Bath Preservation Trust Talking Sense

Sulis Down – Response to public consultation of 9 November 2015 The Trust welcomes the opportunity to feed into the development process for Sulis Down and we have considered the proposals from the consultation event held on 9th November. We accept the need for the sensitive and appropriate development of around 300 dwellings on the Sulis Down plateau based on ‘By Design’ principles and in all ways compliant with Policy B3A of the Core Strategy. The Trust has serious objections to the plans which are being presented and wishes to point out that at this stage we feel naming the proposals Masterplan 1 and Masterplan 2 is premature and misleading. At the Public Enquiry the Inspector specifically laid down the acceptable parameters for the preparation of a masterplan, including the inclusion of all owners on the site (at this stage the plans presented are from Bloor Homes and Hignett Family Trust only), and through extensive public consultation of various options. We regard this phase of consultation as the precursor of the formation of a masterplan; in essence the developers have skipped a stage and the two plans, presented as a ‘fait accompli’, have not been satisfactorily consulted upon and cannot be called comprehensive masterplans under the specific policies laid out in Policy B3A Placemaking Principles (....‘preparation of a comprehensive masterplan, through public consultation and to be agreed by the Council’...). We note also the absence of agreement from the Council on these proposals. This aside, we also have serious concerns about aspects of the two proposed options for the site: Development density: The proposal for 600 dwellings represents an unacceptable level of development that is specifically contrary to Placemaking Principles contained in Policy B3A. We would be interested in the density DPH figure for the proposed options. Whilst we understand the reference to 300 dwellings not being a cap on development we find a doubling of this figure, and the associated increase in the development site boundaries, to be unacceptable and also unjustifiable in any terms except financial gain for the developer. There has been no placemaking evidence to support the increase in dwelling numbers. We also note that in the 2015 workshops stakeholders were not consulted about the plans for doubling housing density and therefore there has been no consultation on this aspect of the ‘masterplans’, this again is in direct contravention of B3A, Point 1. We would consider this to be the key issue for consultation. Development site parameters: the proposed sites 1 and 2 are broadly the same size and both represent unacceptable site encroachment into specifically prohibited areas of the site, namely: Field to the south of the Wansdyke SAM, which was specifically noted as to be avoided in the Inspector’s report. We cannot imagine that housing development close to this Scheduled Ancient Monument would better reveal its significance and protect its setting and therefore the current boundary proposals are contrary to Section 12 of the NPPF (para 137 etc). The South Stoke plateau Southern edge – The proposed development boundary is unacceptably close to this and would therefore cause significant harm to the setting of South Stoke conservation area, to the AONB, and to medium and long views to the site. In addition this Southern boundary is in the zone defined as having ‘high impact’ on the WHS and AONB in supporting evidence in the Examinations in Public, and no evidence has been provided to support the encroachment of the site boundary into this zone. This Southern boundary needs to be set back from its current position to mitigate the potential harm of urban coalescence with South Stoke village as well as the inevitable harm to the GB and AONB. Access arrangements: Policy B3A specifically details access logically from Combe Hay Lane to the West and not from the East because of the risk of urbanisation of the remaining Green Belt areas of the plateau and the harmful effect on the character of the rural lane to South Stoke. The proposed road in option 2 cutting across Green Belt land from South Stoke Lane will add highway infrastructure and street lighting to this open green space. This would pave the way for further suburbanisation at a later date and lead to coalescence of South Stoke Village with the City of Bath. It would also have serious traffic implications for South Stoke lane and would impact further on the, already overstretched, infrastructure of the surrounding urban areas. Urban Design: it is apparent from the housing development at Sulis Meadows that its layout, with the through spine road, was premised on the assumption that the field beyond would become available for housing, but this is not the case. The same false anticipation seems to be assumed for this urban plan. The development should instead reflect the containment inherent in the Placemaking Policy B3A. Business Village: we refute the developers claims that this area adjacent to the Manor Farm Buildings is ‘brownfield’ and note that whilst it is shaded brown (ploughed?) on the options maps (and allegedly therefore available for development), all of it is actually Green Belt land and subject to protection as per the NPPF. The Trust strongly objects to the consultation proposals on the basis that the development site as currently proposed would cause very significant harm to multiple heritage assets, South Stoke conservation area, the Green Belt, AONB and the Wansdyke SAM. The proposals are in contravention of specific policy principles laid out in the Core Strategy Policy B3A and in particular we do not support the concept of a doubling of housing density on this highly sensitive and important green plateau area. We particularly object to being presented with two almost identical ‘options’ as an apparent attempt to create an acceptable 'aura' around the concept of a significantly higher density on this site. We reserve the right to make further comments at future consultation and planning stages. We would be willing to engage and consult with the developers at any stage of the process, to help them to create a high quality, workable new development, well integrated with its surroundings and in accordance with B&NES Adopted Core Strategy and the detailed placemaking parameters set out for this area.

