The following letter was generated by ADVEARSE members on my behalf…

ADVEARSE
8, Lodge Lane
Bridport
West Allington
DT6 5QR
advearse@aol.com

The Rt Hon Sajid Javid MP
Secretary of State for Communities and Local Government
c/o The National Planning Casework Unit
5 St Philips Place
Colmore Row
Birmingham
B3 2PW
npcu@communities.gsi.gov.uk
pcu@communities.gsi.gov.uk

2 January 2018

Dear Minister

West Dorset District Council, Planning Application Ref: WD/D/17/000986 — Land at Vearse Farm, Bridport — Case Officer: Jean Marshall

We would like to request a call-in with respect to West Dorset District Council’s (WDDC) resolution made on 3 November 2017 to grant outline planning permission for the above development of up to 760 houses and other mixed use.

We believe WDDC did not give due consideration to the assessment of the substantial harm this development will cause to a designated area of outstanding natural beauty (AONB) and national heritage assets; that it did not sufficiently stipulate reasons which might justify such harm; that it did not sufficiently stipulate any potential public interest advantages to the proposal, or assess and explain whether any such advantages might be more in the overall public interest than any potential harm. We further believe that WDDC failed to give due consideration to any implications the granting of this permission will have for the potential for future substantial harm to other AONB land in West Dorset and beyond. We believe WDDC’s decision is open to challenge not simply as to the quality of its judgment on this planning issue but on a failure to address, as policy requires, the fundamental issue of the protection of a designated landscape and to consider the true nature of ‘exceptional circumstances’.

We believe the council officers’ report to the committee failed faithfully to represent expert opinion as to the damage that the development would inflict upon the AONB, that it failed to address the existence or otherwise of ‘exceptional circumstances’ as required by the National Policy Planning Framework (NPPF) and that it failed to justify its recommendation of a decision contrary to Local Plan (LP) Policy ENV.1. We thus believe that WDDC has failed in its democratic duty to give any legally adequate explanation or provide sufficient reasons for its decision to allow a residential development of such an unprecedented large scale on an AONB, and failed properly to apply the pressing requirements of paragraphs 14, 17, 32, 114, 115 and 116 of the NPPF and the Environmental Impact Assessment (EIA) Regulations.

We consider this issue to be of more than local importance because the site covers 454,000 square metres of high-quality agricultural AONB land which should expect to have the highest status of protection in relation to landscape and scenic beauty. Records show the presence of a farm and field system at Vearse dating back to at least 1668. The farmhouse and buildings (listed Grade II) have remained isolated within an agricultural landscape for over 200 years, and the land contributes significantly to the setting of the designated Bridport Conservation Area. The site is in Symondsbury Parish, just outside the western edge of the town of Bridport. It is overlooked by many significant hills*, including the iconic Colmer’s Hill landmark, and lies fewer than 1.5 miles from the heart of the Jurassic Coast World Heritage site, deemed of outstanding universal value and international importance to earth science. We submit that these factors represent the true exceptional circumstances here, and that the public interest inherent greatly outweighs any public interest advantages to the proposed scheme.

The vast numbers of new people the development would introduce into the town would put great pressure on existing, already strained and diminishing services and infrastructure, most of which are outside the remit of the heads of the Section 106 agreement. These issues include strain on local NHS services, the inability of the local roads to cope safely with the additional traffic in terms of both vehicles and pedestrians, and the recent drastic cuts to local bus services. We believe the application contravenes the aims of LPT3 (May 2017), in particular points 4 and 5 of Strategy Measure 6, and is not in accord with paragraph 32 of the NPPF (particularly in terms of avoiding additional road safety risk and improving safety for vulnerable users). While the highways ‘experts’ have consented to the proposal, we have identified at least two errors** on which they have had to back track. Dorset County Council (DCC) Highways’ response has been to say that we should take this up with WDDC, which responds that ‘the experts say it’s OK’. So far is the development from having exceptional merit or meeting the public interest that the officers’ report to the committee is peppered with instances where consultees find the latest version of the applicant’s plans still falling short of their requirements, failing to respond adequately to their suggestions or making unfounded assertions.

*The applicant’s Environmental Statement states that ‘The Site is surrounded by a series of hills and ridges that limit views towards it from the wider AONB’, but these hills and ridges that overlook it are the wider AONB, views from which will be severely harmed by the development.

**For instance, the developer submitted a drawing of an alteration to a junction (North Allington roundabout) designed to relieve the increased traffic flow resulting from the development. DCC Highways deemed this significant enough to include it in the outlined Section 106 Agreement details. However, following representations from objectors at the planning committee meeting the DCC Highways officer admitted that the suggested alteration was a mistake. The applicant also proposed the addition of advisory cycle lanes to the principal access road (B3162) leading to Bridport town centre. These must have been discussed with the Highway Authority but again following representations from objectors who were concerned about road safety (the road is only 7m wide) DCC Highways said that advisory cycle lanes were not something they wished to pursue. Local residents remain concerned that the pressure DCC Highways is under to facilitate this application may result in other road safety errors being made. For instance, did DCC Highways also make a mistake when they told the planning inspector who approved the LP that they were satisfied that measures (including the aforementioned mistaken ones) could be taken to accommodate the level of development involved?
 
The nature, size and location of this development would significantly impact the environment, character, culture and heritage of the town and countryside, and adequate reasons have not been provided to explain why such rapid, massive urban growth in this area is considered to be in the public interest.

Paragraph 114 of the NPPF stipulates:

Great weight should be given to conserving landscape and scenic beauty in … Areas of Outstanding Natural Beauty, which have the highest status of protection in relation to landscape and scenic beauty.

Paragraph 115 adds:

Planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest.

As found in the case of the Kent branch of the Campaign for the Protection of Rural England (CPRE) vs Dover District Council, a local planning authority which is going to authorise a development which will inflict ‘significant detrimental impact’ and substantial, ‘long-term’ or ‘irreversible’ harm on an AONB must give substantial reasons for doing so (paragraph 2.212). The Kent judgment found this issue to be clearly at the very centre of the policy expressed in NPPF paragraphs 115 and 116 and in EIA Regulations.

