find out whether each site is suitable to develop, and that residents’ genuine feedback on how valuable the green is to them should make a difference to your decision on whether to proceed with a development here or not. I hope the feedback from residents is very clear
3. Selwood Crescent Green has the potential to be designated Asset of Community Value and/ or a Town/Village Green, which demonstrates that it should not be built on.
The local community considers the green to be an asset of community value. It would appear there is evidence that it would meet the criteria for formal designation as an Asset of Community Value under the Localism Act 2011 according to Mendip District Council guidelines. The green has an actual current primary use as open space that furthers the social wellbeing and social interests (for recreation) of the local community, which you can see from residents’ responses. I understand that an application is being prepared by a group of more than 21 local residents to formally register it as such with MDC in the next few weeks.
There also appears to be clear evidence that the green has been actively used for recreation for over 20 years (55 years). As such it would appear to have the potential to meet the criteria for designation as a Town or Village Green under the Commons Act 2006. I understand that an application could also be prepared by a number of local residents to formally register it as such with Somerset County Council.
These potential designations will demonstrate that building on the green is not appropriate
4. Building on urban green spaces also goes against the findings and advice of a wide range of bodies including World Health Organisation and Public Health England, which recognise the importance of close access to green spaces for the physical and mental health and wellbeing of local communities.
The World Health Organisation’s 2016 report Urban Green Spaces and Health – a Review of Evidence concludes, ‘The evidence shows that urban green space has health benefits, particularly for economically deprived communities, children, pregnant women and senior citizens. It is therefore essential that all populations have adequate access to green space …’. Urban green spaces provide ‘many public health benefits through diverse pathways, such as psychological relaxation and stress reduction, enhanced physical activity, and mitigation of exposure to air pollution, excessive heat, and noise as well as other harmful factors in the urban environment. …’. It points out that enhanced physical activity can lead to improved fitness and reduced obesity, and refers to UK studies that show improved mental health and well-being with reduced levels of stress as a result of living in greener areas compared to areas with poorer availability of green space.
It identifies a need for small open spaces –‘The available evidence suggests that there is also a need for small, local green spaces very close to where people live and spend their day, as well as large green spaces, offering formal provisions such as playing fields, and opportunities to experience contact with nature and relative solitude.’
On the loss of green space in urban areas, WHO concludes, ‘Loss and degradation of urban green space can contribute to the burden of disease exacerbating the effects of other adverse factors in the urban environment, such as inequalities, air pollution, noise, chronic stress and insufficient physical activity.’
Public Health England’s report ‘Improving access to greenspace: A new review for 2020’ identifies greenspace as ‘increasingly being recognised as an important asset for supporting health and wellbeing. … Evidence shows that living in a greener environment can promote and protect good health, and aid in recovery from illness and help with managing poor health. People who have greater exposure to greenspace have a range of more favourable physiological outcomes. Greener environments are also associated with better mental health and wellbeing outcomes including reduced levels of depression, anxiety, and fatigue, and enhanced quality of life for both children and adults. Greenspace can help to bind communities together, reduce loneliness, and mitigate the negative effects of air pollution, …
However, population growth and consequent urbanisation combined with competing demands for land use and budgetary constraints, are putting much of our existing local, accessible greenspace under threat. This report makes the case that we must not lose sight of our growing population’s need for it…..’
It goes on to state, ‘some recent valuations have estimated that: £2.1 billion per year could be saved in health costs if everyone in England had good access to greenspace, due to increased physical activity in those spaces; … in England and Wales, houses and flats within 100 metres of public greenspace are an average of £2,500 more expensive than they would be if they were more than 500 metres away – an average premium of 1.1% in 2016, suggesting that the public places a value on being near to greenspace.’
It states ‘Local authorities play a vital role in … improving, maintaining and protecting existing greenspace’. PHE’s report includes as its first ‘policy’, ‘Consider local green (and blue) space to be critical assets for maintaining and supporting health and wellbeing in local communities. The evidence base linking health and greenspace is compelling and encourages fresh thinking about the way these spaces can help meet local priorities.’.
