Our 3,000 word submission to WDDC

WEST DORSET DISTRICT COUNCIL – LOCAL PLANNING – INSPECTORS HEARING NOVEMBER-DECEMBER 2014

SUBMISSION BY Barry Bates on behalf of ID 3517: ADVEARSE

 http://www.advearse.org.uk/about-advearse/

  1. FOCUS OF OUR SUBMISSION – VEARSE FARM

4.0 BRIDPORT ISSUES FOR THE HEARING

 

4.1 The issues identified by the Inspector for the Hearing are:

(i) Has adequate consideration been given to infrastructure requirements to service the development at Vearse Farm (BRID1) and how its impact on the AONB can be mitigated?

  1. CONTEXT

We have taken account of the National Planning Policy Framework and the West Dorset, Weymouth and Portland Infrastructure Delivery Plan. (Elsewhere we use the initials WDIDP to refer to this plan.) These need however to be applied to the context of the individual town and ‘its needs, size, and roles’

There are two issues about which any discussion about the infrastructure requirements of Vearse Farm must take account.

  • The town.  

a)      This is not a large scale development on a purpose designed site like Cranbrook at Exeter or the development taking place just outside Taunton. The latter can be accommodated into the infrastructure of a large county town with excellent motorway and train links, employment possibilities. Bridport is a small market town of 8,500 people whose infrastructure has developed over the centuries.

b)      It is further complicated by the fact that the summer holiday population puts massive pressure on the existing structure. Bridport simply cannot take the massive demands which an increase of an estimated 20% population from the extra 760 houses would create in such a small timescale. (We will use ‘760 houses’ in this submission although we know that there is no longer an upper limit.)

c)      The road networks in town are shaped by the river crossings which continue to impact on the infrastructure.

d)      We have recently initiated an on line petition which states ‘ we , the undersigned, call on West Dorset District Council to recognise the widespread opposition to the construction of 760+ houses at Vearse farm and to remove the proposal from the Local Plan. ‘The petition gives those signing the opportunity to comment. Most of the comments refer to the fact that this is development will overwhelm the current infrastructure of the town.

  • Current planning

In the recent past we might have put faith in what was known as ‘106 money ‘whereby the developers were forced to put money into schemes to improve the infrastructure as part of a major development. As we know from elsewhere in the country e.g. . Seaton in Devon that developers are increasingly finding ways of avoiding these obligations. Vearse Farm will have knock on effects to the infrastructure of the whole town. We have no confidence that sufficient funds will be made available to address the issues we highlight below. There is some expectation in the Local Plan that these can be addressed in collaboration with the developers. We know that this is naive. Vearse Farm is likely to be to the detriment of the town as a whole.

  1. HAS ADEQUATE CONSIDERATION BEEN GIVEN TO INFRASTRUCTURE REQUIREMENTS TO SERVICE THE DEVELOPMENT AT VEARSE FARM?

 

Our conclusion is that the Local Plan has highlighted a number of the key infrastructure requirements but there is inadequate detail as to whether and how these requirements can be adequately addressed. The WDIDP would indicate that no such detailed planning has occurred.

  • The challenges of Bridport

Bridport is 15 miles from the nearest railway. Bus services are being cut and this presents challenges for those who live in Bridport but who have to commute to their place of work.. Road access is difficult from the North and the one trunk road (the A35) running east to west is badly affected by holiday traffic and its accident record is horrendous.

It is unlikely that the local economy will provide jobs for those living in the 760 houses. The Local Plan fails to explain how the provision of houses will be matched by a provision of employment opportunities.

  • A general comment on the Infrastructure Delivery Plan

a)      The delivery plan is heavily concentrated on Weymouth and Dorchester. It would pay the reader of this submission to take a cursory glance at the Appendix 2. You would be hardly aware that a major development was taking place at Vearse Farm . References to Bridport are strong for cycleways even a skate park. The school investment is a merely the replacement for St Mary’s school. The current school is relatively modern and the replacement is based on housing issues rather than inadequacy of building.

b)      We will refer later to the inadequacy of references to the key issues of flooding and traffic management.

  • Flooding

Vearse Farm already floods. The River Simene has in the past 3 years flooded very quickly in periods of heavy rain. We have attached pictures in Appendix A .The run-off from the new houses will increase both the number of times the area floods and the severity of the flooding episodes. It will be argued that the developers will take measures to mitigate against this threat. To this point we would make the following comments

a)      THE NATIONAL PLANNING POLICY FRAMEWORK states

Inappropriate development in areas at risk of flooding should be avoided by directing development away from areas at highest risk, but where development is necessary, making it safe without increasing flood risk elsewhere.19 Local Plans should be supported by Strategic Flood Risk Assessment and develop policies to manage flood risk from all sources, taking account of advice from the Environment Agency and other relevant flood risk management bodies, such as lead local flood authorities and internal drainage boards.

