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.