I also agree with a recent article by FACLT Director Cllr Clarke (‘The challenge of providing social housing and protecting our green spaces’) that some green spaces have greater value than others and that ‘It is crucial to recognise there are green spaces that can offer substantive benefit to the community, which have to be protected.’
The responses from residents demonstrate that Selwood Crescent Green valuable to the community because it benefits their health and wellbeing for the reasons identified. The development of any local green spaces could therefore have adverse impacts on the local community’s physical and mental health and wellbeing.
The Fair Homes Project would go against very strong official advice to protect local green space, wherever it reduces the availability of and access to local green spaces. It should therefore remove Selwood Crescent Green, and other local green spaces that are used and valued by the local community, from the development list.
5. Any planning application for development on valued and used public open spaces such as Selwood Crescent Green and others would go against Local Plan policy and raise significant and sustained objections, and is unlikely to succeed.
Mendip’s Adopted Local Plan 2014 at paragraph 6.148 states that the council’s default position is that ‘playing fields and other public open spaces are safeguarded from development. However, opportunities and circumstances sometimes arise where development proposals do seek to make use of public open spaces and the wider community benefits may be worthwhile. In such circumstances, the Council will ensure that the overall estate of public open space is not diminished to a level where local standards are not met, or in a manner that means the accessibility of varied types of open space to the local community falls short of play strategy standards.’
Local Plan Policy DP16: Open Space and Green Infrastructure states in its first paragraph: ‘Development resulting in the loss of existing open, sport or recreational space, including allotments will not be permitted unless:
i. It can be demonstrated that there is an excess of recreational or open space in the settlement and the proposed loss would not result in a current or likely shortfall during the plan period; or
ii. Suitable alternative recreational or open space, which is adjudged to be of equal or greater benefit to the community as compared with the space which is to be lost, is provided in an accessible location. ….’
Given that no alternative recreation space can be provided in the project, the question is whether there is an excess of open space in Frome and whether the loss would result in a current or likely shortfall. The latest assessments of the need and provision of open space in Mendip District which would be used to judge this appear to be the MDC Open Space Study and Open Space Technical Paper, both dated 2012. The Open Space Technical Paper identifies Selwood Crescent green as an ‘informal play area’ on a map of page 3.
The conclusions of the Technical Paper summarised in the Open Space Study in para 4.15 is that ‘Frome is identified as having an overall surplus of 3.45ha of open space but a deficit in informal play space of 0.54ha.’. So if the 2012 study is relied upon, there was an excess of open space in general but a deficit in Frome of the type of open space that would be lost to the project, which the loss of Selwood Crescent green and other informal play spaces would worsen.
However, the 2012 is also substantially out of date. MDC is currently updating its open space assessment and no report is available of this work (MDC Planning Policy officer, pers. comm. June 2021). Frome has been subject to additional population growth in the last 9 years, an increase of 7.6% from a population of 26,186 in 2008 (used for the 2012 Open Space studies) to 28,168 (mid-2019 estimates from ONS) and has seen new residential areas created (some with local open spaces) and some losses of open space (e.g. at the Old Showfield). If the population increase and no change to open space provision are assumed (as there is no current estimate), Frome would now have a deficit of 1.1 hectare of open space overall, which the loss of Selwood Crescent green and other informal play spaces would worsen.
It therefore cannot be clearly ‘demonstrated that there is an excess of recreational or open space in the settlement and the proposed loss would not result in a current or likely shortfall during the plan period’ as Policy DP16 would require. Under policy DP16, we must conclude that development resulting in the loss of existing open space should ‘not be permitted’.
6. National Planning Policy Framework (NPPF) policy is that existing open spaces and recreation land should not be built on.
The NPPF is clear about the importance of protecting open space for the health and wellbeing of local communities, stating in paragraphs 96 and 97:
’96. Access to a network of high quality open spaces and opportunities for sport and physical activity is important for the health and well-being of communities. Planning policies should be based on robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses) and opportunities for new provision. Information gained from the assessments should be used to determine what open space, sport and recreational provision is needed, which plans should then seek to accommodate.