B&NES statement

This is powerful stuff and what we want to see from our council - extract below for the whole document use the link Based on the evidence submitted to date the Council does not consider that the masterplan options demonstrate that an eastern has appropriately considered these impacts or identified how they might be mitigated. http://www.bathnes.gov.uk/sites/default/files/sitedocuments/Planning-and-Building-Control/Planning-Policy/Core-Strategy/odd_down_council_website_statement_nov_2015.pdf

More on consultation

Dear Resident, As you may know, last Monday the developers of the planned Sulis Down housing estate held a consultation event at St Gregory’s School at which the public were invited to comment on two options for their masterplan submission for the site. The consultation represented what was probably the last chance residents have to influence the final shape of the development before a scheme is submitted to Bath and North East Somerset Council (B&NES). We at the South of Bath Alliance (SOBA) are writing to you to urge you to respond by 19th November by rejecting both the proposals on the grounds that they completely fail to conform to the planning principles defined by the inspector who carried out the public enquiry into the B&NES core strategy and adopted by the council last year. In summary, both masterplans envisage up to 595 homes being built—nearly double the 300 or so specified in the core strategy. Both masterplans envisage building on the edge of the South Stoke Plateau and, in part, on the field beside the Wansdyke to the east of the present Sulis Meadows estate—areas protected in the core strategy. Masterplan 1 has the new development served by a single access road off Combe Hay Lane which, given the huge increase in the number of homes proposed, would seriously add to the traffic congestion at the Odd Down Park and Ride roundabout. Masterplan 2 envisages an additional access road off South Stoke Lane, which would mean a large increase in the number of vehicles using the Cross Keys crossroads, which would become traffic-light controlled. This access was expressly excluded from the core strategy after the planning enquiry inspector declared it detrimental to the setting of the Wansdyke, a Scheduled Ancient Monument, and the Bath World Heritage Site. The inspector saw no justification for access from the east and it is considered that the case for eastern access has not been made either in terms of any benefits it might deliver or the environmental, heritage and transport impacts/harm it is likely to have. The development site is bisected by Sulis Manor and one of the options for the road linking its west and east sections incorporates Burnt House Road on the Sulis Meadows estate. This would mean hundreds more cars passing through an existing residential area. Both masterplans can be inspected on the Sulis Down website at www.sulisdown.com under ‘Consultation event, November 2015’ in the News and Updates section. It is the view of B&NES officers that it has not been adequately demonstrated that 595 dwellings is deliverable on this site while meeting all of the Placemaking Principles in the site allocation policy. There is currently insufficient evidence to substantiate this scale of development and officers also question the methodology adopted to generate this number of dwellings SOBA comprises local residents’ groups and parish councils who originally opposed the building of any homes on the South Stoke Plateau but who now want to ensure that the developers—the Hignett Family Trust (HFT) and Bloor Homes—create the best possible living environment for both existing residents and those moving into the new homes. We ask you register your objections in your own words to both masterplans at www.sulisdown.com/#!contact/cseo Points you might consider making: 1. Neither proposed masterplan complies with B&NES Adopted Core Strategy. 2. Any proposal to deliver more than 300 dwellings on the entire site would have to be supported by evidence that this could be achieved within the council’s established ‘Placemaking Principles’. No evidence to support this has yet been made public. 3. The core strategy specifically disallows development on the field adjacent to the Wansdyke. Both options encroach significantly onto this area, causing potential harm to the Scheduled Ancient Monument. 4. In both options the southern edge of the proposed development is now shown to be in the zone defined as having ‘high impact’ on the World Heritage Site and Area of Outstanding Natural Beauty. This can only be allowed if detailed evidence is provided to support it. No such evidence has yet been submitted. This will dramatically affect views into the site from key points of public access to the south. 5. The core strategy specifically forbids any access from the east because of the risk of urbanisation of the remaining Green Belt areas of the plateau and the harmful effect this would have on the important ‘rural’ entrance to the Conservation Village of South Stoke. The presence of any form of road across the Green Belt ‘buffer zone’ at the eastern end of the plateau will lead to the coalescence of South Stoke with the City of Bath and open up the possibility of the entire plateau being developed at some time in the future. 6. Manor Farm Buildings are shown as “Sulis Down Business Village”. HFT describe this as a ‘brownfield site’, so expect to redevelop it all for commercial purposes. However, 60 per cent of the area is a green paddock that was once the South Stoke Cricket Field. It remains in the Green Belt and is therefore subject to constraints on development. It would be of particular concern to avoid any further commercially generated traffic on South Stoke Lane. For further information, contact southofbathalliance@gmail.com

