Parcel 4234, Combe Hay Lane, Combe Hay, Bath
The Trust’s Architecture & Planning Committee commends the applicant on presenting a very detailed planning application. However, we are objecting to this application on the basis that a key criterion of Policy B3a – the comprehensive masterplan - has not been fulfilled, and therefore the scheme is contrary to the strategic placemaking principles allocated with the site. We will expand on these concerns later in this response.
In terms of the application for the Phase 1 area, we find some areas of the scheme to be worthy of support, and we acknowledge and commend the clear ambition to create a very high quality development where the applicant has examined in exemplary fashion and detail the matters of design and public realm. However the ecology and landscape mitigation proposals are ‘illustrative’ and therefore cannot carry planning weight for this or a future phase. In particular we are supportive of the overall Garden Suburb design ethos and the 40% affordable housing provision within a relatively varied unit mix (though we note the absence of larger affordable houses and would suggest that an 'in perpetuity' clause should be considered). We are concerned about the lack of sustainability objectives and an excessive provision for cars, at a time when car usage in town centres is to be discouraged.
In our detailed response to the pre-application consultation in November 2016, we outlined our concerns regarding the lack of a comprehensive masterplan as established in B3a (2). This concern centres on the uncertainty that the lack of an overall site masterplan engenders, and the possible future incremental ‘boundary creep’ and over-development that could occur as the planning system and the priorities of the B&NES/West of England authorities change and develop over time so that subsequent phases could undergo different levels of scrutiny in an as yet unknown policy environment. The legal opinion submitted by the developers to B&NES regarding the comprehensive masterplan issue and the ‘risk of pre-determination’ (should the scheme be reviewed by DMC as per Policy B3a) makes clear that the masterplan should be considered as part of a planning application not as a stand-alone item by DMC. Therefore we recommend that, in order to comply with B3a, the overall masterplan should be considered as an outline application with detailed phases coming forward as reserved matters applications.
The Illustrative Comprehensive Masterplan (ICM) document outlines the masterplan principles for the site that are ‘intended to inform all later stages of the scheme’. Yet the ICM does not comment on the general extent of built development, massing, density and height of buildings; these are key issues that would be expected to be included in a comprehensive plan, because these matters control the quantum as well as quality of development. In addition key infrastructure is not being forward planned, this includes green recreation space and site/surroundings connectivity but also crucially local services for residents such as a food store and community places. This leaves the Phase 1 scheme isolated, without an assured future as part of a planned and integrated community with adequate local services.
The key issue here is that the ICM is an illustrative document only, as are the Wansdyke Management Plan, the Landscape & Ecological Mitigation Strategy & LEMP and the Recreation Strategy; they are not part of the planning application, despite the detail of the LEMP. It is surprising that such an approach has been adopted by HFT and Bloor given the clear desire to create an exemplar development, as evidenced in the quality of the site and building plans; this level of quality and the underlying garden suburb ethos of the scheme could well be diluted or distorted in subsequent phases as there is no future certainty supplied by a detailed masterplan that could act as a set of ‘design codes’ for the rest of the development and also ensure continuity of the relatively low density on which a garden suburb character is contingent upon and which is largely achieved with this phase.
A key concern connected to the lack of a masterplan establishing the quantum of development is that, with the proposed numbers of dwellings in Phase 1, the entire site could see housing numbers close to 500. Whilst we are not Highways experts, we understand that a single access road, accessed from a local distributor road (in this case Combe Hay Lane), should not serve more than around 300 houses, in order to avoid over-provision and congestion pressure on the local distributor road. Logically this means that in later stages there is a possibility of a second access road being proposed eastward to South Stoke Lane (despite this being explicitly contrary to the provisions of B3a) together with the associated threat of further development being proposed outside the area established in B3a; in other words, incremental creeping urbanisation of the plateau. The wording of B3a was specifically designed to prevent both creeping urbanisation and creating an unrealistic traffic burden which would necessitate an eastern road, so the absence of a masterplan is presumably because the developers do not wish to propose a masterplan which would actually comply with B3A.