‘97. Existing open space, sports and recreational buildings and land, including playing fields, should not be built on unless: a) an assessment has been undertaken which has clearly shown the open space, buildings or land to be surplus to requirements …’
As demonstrated above in relation to the Local Plan, it cannot be demonstrated that the open space at Selwood Crescent Green is ‘surplus to requirements’, and there are currently no ‘robust and up-to-date assessments of the need for open space, sport and recreation facilities (including quantitative or qualitative deficits or surpluses)’ on which to base a decision to build on open spaces. Under the NPPF paragraph 96, this existing open space ‘should not be built on’. Development on open spaces that are actively used and valued by the local community cannot be justified under the NPPF or our Adopted Local Plan
7. Development would also contravene the Frome Town Design Statement.
The Frome Town Design Statement (adopted by MDC as a Supplementary Planning Document) Policy L3 Green Spaces states ‘Existing areas of public open space should be retained and managed appropriately. Adequate provision of green/open space should form part of new developments.’
The Design Statement identifies Selwood Crescent green as an ‘Other important green space within development limit’ on the Landscape, public spaces and open spaces plan on page 44. The neighbourhood is described under Zone 23: Packsaddle, in which it is stated under ‘Issues’, ‘There is an important network of green space running through the area which needs to be retained and fully used.’.
The loss of Selwood Crescent’s green space (and others) would therefore also contravene this adopted SPD policy.
8. The mature walnut and oak trees will be put at risk.
Arboricultural advice should have been obtained before proposals to develop the site were presented for this public consultation (currently this is shown in the consultation site plan as ‘TBC’).
There are concerns that the old walnut tree is likely to be affected by damage to its roots from building work so close to it, and that the oak tree may suffer from its location within a private garden.
Currently I and residents consider the trees to be at risk due to the development encroaching on their Root Protection Areas (RPA). For single stem trees, in British Standard BS 5837:2012 Trees in relation to design, demolition and construction – Recommendations, the RPA should be calculated as an area equivalent to a circle with a radius 12 times the stem diameter.
The common walnut tree girth at 1.5m is 2.5m. The RPA = 12 x 2.5 = 30m therefore the minimum radius of the RPA is 15m. The English oak tree girth at 1.5m is 1.8m. The RPA = 12 x 1.8 = 21.6m therefore the minimum radius of the RPA 15m. The RPAs for both trees overlap with the nearest pair of proposed houses.
BS5837:2012 states that the ‘default position should be that structures are located outside the RPAs of trees to be retained’. It appears that they will not be. The houses and gardens of the proposed houses would also be shaded by the walnut and the oak, so there would be inevitably pressure from residents to reduce and remove the trees.
These are important trees for the neighbourhood that must be retained, and it appears there is not room to develop houses here as well as to fully protect these trees.
9. Local contact with biodiversity would be reduced.
Residents state that the green is home to a variety of wildlife, including foraging (and possibly roosting) bats, owls and other nesting birds, and squirrels. Trees of this age are host to a large number of species and as such an ecological appraisal should be carried out, including a bat survey.
The WHO’s Urban Green Spaces Review of Evidence (2016) suggests that pro-environmental behaviour can be induced by experiencing natural environments, particularly during childhood. It follows that removing green spaces will have the opposite effect.
10. Highways concerns.
There are concerns in relation to highways access to new properties at the bend of the road, and highways advice will need to be obtained.
11. Building on green spaces in Frome would provide only a very limited contribution to meeting local social housing needs.
The project’s identified need for social housing is for around 500 homes for people registered with Somerset Homefinder that state a preference for living in Frome. The whole Fair Homes project would provide up to 30 homes, just 6% of that need. If the 30 are built, the need for social housing will not end, the problem will not be solved, housing need will continue to rise unless a whole raft of other measures are taken. There may be pressure to develop yet more urban green spaces. The harmful impacts from losing local green open spaces appear to be disproportionate compared to the limited benefits of the project.