Statement from SOBA

IF YOU CARE about the controversial Sulis Down development on former Green Belt land on the southern outskirts of Bath then you can make your views known at the next consultation organised by the developers. It is possibly the last chance for residents and all those concerned about the development to influence the proposals before a masterplan for the site is submitted to Bath and North East Somerset Council. The site on the South Stoke Plateau is currently defined for around 300 new homes in the core strategy adopted by the council last year after a public inquiry. However, the developers—Bloor Homes and the landowner, the Hignett Family Trust—have caused further controversy by announcing in September that they intend to test the capacity of the site in their masterplan by “bringing forward scenarios that include a scale of development significantly higher than that envisaged in the core strategy.” This, it is feared, could mean up to 600 new homes being built— i.e. double the number anticipated. The South of Bath Alliance (SOBA), a network of the communities affected by the development, fought against any housing being built on the Green Belt. Following the council’s inclusion of the site in its core strategy, SOBA is now pressing for the developers to work within the principles approved by the planning inspector which are enshrined in the strategy itself. A further concern is the matter of access to the Sulis Down site. BANES adopted core strategy envisages accessing the whole of the development from Combe Hay Lane to the west but it is divided by Sulis Manor, whose owners have not expressed publicly a view on the plans. There is continued debate about an eastern access from South Stoke Lane (which also could involve access from the Cross Keys (roundabout) across the Green Belt with street lighting etc). This is an option that the Inspector ruled out as being detrimental to the setting of the Wansdyke, a Scheduled Ancient Monument, to the Bath World Heritage Site, to the Green Belt and to the Conservation Village of South Stoke. In addition it would place considerable extra stress on the existing traffic flow via Midford Road and Southstoke Road into the city.

Consultation event

The next consultation is9th November between 16.00 and 20.00 at St. Gregory's school

Recent Bath Chronicle Article

There has a flurry of documents on the Sulis Down Web site http://www.sulisdown.com/ regarding the development on the Southstoke Plateau. The Bath Chronicle has picked up on this and suggested that 600 houses could be built. This would be contrary to the councils plans and that of the government inspector that heard the public inquiry into these plans. We have tried to clarify the position with the developers and have been told that nothing had yet been decided. It remains the view of SOBA that nothing should have been built on the plateau, but having had a public inquiry and from that a full report, this should be honoured. It is not to us guidance, but the rules by which any development should follow.