The officers’ report to the planning committee quotes from the Dorset AONB Team’s comments but with significant omissions, some of which prejudice the view of the adverse impacts of the development on the AONB. Notably, the report omits the opening sentence of the second paragraph of the AONB report:

As you will appreciate, a development of this scale at this location will produce a range of adverse effects that conflict with the primary purpose of the designation, this being the conservation and enhancement of the Area’s natural beauty.

It is only by suppressing such comments that the report to committee can misleadingly claim (Report 12.9):

Overall, both the AONB Team and the Landscape Officer consider that the visual and wider landscape impacts of the development are acceptable.

The WDDC Landscape Officer also highlights the conflict with policy and the possible practical difficulty of ensuring the ‘moderation of adverse effects’ following a grant of outline planning consent, remarking:

the proposals, owing to their scale and location within the AONB, inevitably conflict with Policy ENV1 i), ii), and iii) which aim to protect the area’s exceptional landscapes including their landscape quality and diversity, uninterrupted panoramic views, individual landmarks, sense of tranquillity and remoteness.

Through selective presentation, the officers’ report thus hides the extent of expert assessment of the fundamental conflict between the development and the protection of the ‘designated landscape’; misleadingly suggests that the AONB Team and others consider ‘mitigation’ of landscape damage could be total; and obscures the extent to which they consider the developer could and should have responded more fully to their suggestions.

See also, for example, the comment of Natural England:

In our previous response (dates 2 June 2017) Natural England set out a number of landscaping and biodiversity issues that we considered needed to be addressed by the application. The submitted modified plans have failed to address these issues…

It is the report’s own opinion, rather than that of the expert and other representations received, that (12.11): ‘Overall, the proposal is considered to be acceptable in respect of its potential visual impact on the site and surroundings and in its impact on the Character and openness of the AONB.’ No case is in fact argued for the assertion that follows in the report that the proposal complies with the provisions of LP Policy ENV.1 or the NPPF (paras 115 and 116).

The only ‘exceptional circumstance’ cited in the council officers’ report as justification for this project is ‘housing need’. This disregards paragraph 14 of the NPPF, footnote 9 of which specifically stipulates that ‘policies relating to sites … designated as … an Area of Outstanding Natural Beauty’ should apply to decision-taking whether or not the LPA can demonstrate a five-year housing land supply. In addition, however, the extent and nature of the genuine housing need of local people of Bridport has been clearly identified and this development would fail to resolve that need because the housing on offer would be chiefly targeted at the higher end of the open market and would thus be inaccessible to those for whom the ‘housing need’ exists. Around 500 of the houses planned are simply not needed in this area at all, and should not, therefore, be part of the council’s housing land supply calculations. Further, we do not believe the planning authority had sufficiently investigated scope for alternatives, such as brownfield sites (the register of which was not published until 3 December 2017), empty or abandoned properties and industrial units, or any more truly strategic and relevant housing-need solutions. We therefore submit that there is no identifiable need for such housing on this AONB land and that the public interest against the project far outweighs that for it.

The local town council and both affected parish councils all voted against the development; 251 representations were made by 281 local people, only two of which were in support; and at the outline planning meeting around 27 local people spoke against the proposals. The only justification WDDC has provided for the disregard of these democratic representations is the circular argument that the site has been designated for development in the LP.

We understand that any planning applications should be decided in line with the LP unless material considerations indicate otherwise. However, the LP is also not supposed to be set in stone, but is supposed to be revised and updated as new information becomes available and/or circumstances change (NPPF 17). In this case WDDC has failed to address many issues brought forward by hundreds of local people which should have been resolved during the LP development or, at the latest, at the outline planning stage for this specific proposal. Further, we believe that there are material considerations which should decide against this development and that the LP itself is seriously flawed.

The West Dorset LP states at 3.3.6:

In the plan area, local housing and economic needs cannot be met without major development in the Area of Outstanding Natural Beauty. The need for growth from both a national and local perspective is considered to justify the exceptional circumstances for allowing major development to take place within this nationally designated landscape.

This appears to be WDDC’s only stated ‘exceptional circumstances’ justification. However, this is plainly a general and not an exceptional circumstance at all, and this paragraph explicitly demonstrates that WDDC has abandoned any attempt to discriminate where development might be more or less damaging within the AONB. This blanket approach, as implemented in the Vearse Farm resolution, logically provides slippery slope justification for new development anywhere within the AONB as the local authority continually struggles to meet government-imposed housing targets, thus negating the requirements of planning policy as expressed both elsewhere in the LP and in the NPPF.

We believe the LP fails to apply the terms of NPPF Paragraph 14, which stipulates that such plans should ‘meet objectively assessed needs … unless … any adverse impacts of doing so would demonstrably outweigh the benefits, when assessed’ against overall or specific policies contained within the NPPF. The Suffolk Coastal case in the Supreme Court established that, as well as NPPF policies, development plan policies, such as ENV1 i), are covered by the reference to ‘specific policies’ in NPPF 14 footnote 9. LP Policy ENV1 is absolute in its disallowal of a development such as this:

The plan area’s exceptional landscapes and seascapes and geological interest will† be protected, taking into account the objectives of the Dorset AONB Management Plan and World Heritage Site Management Plan. Development which would harm the character, special qualities or natural beauty of the Dorset Area of Outstanding Beauty or Heritage Coast, including their characteristic landscape quality and diversity, uninterrupted panoramic views, individual landmarks, and sense of tranquillity and remoteness, will† not be permitted.

and,

Development should be located and designed so that it does not detract from and, where reasonable, enhances the local landscape character. … Development that significantly adversely affects the character or visual quality of the local landscape or seascape will† not be permitted.

†The policy wording of ‘will’, rather than ‘should’ throughout should be noted as the case officers’ report points out its significance in other contexts.
 
