Bridgwater & District Civic Society
Planning Representation
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09//08/0017 NE Bridgwater Little Sydenham Farm Outline Application
I refer you to our the Civic Society's representations of 15 March in respect of this application and which may be found at here, and to which this further representation has been added.
The Civic Society has considered the new information provided by the applicant and now responds additionally for your consideration.
The Society has been unable to read certain detail on sundry digitised plans (for example, Illuminance Diagrams) even with sophisticated software and hardware, so has been restricted in accessibility, thereby preventing comment within the timescale allowed.
A1. Contaminated Land
The Society is concerned to read of the extent and nature of the contamination spread thoughout the development site that has been revealed by the additional investigations and further analysis.
On the basis of the new information, the Society raises OBJECTION to the proposals on the grounds that the requirements of Planning Policies PCS16 have not been met, and that to grant permission for the application might endanger public health.
The Society continues to recommend that further expert independent advice is sought before a decision is attempted.
A2. Alternative Energy
The Society notes that the proposal for a wind turbine has been withdrawn, but regrets that little firm proposals and analysis of other Green Energy options has been pursued. Please note the last sentence of paragraph 6 of 15th March.
A3. Access & Transportation
The Society expects the Planning Authority to insist, by condition, that the full Access Infrastructure is completed before any element of the development is occupied.
The Transport Issues paper of 12 August proposes sets of traffic lights at Cross Rifles and elsewhere. This seems to represent an ill-considered approach which has been shown to be ineffective in certain countries in Europe. There, traffic lights are being removed resulting in better traffic flow. The Society does not support the piecemeal ad hoc approach to traffic management proposed by the applicants and the Somerset County Council Highways Department.
The Society asks you to note that the proposed roundabout at Crandon Bridge (Silver Fish) is
likely to be underlain by significant archaeology, and that SCC should ensure that an
archaeological watching brief is maintained.
1. General and Summary
The Society welcomes the initiatives contained within this application for redevelopment and renewal of a large part of this former industrial site.
Whilst it recognises that this is an outline application, the Society asks that the Local Planning Authority should pay particular attention to setting appropriate planning conditions that will ensure that
The Society notes that some supporting information lacks rigour and scientific depth. It is admitted in some reports within the application that the material has been assembled in haste. This is apparent when the reports are studied closely. The Society is of the opinion that the LPA needs to obtain further information and professional opinions on several technical aspects before a valid determination can be made.
The Society notes with concern the potentially fatal risks and unknown distribution of hot spots associated with TPH contamination as reported in the Geo-Environmental Appraisal, paras 10.4 -10.9.
The Society recommends that an independent evaluation is obtained by the LPA to assess the full scale of the level of contamination within the site rather than relying solely upon the applicants' before a planning determination is made.
2. Design
The Society supports the principles within the Design & Access Statement which subscribe to the need for best quality contemporary design. It hopes that there will be scope provided in detailed consent for truly innovative design using 21st century materials. The Society endorses the principles within the Design & Access Statement which subscribe to the need for best quality contemporary design. The Society encourages the LPA to ensure that fine and exciting structures are built which incorporate leading-edge modern materials and highest quality design.
The Society welcomes the acknowledgement on page 56 that "Whereas the development does not advocate pastiche or historic solutions, it is important that the new development has some obvious connection with local character" . The Society does not support pastiche solutions. Where the vernacular is to be emulated, the Society suggests that the LPA should take care to stipulate the need to employ some materials which sensitively reflect aspects of the vernacular.
Examples which might be adopted for vernacular emulation include
3. Enhancement of the Historic Environment and Landscape
The Society is pleased to note that assessments have been submitted within the Environmental Statement and elsewhere.
The Society welcomes the applicant's anticipation (5.2.4) of the requirement for an Archaeological Condition, and fully support the need for this to apply to the whole development site. The society therefore supports the proposals for planning conditions suggested at 10.77 & 10.78
The Society notes that the Desk-based Assessment has omitted to make reference to several published documentary references to the mediaeval settlements within the area, including that at Horsey. It is therefore likely that the site is of higher archaeological potential than is suggested by the DBA.