The Framework also highlights the need to take account of climate change. 

b)      It could be argued that the water from Vearse Farm can be held in water            meadows beyond the development or in subterranean tanks on it.. In some areas of the country that might be true but immediately below Vearse Farm is the west side of Bridport and West Bay Road. Both areas suffered flood damage in each of the past 3 years. Vearse Farm is just 3 miles from the sea. At periods of high tide the sea gates are shut thus preventing the efficient draining of the River Brit especially in spate. As on the Somerset levels with the situation on the River Parrett there is simply no where for the water to go. Flooding is inevitable and this will affect the businesses which lie at risk.

c)      The dangers of flooding on this site are well known. We would expect that the Environment Agency be asked to produce a Strategic Flood Risk Assessment before any Local Plan condones the development at Vearse Farm.

d)      The WDIDP has a whole section on Flooding Risk – section 9. There is no reference to Bridport except 9.2.4 which talks about West Bay

e)      HOW CAN WDDC argue that ‘adequate consideration has been given to this key infrastructure issue and one which the NPPF would require it to address?

  • Traffic Management

a)      The current plan sees the main entrance to the development being on West Road. 760 houses plus the industrial units will create significant extra traffic. The bypass was constructed to alleviate the road from an inappropriate level of traffic. The West Road footpaths are narrow and are used to gain pedestrian access to the Medical Centre.

b)      Our conclusion is that the proposed service road has been wrongly located and designed.

c)      The traffic going out of town from Vearse Farm will spill onto the A35 at Miles Cross. The road is already frequently clogged with traffic in summer weekends. The additional traffic caused by the waste transfer station currently under construction will create further times of congestion. This will inevitably create a rat run through town, the Skilling residential estate and West Road. ( see previous note about river crossings) The Miles Cross junction is an accident black spot and major work there will be essential. This will add to the costs mentioned under flooding. National Trust landholding at Chideock would further inhibit the options for improving the traffic problems.

d)      The WDIDP

5.3.8 States ‘Traffic in Dorchester is now at the level experienced before the by-pass was  opened and residents and those visiting and working in the centre are, as a consequence, facing severance through high volumes of traffic. There are also difficulties for pedestrians at junctions and on narrow pavements due to the high traffic volumes in historic areas; as a result they are unable to enjoy the qualities and attributes of the central parts of the town. The situation is exacerbated on market days due to increased traffic and higher levels of pedestrian activity. ‘

These are precisely the points which could be made about the impact on Bridport. Yet by comparison the impact of Vearse Farm on Bridport is given short shrift .We quote…

5.3.2 In Bridport, junction improvements between West Road and the A35 at Miles Cross together with more localised traffic management in West Allington will be required as a result of development at Vearse Farm

WDDC has totally failed to recognise the major traffic issues involved here. No provision has been made in the planning. If significant investment is not identified at this stage it is unlikely that finances will be found once the inevitable crises occur. As now at Miles Cross we can anticipate the costs of lost lives on our roads.

  • Issues for the town  

It can be argued that a number of facilities required in the infrastructure will be strengthened by the additional housing – retail, arts venues, schools and the Leisure Centre. We note that these have been picked up in WDIDP .

In two respects we have major concerns. Car parking is already an issue in holiday periods and Saturdays . WDIDP makes no comment on these issues.

The Bridport Medical Centre appears to be running at capacity. WDIDP appears to confirm this – stating in 7.2.1 there is spare capacity for GP services in Lyme but shortfalls in provision elsewhere. Where is the provision for additional GP provision ?

Has any assessment been made of the school places required by 750 houses ?

The Town Council has itself expressed concern about whether a development of this size can be assimilated into the town in such a short timescale.

The West Dorset economy relies on tourism . Is West Dorset Council seriously planning to kill the golden egg by destroying the character of one of its key towns and choking its roads with overdevelopment ?

  • Employment

The Local Plan provides for a massive housing development but does not demonstrate where its residents will find work. Certainly there will be little in the town itself.

Q. What justification is there for the industrial land included for Vearse farm ?

 There are plenty of brown field sites within town. The Inspector will be aware of the long standing debate about the use of St Michael’s Estate. What justification can there be for forcing long established businesses to move ?