The government inspector’s report on the LP (Report to West Dorset, Weymouth and Portland Councils by Paul Crysell BSc MSC MRTPI an Inspector appointed by the Secretary of State for Communities and Local Government Date 14 August 2015) notes that ‘The size and extent of the allocation challenges the presumption in the NPPF that major development should be avoided in AONB unless there are exceptional circumstances.’ Nowhere in the inspector’s report are ‘exceptional circumstances’ at Vearse Farm specifically identified, demonstrated or explained. Claims of acceptability alone do not constitute the demonstration that NPPF 115 ‘public interest’ test requirements have been met. The inspector’s discussions focus entirely on the claimed acceptability of the development under various headings that might be considered after a requirement for exceptional circumstances have been met. It is not, for example, an exceptional circumstance under NPPF 115, that the development would provide for the town’s growth, or that adequate traffic arrangements could be provided (assuming that is indeed so) or that some level of landscape damage mitigation could be achieved. Instead, the inspector’s qualified support appears to be justified by the fact that most of West Dorset is AONB land and in order to meet government-set targets houses needs must be built there regardless. However, he also dismisses suggestions that the final planning decision be delayed until the forthcoming neighbourhood plan for Bridport could be used to examine alternative development options. His reasoning is that it may lead to the promotion of schemes in ‘locations where the individual and cumulative impact of development may be greater’. We submit, conversely, that this prevents the opportunity to identify schemes in locations where the individual and national cumulative impact of development may be far less harmful; contravenes NPPF paragraphs 115 and 116 and EIA Regulations; that the case officers’ report offers nothing to remedy the omissions in the inspector’s report; and that the WDDC planning committee failed to take any of this into consideration.

Nowhere in the planning or application documents relating to Vearse Farm can reference be found to the NPPF Paragraph 116 requirement of giving consideration to ‘the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way’. It seems that the ‘exceptional circumstances’ are no more than the circumstances surrounding WDDC’s difficulty in meeting the national requirement for the supply of housing land. The assumption is that, because this particular large site is available, the optimum and easiest course is to locate the entirety of a massive development in one area regardless of it being on one of the most landscape-sensitive edges of the town, providing one of the least adequate accesses to the town centre and to the major road network, or of it being the least strategic, relevant or acceptable housing-need solutions.

It remains, as indicated in the Kent judgment and in the ‘decision-taking’ section of NPPF paragraph 14, the ultimate duty of the planning committee to give full scrutiny to the significant detail and legalities of the location and planning application and to make the weight of public interest decision. Further, as also indicated in the Kent case, it is the duty of the planning committee to give due consideration to any local implications for future such permissions. We submit that granting permission on the grounds stated has both local and national implications because it effectively gives WDDC carte blanche to build on any of its AONB in order to meet national house-building targets and without the need to identify or stipulate ‘exceptional circumstances’, which thus completely cancels out the universal protections of AONB status altogether. The WDDC planning committee, therefore, has further been negligent in failing to acknowledge these compelling, material public interest reasons for refusing permission to build on this area of outstanding national importance.

That is precisely those circumstances under which the NPPF explicitly states that policies for the restriction of development should continue to be applied. We understand that there is currently a fundamental conflict between the seemingly undeliverable designations of national house-building targets and the protections of AONB land, but submit that, until this issue is resolved at national level, and while this anomaly opens up the potential for future disregard of the NPPF and promotes the dangerous, irreversible slippery slope negation of AONB status altogether, the weight of public interest lies much more heavily on the side of refusal in this case.

We would therefore be most grateful if you could call in this important, precedential case in order to give it the careful consideration it deserves.

Yours faithfully

Richard Freer
Co Chairman, ADVEARSE

Copied to: The Rt Hon Michael Gove MP, Secretary of State for Environment, Food and Rural Affairs.

My speech to last night’s Bridport Town Council meeting……….

“On behalf of the ADVEARSE campaign group I would formally like to thank Cllrs. Ros Kayes, David Rickard and Sarah Williams for their like-minded involvement in objecting to the Vearse Farm planning application at the recent meeting convened in Dorchester.

Interestingly, ADVEARSE have discovered that the decision has not quite been set in stone ! Accordingly, a communication with Jean Marshall from WDDC, has indicated that the planner, Hallam, has to enter into a S106 planning obligation. This typically could take at least two months. No planning Decision Certificate will be issued until this procedure is agreed and finalised. From that date, a period of six weeks then ensues whereby the generation of a Judicial Review objecting to the outline planning decision can be lodged.

We understand that the judicial review is a challenge to the process through the Courts and is not an “appeal” against the decision to the Secretary of State.

The Judicial Review’s implementation is currently being expeditiously assessed for viability by ADVEARSE.

Thank you
Richard Freer”

We received this from a cowardly troll called Diane Ronson this weekend.

She wrote……..

“well you lost, what a waste of time and money for stupid advearse you made. you might as well put for sale sign up and move out. And before I forget merry chrismas and happy new year ha ha ha !”

I had to laugh to myself, especially with the appalling spelling and grammar !!

As you will all recall, ADVEARSE gained funding from supportive like-minded people !

….and we’ve ONLY lost a battle, not the war !

Does anyone know who she is as she left no contact details (not surprisingly) so I can only presume she is perhaps a Bridport resident.

I did try a name search but only got one hit.

If anyone knows her please pass this on !

We would like clarify that we understand that the meeting is definitely on for the 3rd November !

We have also been emailed today with an invite to speak at the meeting !

See link….
http://moderngovdcp.dorsetforyou.gov.uk/ieListDocuments.aspx?CId=183&MId=802&Ver=4

It seems written in stone that Hallam will get their outline planning application accepted in WDDC October meeting. One by one the consultees that found good reason to object to this planning application have had their stings removed which is no great surprise as WDDC have said on many occassions that it is unthinkable that this building project will not go ahead. Even though this application is littered with discrepancies and faults the so called experts who probably in many cases live many miles away and who have not even visited the site have found Hallam’s ridiculous problem solving to be OK. So will the people of Bridport who know the town well or Organisations such as ADVEARSE who have a comprehensive dossier on the road and flooding issues be listened to, I very much doubt it. So with so much wrong with this development will WDDC back down ? On their past records I think not, only a legal challenge would stop their progress but they have the upper hand with thousands of pounds of public money to throw at this we as individuals have very little.. So unless there is some legal eagle out there who is willing to freely give his time and knowledge to this injustice of town planning I think Bridport should brace itself to the biggest disaster in its history.

There will be another meeting on Tuesday 20th June convened by Symondsbury Parish Council. This will be held at the Symondsbury Primary School, Symondsbury at 7pm.

It is essential that YOU please attend !

Many thanks in anticipation !

 

 

 

Bridport Town Council recently (13th June) rejected Hallam Land Group’s revised application on the potential development at Vearse Farm !

There will be another meeting on Tuesday 20th June convened by Symondsbury Parish Council. This will be held at the Symondsbury Primary School, Symondsbury at 7pm.