The consultation has rightly identified the need for more social housing. But it offers a harmful, short-term, small ‘solution’ that is inadequate to tackle the size of the problem. Instead, the project partners should be working on an ambitious and positive strategy to tackle the issue in several and effective ways, without building on valuable urban green spaces.
12. Suitable alternative less harmful housing development sites and means of delivering social housing have not been fully explored.
The need to build homes on urban green spaces in Frome has been presented entirely in a vacuum, with the message that this is the only way to provide much needed social rented homes in Frome. It is presented as a moral argument, with no detail, background or context to explain how large or small a contribution the project could make to meeting the identified need, in parallel with other means of delivery or a broader strategy. To understand the context and need for the project, I have asked Mendip District Council the following:
1. How much social housing is there in Mendip and Frome?
2. What is the current demand and need for social housing in Frome and Mendip?
3. What are the recent and current trends in social housing provision into the future, including contributions from developments in the planning ‘pipeline’?
4. How much (and what proportions of) social housing is being provided through Section 106 agreements negotiated with private developers in line with Local Plan policy, and by Housing Associations and others directly?
5. What is the gap between Local Plan policy compliance and actual delivery by developers?
6. Would 100% policy compliance be sufficient to meet local needs for social housing?
7. How can we increase policy compliance?
8. Do we employ a S106 Officer, and if not, would it help if we did?
9. What are the current numbers of social homes likely to be provided in the tranche 1 sites approved by Cabinet in November 2020, and potentially at North Parade in Frome?
10. What are the current numbers of social homes likely to be provided by sites with planning permission or Local Plan Part 2 allocation in Frome, including Edmund Park, Caxton Road, Sandys Hill Lane, and the Keyford allocations?
11. What alternative additional delivery models for social housing have been or could be considered? I am aware that Phoenix Board has commissioned reports and considered these in confidential sessions, and that some potential alternatives exist. Will these be included in the Cabinet paper to inform public debate?
12. What is the potential to purchase of land (by MDC or its Housing Company)?
13. How many empty properties are there are in Mendip, what are the trends?
14. What is being done to have them reoccupied as homes?
15. Do we have an Empty Homes officer, and if not, would it help if we did?
16. Can MDC or its Housing Company purchase empty properties and turn them into homes?
17. Can we invest in new partnerships with other landowners (public and private) and developers at suitable sites, including existing brownfield sites, and potentially suitable greenfield sites owned by other public authorities?
18. Are sites in SCC ownership being looked into, such as at Packsaddle Way in my ward (land gifted to SCC for the development of a school several years ago, which was put forward at an early stage in MDC’s Local Plan Part 2 for the potential development of 90 homes, but later withdrawn).
19. Are there otherwise suitable development sites which suffer from development constraints which MDC could overcome using its powers or through applying for Homes England funding.
20. Can we invest in additional social housing provision at sites MDC already has a stake in. such as Saxonvale?
21. Before we justify building on open spaces valued by our local communities, can we review the above information, and form a clear strategy with an achievable target for social housing provision, and how the viable alternative policies can contribute to meeting such a target.
22. Is the paper coming to Cabinet (via Scrutiny) simply proposing to progress the Fair Homes Project in Frome, or does it look at a wider review and strategy for social housing? Can I propose we do the latter?
I understand the need to increase the provision of social housing, and this consultation has rightly drawn attention to the need to tackle housing needs in Frome. However the project currently offers only a harmful, short-term, small ‘solution’ that will not tackle the size of the problem. I look forward to the project team identifying suitable sites for social housing development, but Selwood Crescent Green is not one of them. The local community is responding – please listen to them. I suspect that a number of other sites identified by the project such as Farley Close, Hodders Close and in Keyford ward, are also not suitable to build on.
Building on Selwood Crescent Green, and other urban green spaces in Frome, will cause harm to the character of Frome, increase the deficit in informal green space in Frome, and affect the health and wellbeing of the local community. This is not a good way, or the only way, to provide social housing, and a broader, more effective long-term strategy is required.
Mendip District Councillor, Frome College ward’
If you agree that this is not a suitable housing development please display the following poster in your window:24 Comments