  1. INSPECTOR’S QUESTION PART 2   – HOW CAN ITS IMPACT ON THE AONB BE MITIGATED?

Our key question here is –‘If it is acknowledged that there is impact here on an area of outstanding natural beauty, why is it being selected in the first place?

  • We would point to the following phrases in the National Planning Policy Framework.

(Paragraph: 005 References ID: 8-005-20140306)

AONB

  • Planning permission should be refused for major development in a National Park, the Broads or an Area of Outstanding Natural Beauty except in exceptional circumstances and where it can be demonstrated to be in the public interest. Whether a proposed development in these designated areas should be treated as a major development, to which the policy in paragraph 116 of the Framework applies, will be a matter for the relevant decision taker, taking into account the proposal in question and the local context.  The Framework is clear that great weight should be given to conserving landscape and scenic beauty in these designated areas irrespective of whether the policy in paragraph 116 is applicable.
  • Vearse Farm occupies a piece of land highly visible to those passing through Bridport. It is also visible from the neighbouring AONB hills and country side. We would urge the Inspector to undertake a site visit. It is highly unlikely that any measures would adequately mitigate against the AONB loss.
  • It is further more on one of England’s outstanding pieces of Heritage Coast – The Jurassic Coast.

Again we quote from the NPPF

  • Local planning authorities should maintain the character of the undeveloped coast, protecting and enhancing its distinctive landscapes, particularly in areas defined as Heritage Coast, and improve public access to and enjoyment of the coast. Heritage Coasts are stretches of our most beautiful, undeveloped coastline which are managed to conserve their natural beauty and, where appropriate, to improve accessibility for visitors.  Most of the defined Heritage Coast is covered (on land) by either Area of Outstanding Natural Beauty or National Park designations.  Natural England has published advice on Heritage Coasts
  • In this section we would point out that the proposed development will take place on good quality farm land. Ministers such as Eric Pickles have stressed the need to use brown field sites first.

Q. Can WDDC produce a compelling argument to build on this green field site? It is simply a highly convenient place to place 760 houses with compliant landowners and the support of speculative builders.

5. CLOSING STATEMENT

We have set out to answer the questions posed by the Inspector but would wish to close with the following statement and questions

a)      Sustainable development

The government has a presumption in favour of ‘sustainable development’. West Dorset District Council has set out its strategic approach to the achievement of sustainable development . In summary it states

In the period 2011-2028, development should help deliver a steady supply of employment and housing land to meet the objectively assessed needs (about 60ha of employment land and about 13,175 new homes across the plan area). The distribution of development will be influenced by: – the needs, size, and roles of the area’s settlements, taking into account any current imbalances of housing or jobs

– the benefits of concentrating most development in locations where homes, jobs and facilities will be easily accessible to each other and there is a choice of transport modes,

– the availability of land, and whether it has been previously developed (brownfield); and

– the environmental constraints of the plan area,

 

Question One Who can argue other than WDDC has failed to reflect these key influences in the proposals in its Local Plan for Bridport ?

b)      Housing demand

We accept the national need for a house building programme. We accept the need for sustainable development in Bridport most especially the provision of affordable houses for local people.

 

The NPPF states that Local Plans should meet an ‘objectively assessed need ‘. We remain adamant that there is no need for such a large development in Bridport. Dorset County Council Research Matters August 2013 gives details of population growth in Dorset as themed year estimates. Overall growth was up just 0.4 % with the majority in the Bournemouth area.

The town has been given this allocation by national and West Dorset politicians to meet their own targets encouraged by speculative builders. It would seem that West Dorset District Council has heeded protests about housing development in other areas such as Dorchester, Sherborne and Crossways. These have carried more weight than their duty to protect the AONB which Bridport is part of and surrounded by.

Questions two and three

  • Surely such protests should not be used as the ‘exceptional circumstance ‘for allowing major development within the AONB? Can WDDC set out the reasons why this is an exceptional circumstance?

       

  • In what way has WDDC demonstrated the need for such a large housing development

c)      An inappropriate scale of development for the town as a whole

The scale of the development is wholly inappropriate for a town of the size and location of Bridport. (To quote WDDC ‘the needs, size and roles of the town) We have seen no convincing argument why Bridport should be expected to accept this allocation. Finally the chosen site Vearse Farm seems wholly inappropriate for the reasons we have outlined.

d)     Vearse Farm is an inappropriate site

This submission has argued that in 3 major respects the proposed site contravenes national and local planning guidelines

  • Risk of flooding
  • Traffic management
  • AONB and environmental /agricultural issues

e)      Consultation

Our recent work on the petition has confirmed two key points .Firstly although West Dorset District Council carried out a consultation process, local people do not feel either consulted or informed about the development. Concerns about the consultation process are shared by the Bridport Town Council. Secondly our opposition to the scheme is shared by many others.