It is essential that YOU attend !

WEST DORSET DISTRICT COUNCIL Planning Department

Planning Application Ref: WD/D/17/000986 – VEARSE FARM BRIDPORT

 

COMMENTS BY

Gavin Fryer

The Sycamores, 85 West Allington, Bridport DT6 5BN

22 May 2017

 

[In this text § signifies a separate §ection of this Commentary]

 

• 1 Overall Commentary on the Proposed Development

1.1              I urge the rejection of this Planning Application for Outline Planning Permission on the following broad grounds:

• The scheme has serious underlying flaws;
• Were this proposal to be implemented, it would have a major and detrimental effect on Bridport and

its surrounding area; and

• Hallam’s have, until now, failed to address many of these issues in the Master Plan.

 

1.2 The scale and speed of the development

This housing development is a large addition to Bridport’s housing stock and potential population. I am not against growth of towns or, indeed, Bridport. I support the provision of low-cost housing in Bridport, that ought to carry a covenant that limits ownership to long-time residents of the Town, particularly younger people who have not previously owned any dwelling*.

The proposal to build 760 houses in a 10-year period on the outskirts of a town of 14,600 residents is excessive. The impact of this development and its size on the Town and its setting within the Area of Outstanding Natural Beauty (AONB) would be very considerable.

* Such a covenant would avoid multiple property ownership, even of another ‘low-cost’ dwelling.

 

• 2 The Inadequacy of the Master Plan – National Best Practice

The scheme woefully fails to meet national best practice in terms of Master Planning. Before Councillors consider this Application, they should study other Master Plan schemes. In broad terms Hallam have failed in many respects, described in these Sections:

• Overall Commentary on the Proposed Development; (§1 above)
• The Inadequacy of the Master Plan; (§2)
• Lack of Consultation; (§3 below)
• The local area and Bridport’s place in the AONB; (§4 below)
• The demand and proven need for 760 houses; (§5 below)
• Steps to deal with run-off flood water; (§6 below)
• Traffic on A35 and associated risks for residents in West Road / West Allington / B3162; (§7 below)
• Damage and significant risk to the health and well-being of residents of Bridport; (§8 below)
• Other specific issues; (§9 below) and
• Summary and Immediate Action. (§10 below)

 

• 3 Lack of consultation

3.1              For a scheme of this scale, evidence of far more meetings with local people would be expected. As a result, the issues identified as “Inadequacies” of the Master Plan that will have a negative impact on the Town as a whole have been superficially addressed. A particular example is the road junction where Magdalen Lane meets the B3162 and faces Allington Hill Road. This junction simply cannot cope with the considerable increase in traffic. (See §7.7 on Future Expectation)

When there was an opportunity early in New Year 2015 at Bridport Town Hall for members of the public to talk with representatives of Hallam and its advisers, it was evident that virtually no one had walked the roads and surrounds of the site or spoken to local residents. There has been little attempt in this Master Plan to address the issues of traffic in town, parking facilities or medical staff, services and facilities or local residents. The identification of a site for a school at Vearse Farm seems ironic because it would mean the closure of St Mary’s School; that school certainly does not wish to move.

Hallam’s desk-top generated plans for the site suggest that this work was largely done in a vacuum. The deliberations between Hallam and WDDC over at least a 6-year period appear not to have flagged-up the issues now brought to light.

Given the huge potential impact on Bridport, this seems somewhat astonishing.

 

3.2 15% increase in Bridport’s population at a stroke

WDDC state in the Local Plan: ‘The spectacular landscapes of West Dorset, from the panoramic chalk ridges to the wooded valleys and undeveloped coastline, the picturesque settlements and variety of natural habitats, are something that set it apart from the rest of the country. We are proud of this, and want to be able to say the same in 20 years’ time.’ (1.3 VISION AND OBJECTIVES – A VISION FOR WEST DORSET)

Comment:

Were the Vearse Farm development be allowed, that would be in direct conflict with this statement and would demonstrate a lack of consideration for the impact of the development on the character of the area.

It cannot be stressed often enough:

Vearse Farm and the 2000+ residents will have a dramatic effect on the town, adding nearly 15% to the existing population at a stroke. In practice, the other Planning Applications approved by WDDC from mid 2014 to early 2017 include another 62 dwellings, 3 flats and 26 apartments in Bridport that are likely to add more than 1%, to the town’s population. If two fields adjoining the East side of the Vearse Farm site, shown on one of the plans of the site as though for houses, albeit not part of this Application, are included the percentage addition to the Town’s population could be more.

The scale is excessive; when taken together, effectively this expansion would be decided on a single Planning Application, that is a single approval! The Application should be rejected.

 

• 4 The local area and Bridport’s place in the AONB: Inspector’s Report on the 2015 Local Plan

4.1 AONB and Agriculture

The proposed development is in an area of Outstanding Natural Beauty and good agricultural land lying in the alluvial valley of the River Simene, and it transgresses national and WDDC planning guidelines, particularly relating to flooding and to the protection of Areas of Outstanding Natural Beauty (AONB).

In approving the inclusion of Vearse Farm in the Local Plan the Inspector, Mr Crysell, justified it (para 177) by reference to ‘exceptional circumstances. He did not however spell out what these are.

I consider that these only make sense if Vearse Farm was an exceptionally good site for housing. (See below for my comment on Flooding risk and traffic loading.) There are considerable costs to be borne by one party or another to fund the extensive infrastructure works, so it is to be expected that the sale prices of the proposed houses will be well above the financial capability of local people.

By contrast, Vearse Farm was a key portion of the overall estate at Symondsbury of 3,900 acres that 200 years ago produced one quarter of the flax grown in Dorset. The farm has very good agricultural land to the south of the Symene River and all the way westward to Miles Cross that would have been classed as Grade 2 when those grades were in common parlance. Until 2003 Vearse Farm was renowned for the quality of Flax the Rope and Net industry on which the Town hitherto thrived.

There is no excuse, or valid ‘exceptional circumstance’, for removing these alluvial fields from Bridport’s stock of good agricultural land. Clearly these acres could still be producing more of the food eaten by residents of Bridport.