In addition, we question the proposal to furnish up to 4 parking spaces for the larger houses, which we regard as vastly excessive and contrary to sustainability principles. We would prefer to see a maximum of 2 spaces (including electric charge points). The focus on parking has also compromised the garden suburb spirit in relation to green frontages. We also question the apparent lack of adequate connectivity between the new estate and its neighbour to the north or of any explicit social meeting point within the site are, especially bearing in mind the policy 3A requirement for ensuring that it is well integrated with neighbouring areas.
There is a natural conflict identified in the ICM with landscape principles proposing the creation of vistas through existing woodland towards the AONB, whilst the heritage principles emphasise enclosure of the site to avoid views into the site and light spillage that could harm the special character of the green wooded ridge. Open paths and vistas across the shelter belt are not supported by the Trust as these would provide glimpses of built development from open countryside; they would therefore harm the valued character of the ridge. Paths through the shelter belt should be dog-legged to protect views into the site. We note the LVIA’s photomontages supplied in the Appendix to the Environmental Impact Assessment but question why all the LVIA viewpoints of the proposed development are located very far from the ridge with none giving closer views of the built development from vantage points across the South Stoke valley such as the PROW south of South Stoke towards the Somersetshire Coal Canal and viewpoints near the Cam Brook or from Combe Hay and Combe Hay Lane its winds down into the valley.
Whilst the heights of the larger buildings appear acceptable at 2.5 storeys, their position at the South Stoke ridgeline and at the back of the site on higher ground risks their visibility in longer views and we hope this will be sufficiently tested in the LVIA’s. This approach appears contrary to B3a (Section 5 – paras on WHS).
In our view there is too little proposed tree planting along existing boundary woodland belts. We would expect to have seen planting plans and landscape softworks specifications detailed as part of the planning application, rather than contained in illustrative drawings/documents and left to condition. We welcome the extra planting proposed for the southern belt of Derrymans, but would voice concerns over the use of this field for allotments and play areas, which of themselves are possibly acceptable but which run the risk of becoming incrementally developed with ad hoc associated structures and parking which may affect the openness of the Green Belt; perhaps planning provisions can be put in place in the decision notice to safeguard this predominantly green space. Ideally play space should be accommodated within the housing site and not tacked on in the Green Belt to release space for more housing. A proper comprehensive masterplan would allow for the provision of play space to be accommodated elsewhere within the overall site as could an uplift in the green infrastructure noted above.
Over the past two years, the Trust has continually voiced concerns over the HFT/Bloor departure from the key requirement in B3a, viz. to provide a comprehensive masterplan for this development in order to avoid uncertainty and inconsistencies regarding the later phases. We think that the quality and success of this scheme could be severely compromised by the lack of clarity and certainty regarding the quantum and indeed quality of development and its associated infrastructure in later phases, given that the illustrative masterplan and associated landscape and ecology documents hold no weight in planning terms and in any case do not examine the amount of development – that great ‘elephant in the room’ which no one appears to want to deal with.
We have noted the legal advice submitted as part of the application which in our view reinforces our position as it states that the local authority should not consider a masterplan PRIOR to a planning application (to avoid pre-determination) but states absolutely clearly that ‘the requirement to produce a Comprehensive Masterplan should only be discharged through the submission of the required masterplan as part of an appropriately supported planning application’. In turn this suggests that in order to discharge the requirement there SHOULD be a comprehensive masterplan as part of any substantive planning application. In our view, an outline masterplan application for the entire site (including the Business Village) should be submitted, treating Sulis Manor notionally as it is not under the applicants' control, although it is clearly a crucial part of the overall site. Once the overall masterplan is consulted upon and agreed, this could be followed closely by a Phase 1 reserved matters application. We therefore object to this application on the basis that it is contrary to the local development plan, namely Policy B3a of the Core Strategy.