Odd Down FC statement

This is from the www.sulisdown.com web site Summary ODFC provide an important football club and community facility alongside Combe Hay Lane and as such, wish to participate in the planning and master planning process for Sulis Down, reflecting the objectives of Place Making Principle 10 within Policy B3A of the BANES Core Strategy 2014. With limited resources at its disposal, the club will take a cautious approach to assessing options during the master planning and subsequent stages, but at this point wish to remain open minded and rule nothing out, especially if this would result in long term benefits for the football club and the community. We also recognise the potential significance of providing upto 80 local homes, including affordable housing, here in Bath. We therefore wish to work with the other landowners at Sulis Down and the Council to explore the opportunities and constraints that may arise from Policy B3A and its Placemaking Principles and support the proposed master plan. Background ODFC owns the Lew Hill Memorial Ground, off Combe Hay Lane, Odd Down. The Ground, which comprises approximately 2.2 hectares of land, is allocated in the Council’s Core Strategy 2014, as part of a mixed use development scheme ad joining Odd Down, known as Sulis Down. The Club was founded in 1901, playing on various local pitches before setting up their ground at Combe Hay Lane, which the Club purchased in 1952, known as the Lew Hill Memorial Ground. A social Club was opened in 1972. Currently the Club play in the Premier Division of the Western League. The ground has one full professional playing pitch and a smaller training ground. Both are grass and play is limited to, at most, 2 or 3 matches a week depending on conditions.Income for the Club (there are player and match fees to pay) is produced from many sources, chiefly a popular social club (approximately 500 members) – open every day/evening and which attracts 250 on a good evening. Membership is drawn from Bath, almost exclusively and mostly local to Odd Down. It is the largest social focus for Odd Down. The Clubroom (which has accommodated 400) is used for parties - business seminars, funeral wakes etc. and has good facilities. As well as football, the Club has 5 skittle teams and darts teams and runs many events for the older population. The grounds have good car parking and the club has contractual arrangements for daily parking with St. Gregory’s School and New Sixth, as well as the GP Surgery in Sulis Manor Road.The car park accommodates vehicles for other activities – for using mobile vehicles (training, screening etc) and runs a weekly weekend Farmers’ Market with a regular handful of stalls. The professional pitch is flood lit and must maintain a minimum crowd capacity and facilities to compete in the relevant league. The Club is managed carefully to balance its books and has a very local membership. Its business model works and balances its market with the particular management level and price point it has.There is understandable concern that its business model could easily fall out of balance if running costs, membership costs, location, character etc change. But it does need capital investment, especially to keep an offer that works for existing and new families. It would like to do more work to bring school age children into the game and swaps facilities with St Gregory’s School at both summer and winter seasons.The Club would like to develop a new Clubhouse facility, ideally located above improved changing rooms and storage. Such facilities might include separate function rooms as well as the Social Club. Existing boundaries to the club are overgrown and in poor condition and in places unauthorised access is an issue. Planning Position The Lew Hill Memorial Ground extends to about 2.2 hectares and is bounded by Combe Hay Lane to the west and Sulis Manor Road to the north and Sulis Meadows immediately to the east. Since the adoption of the Core Strategy in 2014, the grounds are allocated for redevelopment as part of the mixed use scheme at Sulis Down, as reflected in Policy B3A, the Concept Plan and numerous Placemaking Principles. The relevant policy for the ground is Placemaking Principle 10, which states: 10 Retain and/or enhance the Odd Down Football Club (Football Pitches, Clubhouse and changing facilities, play area, local market and car park) either: (i) in its current location; or (ii) by re - providing the Football Club with an equivalent facility within the area (extract from BAN ES Core Strategy 2014) Those responsible at ODFC did not seek to allocate the Memorial Ground for new housing, however the opportunity to enhance the football club facilities as referred to above, is something which the club wishes to fully explore and pa rticipate in. The redevelopment of land immediately alongside the Memorial Ground for atleast 300 homes, is also of great interest to the club as it wishes to develop its community facilities that complement new housing, whilst supporting the football club into the future. Therefore the production of a master plan that reflects the elements and opportunities expressed in Placemaking Principle 10 is desirable at this stage. The provision of an equivalent facility within the area is clearly a significant concern of the club, should it contemplate relocating. A number of options within Sulis Down have been tabled and the club will carefully assess these alongside other alternatives in due course. The club understands that the Memorial Ground could accommodate up to 80 new homes within Sulis Down and consequently appreciates the significance of such a housing provision, including an element of affordable housing, which is much needed in Bath. Nevertheless the location of the Memorial Ground is important to the community it currently serves, including the Social Club, St Gregory’s School and New Sixth and the GP Surgery. Therefore seeking to balance all those needs, together with the future needs of the football club will form part of this master planning process and decisions of the club in the future. Enhancing existing facilities at the Memorial Ground will also be examined carefully, particularly if this can provide an enhanced community role in Sulis Down and secure a strong future for the football club. Participation The club has participated in the earlier Core Strategy process and has worked alongside the Hignett Family Trust, who have continued to promote Sulis Down. The club engaged in the earlier public exhibition and workshops and will participate in the master planning workshops with the Council, however due to limited resources, the club will not be committing to future, at risk, expenditure through a Joint Planning Performance Agreement (PPA). Nevertheless the chairman and other officers of the club will try to attend relevant workshop events and support the landowners as they draw up the master plan. Its is hoped that this Position Statement and the participation of the club, demonstrates that achieving the outcomes set out in the Placemaking Principles is fully supported by the club. Therefore options to retain the club in its current location or to relocate it nearby, need to be reflected in the master plan. The alternatives should in either case, lead to enhancement of the club and to a secure future. Because the club also serves an important social function to the community of Odd Down, the relocation of the social club function would be extremely sensitive. Alternative locations on Sulis Down have been provisionally assessed at public workshops and whilst it is premature to reach any firm conclusions, locations in the immediate vicinity of Combe Hay Lane would be more likely to address the requirements of the club. The landowners and the Council will examine the constraints and opportunities of these options and reflect these in the master plan. Future Decisions The chairman and other officers of the club will engage in the planning process to ensure that the interests of Odd Down Football Club are understood and protected. Ultimately the conclusions of this process will be discussed and approved by members of the club following any recommendations from the chairman and other officers. The formation of a master plan will be a useful step in this process and will provide greater clarity to the club.