 

4.2 Wildlife Habitats

WDDC state in the Local Plan: ‘Internationally designated wildlife sites (…..), will be safeguarded from development that could adversely affect them, unless there are reasons of overriding public interest why the development should proceed and there is no alternative acceptable solution.’ (ENV2. WILDLIFE AND HABITATS (i))

Comment:

What can be the compelling arguments for disturbing the balance of wildlife habitats by proceeding with this Planning Application? The need for another 2,000 additional people in Bridport has not been justified in any documents presented to the public. Even so, the Town does not need so many houses the price of which would almost certainly dictate that they would be bought by ‘absentee landlords’, when the real and only justifiable need is for low-cost housing for the young people of the Town and those on low wages.

 

4.3 Protection and Enhancement of the Environment

WDDC state in the Local Plan: ‘Development should protect and enhance the natural environment – its landscape, seascapes and geological conservation interests, its wildlife and habitats and important local green spaces – by directing development away from sensitive areas that cannot accommodate change. Where development is needed and harm cannot be avoided, appropriate mitigation to off-set any adverse impact to the landscape, wildlife and green infrastructure network will be required.’ (STRATEGIC APPROACH)

Comment:

No information is provided in the supporting documents with this Planning Application that justifies such a development need.

 

4.4 Conservation, Listed Building and Landscapes

WDDC state in the Local Plan: ‘The councils will have special regard to the conservation of the area’s natural beauty in development management decisions. The cumulative and indirect, as well as the direct, impacts of development need to be taken into account, such as changes to drainage which could affect the landscape down stream. Effects of development outside, but affecting the AONB (within its “setting”), will also need to be carefully considered. National policy guidance gives great weight to conserving the landscape and scenic beauty of Areas of Outstanding Natural Beauty, and states that planning permission should be refused for major developments in these designated areas except in exceptional circumstances and where it can be demonstrated they are in the public interest. Consideration of such applications should include an assessment of:

• the need for the development, including in terms of any national considerations, and the impact of permitting it, or refusing it, upon the local economy;
• the cost of, and scope for, developing elsewhere outside the designated area, or meeting the need for it in some other way; and
• any detrimental effect on the environment, the landscape and recreational opportunities, and the extent to which that could be moderated.’

(2.2 PROTECTING AND ENHANCING OUR NATURAL ENVIRONMENT – LANDSCAPE AND SEASCAPE para 2.2.3)

Comment:

The farmhouse at Vearse Farm is a Grade 2 listed building. Why is development to be allowed near this building that would reduce its impact in the ‘green’ landscape? Surely this Application should not go ahead in its present form.

WDDC state in the Local Plan: ‘ii) Applications affecting the significance of a heritage asset or its setting will be required to provide sufficient information to demonstrate how the proposals would positively contribute to the asset’s conservation.’ (ENV4. HERITAGE ASSETS)

WDDC state in the Local Plan: ‘The plan area’s exceptional landscapes and seascapes and geological interest will be protected, taking into account the objectives of the Dorset AONB Management Plan and World Heritage Site Management Plan. Development which would harm the character, special qualities or natural beauty of the Dorset Area of Outstanding Beauty or Heritage Coast, including their characteristic landscape quality and diversity, uninterrupted panoramic views, individual landmarks, and sense of tranquillity and remoteness, will not be permitted.’ (ENV1. LANDSCAPE, SEASCAPE AND SITES OF GEOLOGICAL INTEREST (i))

Comment:

This application flies in the face of these direct ‘commands’ and should not be permitted. How can WDDC possibly approve this Application for Planning Permission.

The Application must be resisted.

 

• 5 The demand and proven need for 760 houses

5.1 Demand for 760 houses is not proven

760 houses represents an addition of say 2,000 people, nearly 15% to Bridport’s population.

The Report Set Up To Fail by the Council for the Protection of Rural England (CPRE) showed why housing targets based on flawed numbers are threatening our countryside. The Strategic Housing Market Assessment (SHMA) was studied by CPRE in 2015. This study showed that of 54 recent Local Plans examined, the average housing requirement was 30% above Government projections, in some cases up to 50% overstated.

CPRE has demonstrated that flawed national processes have distorted housing need figures, and that these figures are generally 35% higher than has been demonstrated to be the public need. However, there is demand for low-cost housing in Bridport – though not of the type or price that would be proposed for Vearse Farm (‘VF’). It is understood that a majority of the housing units on VF would be offered on the open market, at open-market prices. That does not satisfy the real local need (see 5.4 below).

The scheme does not reflect the interests of Bridport but rather the need of WDDC to deliver its hypothetical housing targets now shown to be greatly overstated.

 

5.2 The actual and pressing need for low-cost dwellings – Labour and Housing

WDDC state in the Local Plan: ‘West Dorset has many communities of different sizes, from the small, rural villages to the larger market towns. It is important to us that we have a thriving economy, decent affordable homes and a network of community facilities, so that local people of all ages and abilities can enjoy living here and playing an active part in their community.’ (1.3 VISION AND OBJECTIVES – A VISION FOR WEST DORSET)

Comment:

WDDC should not take steps that do not safeguard Bridport’s economy. Local businesses need younger people who can afford to live in this community to take responsibility for the sustaining such businesses and eventually take over management and direction of the businesses. Without low-cost housing how can a young person remain in the locality to be available for these roles. It is known that some younger people have, as a direct consequence, left Bridport to seek a dwelling at economical cost in the environs of Exeter.

These factors are also important to us, the residents.

 

5.3 Lack of Low-cost Housing

WDDC state in the Local Plan: ‘1.2.2 West Dorset is renowned for its outstanding environment, including a varied and beautiful landscape underpinned by great geodiversity which is expressed in the internationally recognised coastline, the Jurassic Coast World Heritage site, attractive villages and market towns. It has a range of cultural and historic associations, including those with Thomas Hardy’s novels, the Tolpuddle Martyrs and early discovery of fossils at Lyme Regis. Despite the high quality of life enjoyed by many in West Dorset there is a lack of affordable housing and some issues of rural isolation.’ (Paragraph 1.2.2)

Comment:

In the light of this statement in the Local Plan, what indeed is WDDC doing to help to deliver low-cost housing in the Bridport locality, making such dwellings available to young families and others, and those on the Housing Register.