We urge the Inspector to find the part of the Local Plan relating to Bridport as a whole and Vearse Farm in particular ‘unsound’.

Barry Bates 30 October 2014

ADVEARSE APPENDIX A –

Flooding at Vearse Farm

ADVEARSE APPENDIX A

Site for Vearse Housing

 

ADVEARSE APPENDIX ADistant view from Vearse Farm

 

 

 

 

 

3,000 word document sent to WDDC

A 3,000 word document has been sent to WDDC indicating our objection to the development at Vearse Farm.

This precedes the meeting with the Inspector at South Parks House , Dorchester on 4th December at 10.00.

If you would like to attend as an audience member, please register with Christine Self on [email protected]

WEST DORSET, WEYMOUTH & PORTLAND LOCAL PLAN EXAMINATION

NOTICE

The Hearings relating to the West Dorset, Weymouth & Portland Local Plan Examination are due to commence on Tuesday 25th November and will last for three weeks. 

The Hearings will take place in Committee Rooms A & B, West Dorset District Council Offices, South Walks House, South Walks Road, Dorchester, Dorset, DT1 1UZ

The sitting times are Tuesday to Thursday from 10am-1pm and from 2pm-5pm and on Friday from 10am to 1pm.

Details of the Draft Programme showing the Matters and Issues identified for discussion by the Inspector and Guidance Notes explaining the Examination process are available to download online at Draft Examination Programme   in…….https://www.dorsetforyou.com/localplanexamination/west/weymouth.

Cllr. David Tett writes in support of ADVEARSE !

“The public examination gets underway on the 25th November.  The Petition of Advearse sets out the concerns and fears of many townspeople and others with regard to the potential development of a vast number of homes at Vearse Farm, concerns and fears which I share.

We are all too aware of the floods in the recent past and, coupled with the pending development of the Waste Transfer station at Broomhills, will only put even more pressure on the inadequate road structure.

Moreover, it is Central Government policy not to build on green land but to concentrate on brown land sites”.

Facebook letter from a prospective new resident !

From Chloe “Branny”Branwhite on Bridport N0tice page
As a young person hoping to move to the area, what worries me about the Vearse Farm development is that it will make Bridport something of a mini-version of where I currently live (east London) and spoil some of the very reasons I’m moving to the town. I don’t claim to be an expert on the situation in Bridport – far from it – but I have been a regular visitor for fifteen years now. I don’t disagree that there is a need for social housing (just as there is in my local area) – certainly if I was moving to Bridport on my own – well, frankly I couldn’t afford to. But need the development be so *big*? Especially when a lot of the houses aren’t even going to be “for the locals” as such. I have read somewhere that they will be for “economic migrants”, which doesn’t sound very local to me. Will there be enough jobs for these people (I am expecting to commute) or the infrastructure to support such a large influx of people? Are there enough school places for their children or places where those same children can go after school? There is currently an average three week wait where I live to see a GP – while I doubt the Medical Centre could get that bad, are the people of Bridport prepared for potentially waiting longer to see a doctor, or a dentist? Instead of a rush hour, are you prepared for a rush two, three or even four hours because of the inevitable increase in traffic? What about those who rely on the bus to get around (such as myself), will there be enough room for them to get on and get to work on time where they do find employment? Yes, the development will probably bring some short-term employment while is being built and yes, local businesses will probably benefit from potentially 1500+ plus regular customers once the houses are occupied. But would it really be worth it to build quite so many, when there is no guarantee that they simply won’t become more holiday and/or retirement properties, with few or none for the local people who really need them? By all means, build some houses (though I hear the proposed site is a floodplain, so its maybe not the greatest place). But eight hundred is, in the opinion of this grockle, far too many.

Signatures hit 1,250+ !

A successful morning in Bucky Doo Square, Bridport was experienced by ADVEARSE members, on Saturday 25th October. The two combined petitions now currently total 1,290 signatures, opposing the housing development at Vearse Farm, West Road, Bridport ! More signatures are still expected to be submitted.

Thank you to all the local residents and visitors to the Town, who kindly signed our petition !

