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