 

5.4 Affordability of Low-cost housing

WDDC state in the Local Plan: ‘1.2.10 There is a high level of affordable housing need, with over 3,000 people on the housing register in West Dorset and 4,600 in Weymouth and Portland. The average house price outstrips local wages by a factor of 11 in Weymouth and Portland, and by a factor of 12 in West Dorset. More than 1 in every 20 homes in West Dorset is either a second or holiday home, and this proportion is especially acute in some coastal resorts. Increases in fuel prices will impact on local people, particularly those in older properties that have a poor energy performance rating.’ (AFFORDABILITY OF NEW HOUSING para 1.2.10)

Comment:

First, the term “affordable” in relation to a dwelling, in reality has no significant or comprehensible meaning. That would depend upon the subject’s means, since anything at a price can be afforded by someone. It is preferable to use the term “low-cost” in relation to housing, whether for outright purchase or for rental.

People who work in Bridport have incomes that in the lowest quartile that averaged £14,134 pa,; they need low-cost dwellings.

However, the houses planned for the VF site are likely to be priced over say £200,000 each; if 30% of such cost is intended to be the ‘affordable’ price for ownership ‘entry’, the likelihood of Bridport young people who earn c. £15,000 pa being able to service £60,000 is impossible. These people have to buy food every week and clothes from time to time, and pay the utilities.

On this basis the excessive number of houses the subject of this Planning Application means that it

should be rejected outright.

 

• 6 Steps to deal with run-off flood water

6.1 Risk of flooding from Surface Water flowing from VF Development

The Environment Agency have high profile concerns about the flood risk on the Vearse Farm site. Many of their concerns have yet to be satisfactorily dealt with.

I urge Councillors of WDDC to withhold permission until these have been addressed.

 

6.2              Hallam may say that there is little building in the areas most at risk of flooding. The concern shared by many in the town is not only about on-site flooding but equally the impact that the run-off will have in Bridport and West Bay. These have potential for damage and worse. Phrases such as ‘once in a 100 years’ provide little assurance to local residents who can vouch for the material floods that have occurred in the last five years.

6.3              The flood map from Environment Agency’s website dated 2014 shows four levels of flooding risk.

This likelihood of flooding from Surface Water in any given year may fall in one of the following four categories:

• ‘High’ means greater than or equal to 1 in 30 (>3.3%);
• ‘Medium’ means less than 1 in 30 (<3.3%) but greater than or equal to 1 in 100 (>1%);
• ‘Low’ means less than 1 in 100 (<1%) but greater than or equal to 1 in 1,000 (>0.1%);
• ‘Very Low’: means less than 1 in 1,000 (<0.1%).

These have happened both in winter and summer, and certainly twice if not three times in a single season. For Councillors who do not know the area it is worth pointing out that Bridport is well-known as a flood-prone district and is so close to the sea that if the sluice gates are shut by high tides at West Bay much wider areas of flooding will inevitably ensue.

The ratio ‘1 in 100’ is irrelevant in the context of Vearse Farm.

 

6.4 The proposed cycle route and flooding at Magdalen Bridge

Last autumn the emergency services (6 vehicles and 10 Officers) were called to rescue a man caught in flood water at the proposed cycle exit onto Magdalen Lane. Hallam are proposing a ramp for cyclists and pedestrians. This is an extremely foolhardy proposal and shows yet again the lack of research on the ground. An 8-foot wide track on a ramp would if wider be liable to block the way for floodwater to escape. Meanwhile, youngsters on cycles could easily cause difficulties for four-wheel electric chairs, parents with prams or pushchairs, or older adults walking on the ramp. A person walking with the aid of sticks would be at peril.

And, any movement here by cycles that incorporate any type of electric or petrol motor assistance or principal drive other than ‘pedal-power’ should be absolutely banned.

 

• 7 Traffic on A35 and associated risks for residents in West Road / West Allington / B3162

7.1 Impact on A35 – HIGHWAYS ENGLAND objections

At present, HE has recommended refusal because of their concerns about the impact on the Miles Cross Junction. The trunk road in this vicinity is one of the worst accident ‘blackspots’ in the country. In order to protect both local residents who use this junction and drivers from anywhere in this country, an effective solution has to be developed that will reduce the incidence of traffic accidents on the A35 approaching Miles Cross from west or east.

This has to be a full roundabout junction that would have the advantage of slowing the speeds at which the traffic travels. All 50 mph limits on the A35 to the east of Chideock and eastwards up the hill out of Bridport Town to the turning into Walditch should be removed in favour of no more than 40 mph limit. Too many really significant traffic accidents have taken place along this stretch of the A35 that it continues to be known as one of the worst “accident blackspots” in the country. See also comments below related to B3162.

The B3162 cannot be considered in isolation from A35 and traffic circulation around and within Bridport.

 

7.2 Impact of traffic on West Allington / West Road (B3162)

The by-pass was built to alleviate the traffic using West Allington / West Road. Vearse Farm will add many hundreds of journeys on to this road every day and return the local population to the traffic chaos that subsisted before the by-pass was opened, and worse. (See other points in this Section 7.)

 

7.3 Impact on the Town Centre of Bridport of Traffic Jams and lack of Parking

These are big issues:

1. a) the increased traffic will put the junction of West / East / South streets converging at the Town Hall above the capacity for manageability. WDDC and the County Authority should expect many more instances of stationary traffic than has been evident until now, as a result of the additional traffic generated by 2,000 people and their services of all kinds.
2. b) even more significant is the impact on car parking. The proposed development scheme makes no provision for extra car parking in the Town Centre. Reports in the local press document cases of visitors who came into the Bridport town centre and, finding they are unable to park, drive away. The lack of car parking will have a very negative effect on the economic well-being of Bridport, the markets and, at holiday times the aggregate visitor numbers.

A Park+Ride facility is needed in conjunction with a car park able to absorb, say, 2,000 private vehicles. Such a facility would facilitate the Town’s economy to expand and, in summer provide for a larger number of visitors. The A3066 road towards Beaminster is one of the best possible routes giving access in and out of the Town along a main road. If there were a dislike of building houses in the vicinity of the abattoir off Mangerton Lane on the way towards West Milton, this would be a most suitable location for such a Park+Ride facility.

 

7.4 Pavements along West Road – Legal threat to WDDC

The record of the problems that result from cyclists and pedestrians using West Allington / West Road demonstrates that the pavements are simply too narrow. Individuals have from time to time had their clothing caught on vehicles and been drawn into the roadway. Hallam say this road is about 7 m wide:

actually the width shrinks in several places and down to 6.2 m width;

           There are examples nationally where Councils have been sued as a result of giving planning permission in

similar circumstances when at a later date people have been injured in accidents.