The Society has studied the Assessment of the Setting and Impacts on Designated and Registered Historic Assets Report, Appendix 10 S.3. It notes note that the analysis has been "swift". The Society questions the validity of some of the methodology. It considers that the large number of "negligible" (neutral in the Tabular Matrix Table 4) outcomes are biased in favour of the development. It is surprising that there has been no consideration of additive effects of negligible and slight outcomes in respect of the overall setting. Further work should be undertaken which will refine the data and assessment of the impact of the proposed development on the setting, and to including the more quantitative detail of the likely impact of the Wind Turbine on this setting.
The Society wishes there to be a management plan required by planning condition which will ensure the enhancement and preservation of the setting of Sydenham Manor House.
4. Access, Transportation & Noise
The Society recognises that a development of this size will place additional burdens upon transport links.
It considers that the applicants have made insufficient provision for future peak road traffic flows along the A39 Bath Road. There is little evidence of coherent planning of road infrastructure to take account of nearby additional developments such as the new hospital and expansion at Bridgwater College. The proposed junction with the Bath Road is likely to cause traffic management difficulties at the Silver Fish/Crandon Bridge junction at Bawdrip.
The Society believes that the anticipated peak flow data for the A38 Bristol Road has been significantly underestimated. The proposed junctions may result in queuing back to the motorway junction. The Society anticipates that the development will impede access to the town of Bridgwater from both A38 and A39 at the confluence of the two at the Cannon Interchange, however it is modified. Traffic should not be routed through housing areas.
The Society recommends that consideration is given to creating a limited access junction with the M5 at the A39 overbridge and invites the LPA to apply a condition to that effect.
The Society is dismayed to note that no provision has been made to ensure that rail siding corridors have not been retained to the development. The Society notes that Tesco makes extensive use of road/rail services, and anticipates that Wm Morrison or successors may adapt company policy to favour more energy efficient transport and distribution.
The Society recommends that a planning condition is made which ensures that potential rail connected corridors are retained or newly provided within the development site in the interests of future sustainable transport. Provision should also be made to allow (or not to impede) a future additional unstaffed peak time passenger railway station adjacent to the development.
The Society notes the application must demonstrate that it has met the requirements of PPG24. Having examined Appendix 14, the Society questions the validity of the methodology and sampling of the method. There is little evidence of sufficient data having been gathered over a sufficient period to represent seasonal variations (measurements are reported for October 2008, and legacy values from December 2005 are given without qualification). Local residents are aware of considerable seasonal variations in perceptible noise, and diurnal variations are significantly dependent on climatic conditions and cloud cover. The Society notes that some noise levels are declared at NEC level C even from the limited data gathered. It is likely that true levels are already higher and unacceptable.
The Society recommends that the LPA seeks a further assessment of noise level impact based upon gathered data which properly represents the seasonal variations.
The Society considers that the proposed noise reduction screens will be an unacceptable intrusion into the historic landscape and setting of historic buildings.
5. Microgeneration and Alternative Energy
The Society welcomes initiatives that will result in lower consumption of energy overall and an increase in the proportion of energy converted from renewable reserves.
This application does not demonstrate that the full range of renewable energy resources has been considered adequately. The reasons given for rejection of certain strategies seem biased towards favouring lower cost single solutions such as a wind turbine. Biomass digesters could be more efficient and less visually dominating. Biomass fuel combustion plants may rise to significant pollution and a public enquiry rejected an application for a plant at Express Park. The Society would wish to contribute to a Public Enquiry should one be called.
The Society recommends that the LPA seeks further detail from the applicant in respect of Green Energy options.
The Society does not object to the use of wind turbines. It does oppose the construction of the wind turbine at the suggested site on the grounds of interference with visual amenity, unacceptable destruction of the historic landscape (especially the mediaeval village of Horsey) noise and as a distraction to motor traffic.
A planning condition should be made to ensure that individual dwellings embody an element of microgeneration within their construction type.
6. Section 106 Agreement & Provisions for Public Facilities
The Society encourages the LPA and the Applicant to secure a section 106 agreement before the application is determined. Such an agreement should intend to achieve benefits for the Bridgwater and district community and not just for those living and working on the development site.
The Section 106 Agreement might include contributions for community projects in the Public Realm (Policy BE5) such as the Centre for Alternative Energy being planned for the Old Mill in Blake Street; a wildlife reserve and improvements to the waterways, and and in particular make excellent provision for Public Art (Policy BE 12).
15th March 2009