Bath and North East Somerset Allotments Association

3 August 03

Re: Land rear of 237 Englishcombe Lane

I am extremely concerned about your officers' recommendation to 'delegate to permit' the above application which is before you for consideration at Wednesday's Development Control Committee meeting. You will have already heard me speak to you about this site at the full council meeting in connection with the revisions to the draft Local Plan.

I am concerned about the short-sightedness of this recommendation, in a locality without its fair share of open space. I ask that you consider very carefully the detailed points I make below, and either refuse this application, or at least decide to defer the decision pending the period of consultation into the revised Local Plan and pending the green spaces review.

The locality I refer to is the group of about 400 households comprising Ambleside Road, Marsden Road, Edgeworth Road, Georgian View, Canons Close, Rowacre, a short length of Rush Hill, and the houses along the nearby stretch of Englishcombe Lane on its eastern side. Together these houses form a shallow half-bowl in the landscape: with the site in question, an old orchard, located centrally at the base.

All the houses and private gardens here are well cared for by their occupants and it is clearly a very pleasant part of town in which to live. But housing density is quite high, at about ten houses per acre, and there is just one area of open amenity space, which is quite small and sloping, at the bottom of Ambleside Road.

Englishcombe Lane is a fast and quite busy road, with bends hereabouts. This means that most residents would not, I think, particularly regard the next nearest green space, below Sladebrook House and below the bend, as part of their own locality.

I am well aware of the encouragement of PPG3 of infill development and of re-use of brownfield sites. But you must be equally well aware by now that this is not a brownfield site by any common-sense interpretation of the word: and that if you were to permit development here then every large back garden, every church ground, play corner and wild space that is not specifically zoned green in the local plan will be extremely vulnerable to threat of development in the next few years. There are lots of such sites in every ward in the city, and each such threat is likely to generate local controversy and anger that you, the ward councillor, will appear to be powerless against.

Just how will you be able to hold to the council's aspiration to make Bath a better place to live, work and play? The frustration and indignation that Southdown people are feeling today will be felt all over the city very soon as your officers' particular interpretation of the Planning Policy Guidance notes really starts to bite.

There is a better way forward from here, but it does not appear to be being brought to your attention by your officers.

First, please visit the locality, not just the site itself. You will see the role the site plays as a semi-wild green space from the top of Round Hill, or from parts of Edgeworth Road. You will surely appreciate its importance as a green, cooling space among a sea of rooftops: psychologically cooling if not measurably so.

I would guess that the site is visible from between fifty and a hundred nearby households, and to them it is visually important in that they will certainly feel upset if the trees are felled, even if (being private land) it is not currently highly profiled in their minds right now.

You can therefore ask for reclassification of the part of the site without a house on it, as a visually important open space, as has been done for other sites. But this will now have to be done in the context of the autumn consultation period and hence the immediate application must be refused or deferred, so as not to prejudice that process.

Better than that, within the government's typology of urban green spaces, you will actually find a category that this site fits perfectly: semi-natural habitat. [Annex A: Assessing needs and opportunities: Planning Policy Guidance 17 companion guide]. Bats fly over and most likely roost here, badgers roam through, there are wonderful apples and plums on venerable trees, and the developers' ecologist's report mentions features such as the old field boundary that are of neighbourhood/parish importance. How could you possibly destroy this wonderful gift of so many decades of growth for the sake of houses precisely where more houses are not needed, for lack of local open space and indeed other local amenity?

Your officers have suggested that this site is on a slope, but it is actually on flatter ground than either of the other two amenity spaces already referred to. It also has excellent potential pedestrian access, from Marsden Road and from Englishcombe Lane. Entrances onto the site from either end would therefore be quite easily possible for wheelchairs. And there could also be scope for small-scale ball games and shuttlecock on relatively flat ground within the site itself.

Our own interest in the land is to protect it as a community facility, and, subject to the particular wishes of local residents, to instate a few allotments to help compensate for past losses of nearby allotment lands at Canons Close and west of the Englishcombe Inn. This site too may once have been allotments. I have not yet been able to track down a historic map from the 1950s that might demonstrate that. (It is missing from the central library and I have recently sought for a copy in the council's possession, without answer as yet).

This is another reason to defer your decision, as historic allotment land is now by and large being protected in the revised Local Plan. Certainly, the orchard would tend to signify that this is well-watered ground, from natural springs or from seepage, so it is quite possible that the trees have grown up out of allotment plantings.

Current government advice, in the companion guide to PPG17, is that allotment provision should be both demand-led and be provided on a population basis. The council has not carried out any survey locally to estimate demand, and I think it should do so before further consideration of this application. Nor has it yet agreed any population based standard for provision, but at current level of demand, which the government anticipates will rise, there is take-up of one allotment per 30 households in the city. This would imply a local existing shortfall of about 13 plots. If a site of this size were provided, it could easily be self-managed, with assistance from our Association, so that no cost would fall on the council. Indeed, allotments are a highly valued leisure facility and so the council would indirectly benefit from a rise in prices and hence taxable value of houses nearby.