Allowing for the proper clearance for cyclists when motorists pass, of 1.5 m., means that there is insufficient space for a car or larger vehicle to pass without facing oncoming vehicles. Veering to the left pavement in that circumstance, a vehicle is likely, sooner or later to cause an accident, even a fatality.

Dorset County Council Highways Department has also voiced its concerns about the impact of Vearse Farm on West Road, the western extension of B3162.     These factors alone dictate a comprehensive review of work done so far. The Master Plan is, thereby, shown to be no ‘Master’.

Before any deliberations take place by Councillors the traffic issues must be solved. Capacity for vehicles is quite inadequate, if a significant number of additional dwellings are added to the existing housing stock on either side of West Road / West Allington.

 

7.5 Traffic in West Allington and Traffic Speeds

West Allington is already overloaded with lorry traffic and passenger. Vehicles consistently travel well above the 30 mph limit, indeed the speed limit in this road ought to be 20 mph. I have advocated this.

7.6              The Inspector, in his report – para 176 – gave no inkling of the measures necessary to solve the traffic augmented by the VF scheme. At a meeting of the Symondsbury PCC in the summer of 2015 at which Hallam gave a presentation about VF, the representative of the Highway Authority who attended that meeting also had not visited the ground for any study but merely suggested that all that was necessary to control the increasing flow of traffic along West Allington, was to add an extra lane on the entry from North Allington at the roundabout at the west end of West Street.

Probably that additional lane would add to the congestion – not solve anything.

 

7.7 Future Expectation

It is believed that the ‘pinch-point’ close to the junction West Allington / Magdalen Lane / Allington Hill Road is to be made even more marked. It is bordered by Listed structures that cannot be taken away or altered. Currently, Day-care Centre vehicles and others have to collect and drop-off individuals who reside in three of the buildings on the opposite side to the Bridport Medical Centre. Those people are in particular need of care services. Consequently, there would be additional traffic jams at this point. If traffic speeds are also reduced, that would be welcomed. The capacity of the road in present conditions would be reduced.

In any case, a 20-mph limit along all of West Allington is needed because traffic that ought to be routed along the A35 by-pass travels on B3162, and frequently at speeds 40-50 mph, that sooner or later will cause a fatality (see 7.10 below).

This potential consequence must be addressed by WDDC in conjunction with Dorset County Council Roadways Department to safeguard residents and avoid so far as possible such an event taking place.

There is no excuse in current times for any plans to be drawn up including ‘fudges’ that are dressed up as solutions to potentially severe and persistent problems. The problems cannot be made to evaporate!

Safety and improved life-style of residents should be paramount; should override personal preferences.

 

Vehicle weight limits to be enforced by camera

7.8              The 7.5 ton weight limit for entry to the Town’s streets is regularly breached. On 26 March 2017 at c.13.00 hours, a 32-ton closed-lorry was followed being driven into East Street, straight through the Town and along West Allington / West Road. This sort of passage must be stopped !

It’s 4-times the specified weight limit.

 

Traffic on B3162 must be re-directed to the A35 Bypass

7.9              This is a B class road: the Bridport by-pass on the A35 was intended to take traffic away from this B road. West Allington is unsuitable for big vehicles and certainly for construction vehicles as it narrows at two points, has quite narrow pavements, is bounded by historic listed buildings, has the Bridport Medical Centre to which many people from all over the Town make visits, as well as Almshouses and homes for individuals with special needs. As many of these people walk to and from the Town centre, some along the narrow pavements, an accident is ‘waiting to happen’. Already people’s clothing has been caught up by passing heavy vehicles.

 

Recent near-fatality

7.10            An example of the risks recently observed in West Allington, in the week ending 6 May 2017 a driver of a private car coming from the Town centre, along West Allington, signalled to turn right into West Gables Close. Waiting to turn right, with a second vehicle behind, a third vehicle travelling from the Town did not pause, but passed at speed on the right off-side of both waiting cars, missing the first that had begun to turn by a hair’s-breadth. A fatality and write-off of three vehicles was avoided by only the slightest of margins.

 

• 8 Damage and significant risk to the health and well-being of residents of Bridport

8.1  WDDC state in the Local Plan: ‘High priority will be given to protecting and enhancing the area’s heritage assets – including its Listed Buildings and Conservation Areas, and other features with local historic or cultural associations, particularly where they contribute to the area’s local distinctiveness. Development will be directed away from areas where there is likely to be significant risk to human health or the wider environment, through flooding, coastal erosion and land instability, air and water pollution.’ (STRATEGIC APPROACH)

Comment:

Based upon National Planning Precepts, WDDC must give high priority to protection and enhancement of the area’s heritage assets, etc., particularly where they contribute to Bridport’s local distinctiveness. The ways in which that precept is being delivered by the local authority are not readily evident from the proposals for development of VF.

Furthermore, Hallam have seemingly totally ignored, and failed to measure, the damage and significant risk to the health of the residents of Bridport that would be imposed were this Planning Application to be permitted.

This Application should be resisted with vigour.

No account has been measured of the additional noise, pollution, vibration arising from the considerable addition to the traffic in the western portion of the Town area and to a proportional extent to other parts of the Town. These factors can only lead to an increased demand on medical services in the area as a result of polluted air that residents have every right to enjoy. All of this says little about how the area’s heritage assets would be protected.

Surely personal health of residents should be paramount in the Council’s considerations, per National Planning Precepts.

 

8.2 Safety of Residents

WDDC state in the Local Plan: ‘Development should be of high quality design to help achieve sustainable, safe and inclusive communities, enhancing quality of life for residents and visitors, and designed in keeping with or to positively contribute towards the local identity of the area.’ (STRATEGIC APPROACH)

Comment:

The safety of residents on the proposed site the subject of this Planning Application has not been adequately considered. Traffic risks that Hallam has barely touched upon and knows not how to deal with will inevitably increase should this Planning Application be allowed. It is totally unacceptable that this developer and the local authority having discussed this plan for six years and more, should present incomplete data and quite inadequate argument for exposing the public to specific risks that, through commentary submitted by members of the public on this Application, will be identified and will be evident to that Authority.