Peter Duppa-Miller

It is with sadness that we no longer have Peter Duppa-Miller as one of our members. With Peter passing away we have lost a huge advocate for the area, and such a huge amount of knowledge and experience. We will always remember the efforts Peter has put in to us trying to achieve our objectives.

SOBA objectives

SOBA was originally set up to stop the building of houses on the Southstoke plateau. With the ruling of the government inspector allowing around 300 houses to be built that objective is lost. As part of the work by SOBA members a number of key points were agreed by the inspector, to maintain as much of the environment that we have fought to retain. The new objective of SOBA is to ensure that these hard fought points are included in the new development.

Timetable update

Since the last SOBA meeting we have received the following summary of the expected progress of the “Sulis Down” Masterplan. July 2015. Public Consultation on a Draft Masterplan. Sept/Oct 2015. Draft Masterplan will be submitted to B&NES’ Planning committee for comment. Jan 2016. 1st Planning Application likely to be submitted. This would then go to The councils planning meeting in Mar/Apr 2016

Sulis Meadows questionnaire

Results of the Sulis Meadows Questionnaire below Click Here

Key documents

Inspectors report

http://www.bathnes.gov.uk/sites/default/files/sitedocuments/Planning-and-Building-Control/Planning-Policy/Core-Strategy/cs_pins_final_report.pdf

Adopted Strategy

http://www.bathnes.gov.uk/services/planning-and-building-control/planning-policy/core-strategy-examination

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