We identified the larger portion of this site as important to protect from development and notified the policy planners to that effect last September, before the planning application first came in. This notification was done in the context of a survey of historic allotment lands at the request of the policy planners and in the context of the draft Local Plan. Unfortunately, as has been our consistent experience, it appears that nobody in Development Control has used any of the information we brought forward in that survey, and indeed it is possible they may not even have been aware of it, although they would have been had they read any of our subsequent representations. That makes me suspect that representations that raise locality and community issues as distinct from site issues count for very little or nothing at all. This cannot be regarded as good practice and would appear to fly in the face of the fine, indeed inspirational, wording contained in the draft Local Plan:

This site forms part of the distinctive character of a distinct community. It is not green belt, it is tucked in among the settlement. That is what makes it locally so important. It does not appear to have the most charismatic wildlife, no horseshoe bats or red squirrels or great crested newts. But it is the only local wild habitat that has the potential to become a community resource, and that is what makes it locally precious.

There are mechanisms to bring this land into community ownership, under good management and without cost to the council. But these mechanisms would be prejudiced under consent of outline planning permission, which is why I urge you to vote against the recommendation.

The most obvious mechanism is via a charitable land trust that can pull in lottery funding, or funding related to the city's World Heritage Status. You will know that St Stephens successfully saved their allotments a few years ago in a similar manner, and that they are now one of the city's flagship sites.

There are now also new sources of funds that you may not yet be aware of, such as the Allotments Regeneration Initiative, that has already been successfully used at an old allotment site in Moorfields. Another possible mechanism, I am told, would be for Southdown to apply for Parish Council status. And I am sure there are other possibilities, given the will.

Yet another helpful aspect could be that one of the revisions to the draft Local Plan (Policy NE.4) gives productive and veteran trees protection from adverse impact of development.

You might have a concern about the fate of the existing wildlife on this site if it were to be opened up as a community facility. I would anticipate that that could be resolved by a combination of education, seasonally closed areas, and community management, particularly by local young people themselves. Additionally, allotment holders would often be able to provide informal supervision.

I need now to address in some detail your two major concerns: how to meet the government's housing targets; and how to prevent infill development on sites such as this, which you have been told by your officers are 'brownfield' under their interpretation of PPG3.

The housing target to be met by Bath and North East Somerset via the Local Plan mechanisms, is 6220 additional dwellings. The calculated figure actually stands at 6236, so your target could still be met without the ten houses provisionally proposed for this site.

I am sure nobody in Southdown, and certainly not ourselves, is against the council's desire for new housing, and particularly for affordable houses. For example, I have myself personally, or on behalf of the Association, supported the redevelopment behind Third Avenue, and the proposals at Western Riverside and at the Clarks Factory site. We have also agreed to cede historic allotment land in certain cases, such as for a school playing field at Claude Avenue. So we are not against what you are trying to do. It is just that to put additional houses here seems so wrong.

The government, and now you yourselves, argue a move against green field development, and I'm sure that in general this will prove to be a very popular new direction. But I feel that the way that this particular site has been 'brownfielded' gives considerable cause for concern. It has arisen out of a new process, called The Urban Housing Capacity Study. This asks councils to assess in detail the capacity of different kinds of site suitable for development and for redevelopment, and recommends how to prioritise.

The three possible categories into which this site could have fallen are previously-developed vacant and derelict land and buildings; intensification within residential areas; and vacant areas. The process of selection is explained clearly and at length in a government document called Tapping the Potential, issued in December 2000.

The first point to be aware of is that, as the CPRE's commentary on this document notes, ''urban capacity studies are as much about choice as they are about fact.'' Thus, even though you are now intending to encourage the use of 'brownfield' land wherever possible, government statements make it clear that this must be in balance with other considerations, and that a great deal of judgement, whether by yourselves or by your officers, will often be necessary. And, I would add, with judgement there must surely be imagination, to consider not the site alone, but the impact on the locality. If your officers feel constrained in using their imagination, then that role surely must fall to you.

With regard to previously-developed vacant and derelict land and buildings, the document makes it clear that ''essentially these are the sites which fit with the normal public perception of brownfield''. This site does not fit the normal public perception of brownfield.

With regard to vacant land not previously developed, the document states that ''it is that land often shown within built up areas on Ordnance Survey maps as a white area without annotation''. Most of this land is shown not as white land on the Ordnance Survey base map, but as woodland (stippled grey).

Therefore the category ''intensification of residential areas'' must have been applied to this site to bring it forward as suitable for development.

This is where I plead with you to reconsider, using your imaginative judgement. If this already quite densely built up area is suitable for intensification, what are the implications down the line for your own ward?

Fortunately, there is sufficient guidance, I believe, in the government's own documents, to guide you around this problem.

Tapping the Potential notes: ''as importantly, the eventual assessment of [the area's housing] capacity should reflect the Government's commitment to maintaining biodiversity and green spaces in urban areas''.

More detail on this is to be found in other government guidance:

Here and now is surely the opportunity. Your Policy Planners and the Parks Department have recently indicated their intention to carry out a Strategic Review of Open Spaces (see Paragraph B9 of Annex 2 [Main Changes] Report of the Revised Draft Local Plan as presented to the executive committee on July 9).

Such a review cannot come a moment too soon, in my view, given the huge extent of green space, particularly in the city itself, that has now become vulnerable under your officers' interpretation of the new PPG3. The most important of these spaces currently in private ownership and in areas of deficiency will be needing some form of protection.

There is scope for a more balanced evaluation of local community space and potential housing sites and I urge you to now ask your officers to speedily do this using the Green Spaces Strategic Review mechanism, and to ensure at the committee meeting that this particular planning application be deferred until it can be considered within that context as well as through the Local Plan revisions consultation process.

Yours sincerely

Helen Woodley

Publicity Officer

Bath and North East Somerset Allotments Association

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