It needs pointing out that the word ‘should’ in this Strategic Approach is grossly unfair towards the Residents of Bridport. Why should the ‘Strategic Approach’ towards the safety and sustainability of the community in the Town be left to ‘best endeavours’ of the local authority, when the key role of that authority ought to be towards the quality of life and safety of its human constituents.

 

Such responsibility should rank above virtually all else that the Local and County Authorities do.

 

Adverse Impacts outweigh the Benefits

8.3  WDDC state in the Local Plan: ‘the following matters will be taken into account:

• the extent to which the proposal positively contributes to the strategic objectives of the local plan;
• whether specific policies in that National Planning Policy Framework indicate that development should be restricted; and
• whether the adverse impacts of granting permission could significantly outweigh the benefits.’

(INT1. PRESUMPTION IN FAVOUR OF SUSTAINABLE DEVELOPMENT)

Comment: This Commentary in §1 to §10 argues that, without doubt, the ‘adverse impacts’ consequent upon potential approval of this Application for Planning Permission certainly do outweigh the benefits.

       This Application should be rejected.

 

• 9 Other Specific Issues

9.1  Insurance of Private residences in Flood prone area

The flooding risks and recent frequency of instances may render it difficult for householders to obtain insurance at normal rates. Once insurers are made aware of frequency of flooding, insurance rates for properties on the site could well be raised such that some residents could no longer afford to remain living there.

Recent experience of irregular floods suggests that these insurance rates can only rise.

 

9.2 Bridges

Flooding that occurs regularly can cover up to 100 yards of the roadway from West Road up to the existing Vearse Farm. There will need to be a raised roadway on bridges to ensure access to the estates at times of flooding. The Master Plan document states that these can be agreed at the ‘reserved matters stage’.

For reasons set out in this Commentary, this is quite unacceptable. As photographs of the recurrent flooding would show, either an embanked road or extremely long bridges will be necessary extending over the 100 yards or more along the access road leading to the Farm which is regularly flooded.

 

9.3 School

The provision of a school site is a sop. St Mary’s School can be expanded to take the limited number of children coming from Vearse Farm. To close St Mary’s would disadvantage the families from other areas who currently use the school. Many of these parents walk with their children to the present school; it would be a much longer walk should the school be removed to the Vearse Farm site. Were such pedestrians be using the ramp proposed at Magdalen Bridge, at the same time as cyclists, one can envisage a danger spot being created there.

 

• 10 SUMMARY and IMMEDIATE ACTION

10.1            In view of the difficulties shown by this Commentary that patently were not brought to view owing to the methods used by the developer in drawing up the proposals for development at VF, the following actions should be taken urgently by all Councillors who become involved in assessment of the viability and relevance to the needs of Residents of Bridport:

 

• to undertake a Full Site Visit, not only of the Vearse Farm site, as such, but equally important the residential roads and streets around the site, before debating the application;
• to read up about the serious issues attached to this particular development; and
• defer all deliberations on this Application for Outline Planning Permission until the traffic issues are demonstrably solved.

 

10.2            WDDC is clearly feeling under short-term pressure to approve development of housing sites that add up to delivery of the Local Plan. Vearse Farm has serious difficulties associated with it. It is such a large development that, in its present form, it is simply not in the best interests of the local residents or of the Area of Outstanding Natural Beauty. Even if it was in those interests, which it is not, Hallam has failed to undertake the quality of detailed planning that should have addressed the many concerns.

 

Councillors may feel they have a short-term duty to deliver their quota of these fictitious housing targets. But that is over-ridden by their longer-term responsibility to look after the interests of their local communities.

 

Conclusion

For the reasons stated above, this massive scheme should be rejected, having regard to the huge detrimental effect it will have on Bridport’s locale in West Dorset, and the unsolved problems associated with it.

-end-

ADVEARSE has always viewed the decision about building on Vearse Farm as one of the most important decisions in Bridport’s history. We have campaigned for over 4 years to inform people about the development. We therefore would urge as many people as possible, whether for or against the scheme, to make their comments (follow the links on dorsetforyou.gov.uk). We believe in local democracy and it is important that the WDDC councillors have the fullest idea of what local people think.

We are pleased to see that the scheme includes a significant number of affordable houses – this is vital for the future of Bridport. We are intrigued to see yet more sweeteners – such as a ‘community food growing area and a community orchard in the flood zone ‘. Are they thinking we won’t notice they have also sneaked in over 760 houses?

Hallam claim to have addressed the fears about flooding and traffic. At present the experts at Highways England, Dorset County Council Highways team and Environment Agency all retain their objections to Vearse Farm. We believe that the Councillors will not be able to approve the scheme until these objections have been overcome.

The Vearse Farm development will result in hundreds additional vehicles per hour on West Road/Allington at peak times. We believe this will result in unacceptable levels of congestion and increased dangers for both cyclists and pedestrians along this narrow route.

Hallam claim to have produced a ‘Master Plan’ after ‘extensive work over the past 18 months’, ADVEARSE have researched the creation of Master Plans in other areas of the country and have to tell local people that the Hallam process falls way short of national best practice. As an example, we would cite the fact that nothing is being done about town centre parking which will be badly affected by the new houses. Lack of parking will severely discourage market visitors and holiday makers. One of our members contacted WDDC four weeks ago to ask what provision is to be made to increase the town’s parking capacity and who will pay for it; so far there has been no reply.

Our initial comments hold good. Incremental growth is healthy for towns – Vearse Farm is too many houses too fast; there is no local demand for so many houses and there are no exceptional reasons for building on good farm land in an area of outstanding natural beauty.

We will be using all means at our disposal to inform people about what is proposed and urging opposition to the scheme. We keen to hear from others who share our concerns Our website (http://www.advearse.org.uk/about-advearse/) gives more details and also advice about how you can donate to the campaign.

You can comment on……..

http://webapps.westdorset-weymouth.gov.uk/PlanningApps/Pages/Planning.aspx?App=WD/D/17/000986

 

 

Up to 186 new affordable rented homes could be built on the prop…osed Vearse Farm housing development. That is great news for those people in Bridport who are struggling to pay high private sector rents, many of whom are on low incomes. But exactly how affordable will these new homes be? Will they really solve Bridport’s affordable housing crisis?