Letter to councillors, Bath & North East Somerset. 28 August 2003

Our beautiful World Heritage status city is about to lose one of its few remaining urban orchards. Not only is this splendid orchard at its peak of productive maturity, it is also the only significant natural green space in its locality. I refer to the land to the rear of 237 Englishcombe Lane, in the heart of Southdown, which the planning officers are recommending our Council to approve for housing development at Wednesday's committee meeting.

We need more houses, and government guidance is now encouraging 'infill' development. But the Council's officers are advising the committee members that therefore they have no substantial grounds on which they may refuse this application.

This is simply not true. Government Planning Guidance is quite clear that it intends Local Authorities to assess the open space requirements of a locality, including involving local people, before assessing the housing potential of a site.

It also requires an assessment of existing open space irrespective of ownership and the extent of current access.

It also intends the Local Authority to assess opportunities for new provision for open space by taking account of the best possible use of each area of land. It makes clear that even where land falls within the definition of 'previously-developed', its existing and potential value for recreation and other purposes should be properly assessed before any development is considered.

The relevant Government document, known as PPG17, also explains that an open space is well used if used by wildlife, and that well-used spaces are to be highly valued. The same Guidance even has a category, ''semi-natural habitat'', in its typology, which fits this site perfectly.

The developers' ecologists have argued that the site has little worth because they have not found bat roosts, although it is acknowledged to be a significant bat feeding habitat. Our councillors have therefore been advised that although 'mitigation' measures would be needed, there are no grounds for refusing the application on its wildlife merit.

But the Government guidance is that is not necessary to find specific rare or important species for a site to be valuable for wildlife.

This site should be properly valued for what it is, an urban traditional orchard: a productive, cultural and educational asset in its own right. Worcester city council has a draft policy that recognises the special value of traditional orchards within that city and which aims to conserve all known intact orchards. Where is our policy?

Southdown has already been developed to a density higher than that which the government recommends as suitable for further 'infill' development, and the local allotments have already been taken. Officers appear to be recommending councillors to cram houses onto every urban space that does not have a recognised special character. But PPG17 particularly refers to the importance of protecting open space in helping to form the character of an area where there may be little of historic merit to protect, as in this case.

The planning officers have not informed our councillors about any of this. I can find no explanation for why they have chosen not to draw attention to the relevance of PPG17. Instead they advise members that the comments of objectors, who consider this to be a green field site, should be given little weight. They advise that it falls within the government's definition of that ''previously-developed vacant and derelict land and buildings'' which must be prioritised for housing development.

But a different government report warns that such sites are essentially those which fit with the normal public perception of brownfield.

Contrary to officers' advice, therefore, the objectors' perceptions are perfectly valid and they have the weight of the relevant government document behind them.

Wednesday's decision will be absolutely pivotal. If this piece of land cannot be defended, innumerable precious city spaces will become imminently vulnerable to development.

It could easily happen in your street next and people should be very concerned about the quality of the professional advice that our councillors are being given. It runs counter to the government's intentions, particularly for this very special city that we are so privileged to inhabit.

Relevant councillors will have received further detail from me on all this. But if you are a councillor who intends to sit on next Wednesday's committee as a substitute for a colleague, and would like more information, please phone me.

Yours faithfully

[a local campaigner]