If you have missed today’s opportunity to sign up, please go to our electronic petition on …..

https://you.38degrees.org.uk/petitions/stop-vearse-farm

West Dorset District Council – Local Plan – Response to Further Consultation by ADVEARSE

[email protected]

  1. CONSULTATION
    • ADVEARSE is grateful for the opportunity to respond to this further consultation. As we have stated to the Council before the decision to confine comments to changes to the plan is flawed and undemocratic.
    • Over the past year we have attended many meetings and been contacted by many people. Many people in Bridport including Town Councillors who made the point on record at a public meeting believe that the initial consultation was a charade. Bridport feels that it was not fully consulted about the original proposals.
    • We would urge you to accept comments which are wider than those based on the changes. We therefore ask that you confirm that this submission has been accepted.

     

  2. COMMENTS ON THE STRATEGIC HOUSING MARKET REPORT BY PETER BRETT
    • After the dire performance of your previous consultant at the Inspectors initial hearing we are not surprised that you brought in a different set of consultants. They are building on previous work and it is revealing to note that many of these were found to be inadequate. There are so many variables which can change we have little faith in the revised figure of 775.
    • This is a thorough document, with on the surface of it, an impressive set of statistics. It certainly tries to challenge previous assumptions. At the end of the day it is however only producing policy driven evidence. We see no evidence in your revised submission to the Inspector that you have used both the Brett report and the delay in the Inspector’s consideration to revisit the fundamentals of the WDDC policy regarding the construction of this plan.
    • We note that the report states that (within constraints) Local Authorities can now set their own targets. Where is the evidence that you have actually engaged with this opportunity with for example the Bridport Town Council?
    • The fact the report covers the wider area including Weymouth and Portland is encouraging in that the housing demand can be seen in a wider context and spread where it is actually needed.
    • The report does however show a number of factors which would question the numbers proposed for housing. Firstly the impact of migration – By our own experience we know that if you build houses in West Dorset people from outside will buy them. That does not however mean that these were actually needed. It certainly will not fulfil the requirement to meet LOCAL housing need. Secondly – the completion figures are consistently below target. (6.26)

     

  3. Finally the report is focussed on housing, population, creation of households. It cannot be criticised for that since it is a report on Housing Market need. However, these issues need to be fed into all the other factors – employment, environment; transport…WDDC has never adequately addressed these. Other Local Authorities such as the South Hams have chosen to be more robust in taking all these factors into account. As a result the character of the area is being preserved from the ravages of over development.
     
  4. CHAPTER 3 – SUSTAINABLE PATTERN OF DEVELOPMENT ONLY
    • Having listened to the Inspectors criticisms of the Plan we are surprised that the changes you propose are so minimal.
    • In what way is this ‘sustainable pattern of development’?
    • As indicated in the last section we do not see how you can justify the increased figure of 775 other than an attempt to mollify the Inspector.
    • FPC3 – where will these jobs actually come from? If you are accepting a more modest target for job growth who will actually buy the houses? In what way will this distorted housing market create a balanced demographic?
    • FPC5 / FPC6 /FPC7 – Tinkering with the figures is largely irrelevant.
    • Where is the analysis of affordable? The real need for housing exists on the housing lists – affordable housing for local people. Nationally there are many examples where builders are avoiding their obligations to provide affordable housing. Where is there any discussion of this critical issue in your consultations?

     

  5. OVERALL COMMENTS
    • As Peter Brett’s report shows predictions of future growth be it population, housing need and the like are always imprecise and theoretical. Unfortunately they translate into specific proposals. In the case of West Dorset they are used to justify a massive development at Vearse Farm
    • WDDC has failed to take the opportunity of the delay to rethink the flawed Local Plan. For Bridport the plan proposes a development of a massive scale on a site which has many problems not least the impact of flooding and traffic management. Do we really wish to see the creeping suburbanisation of East Dorset here?
    • The Plan remains unsound on many levels. The veneer of statistical objectivity which has been used to tinker with the housing projections leaves the Plan as a whole inadequate for the future of West Dorset. The people have a right to expect more from those charged with taking a long term view.

ADVEARSE Steering Group – Summary of Meeting – 29 May 2014

Key outcomes

  1. New members- We agreed to invite 2 new members to join the group.
  2. We discussed the news that the Highways Agency have expressed increased concern about traffic issues particularly at Miles Cross. We agreed to contact the Agency to get a detailed briefing .
  3. We noted the outcome of the new consultant report on housing need in West Dorset and the fact that WDDC ‘s Local Plan is likely to be re-presented to the Inspector shortly. We agreed to be fully involved in the Inspection hearings.
  4. We agreed that our main focus should be the Neighbourhood Plan . We will aim to be involved in the process and the referendum which is required for its adoption. We considered tactics we might deploy should Vearse Farm be included.
  5. Website – 600 plus hits so far.
  6. Next meeting June 25

Campaign Site