The site is not allocated in the draft South Glos Local Plan

South Gloucestershire Council has prepared a strategic vision for where homes should be allocated over the next 15 years. That vision is contained within the draft Local Plan which is currently with the Planning Inspectorate while the council awaits a date for a public examination. 

The draft Local Plan does not allocate this site after it was considered and rejected at earlier stages of the plan consultations. 

Specifically, the Land East of Roundways was not included in the draft Local Plan's preferred strategy because it could not meet two of the three Phase 3 criteria for inclusion: 

• "Criteria 1 - Infrastructure: Development of this site will significantly increase highway trips heading through Coalpit Heath toward Wick Wick Roundabout. This level of additional highway demand on a heavily congested corridor is likely to have significant impacts on journey time reliability. Scheme assessment previously carried out supporting the relevant CRSTS scheme for the A432 and subsequent outline business case has suggested that there is little scope to provide dedicated bus priority measures along the A432 due to the constrained width of the existing highway and the presence of a large number of properties adjoining the road."

   

• “Criteria 2 - Services and Facilities: The scale of growth is not supported by a suitable level of employment within Coalpit Heath with development on this site building in the need to travel to access wider services and facilities as well as access to employment. The issues raised regarding the A432 will also have a negative impact on the current public transport services which are unable to operate independently of private vehicle commuter trips. This will impact the quality and reliability of public transport services as additional vehicular traffic is added to the A432 from this development with no identified, funded or deliverable mitigations to ensure the future quality of public transport services.”

The site is not allocated in the draft South Glos Local Plan

South Gloucestershire Council has prepared a strategic vision for where homes should be allocated over the next 15 years. That vision is contained within the draft Local Plan which is currently with the Planning Inspectorate while the council awaits a date for a public examination. 

The draft Local Plan does not allocate this site after it was considered and rejected at earlier stages of the plan consultations. 

Specifically, the Land at Frog Lane was not included in the draft Local Plan's preferred strategy because it could not meet two of the three Phase 3 criteria for inclusion: 

• "Criteria 1 - Infrastructure: Development of this site will significantly increase highway trips heading through Coalpit Heath toward Wick Wick Roundabout. This level of additional highway demand on a heavily congested corridor is likely to have significant impacts on journey time reliability. Scheme assessment previously carried out supporting the relevant CRSTS scheme for the A432 and subsequent outline business case has suggested that there is little scope to provide dedicated bus priority measures along the A432 due to the constrained width of the existing highway and the presence of a large number of properties adjoining the road."

   

• “Criteria 2 - Services and Facilities: The scale of growth is not supported by a suitable level of employment within Coalpit Heath with development on this site building in the need to travel to access wider services and facilities as well as access to employment. The issues raised regarding the A432 will also have a negative impact on the current public transport services which are unable to operate independently of private vehicle commuter trips. This will impact the quality and reliability of public transport services as additional vehicular traffic is added to the A432 from this development with no identified, funded or deliverable mitigations to ensure the future quality of public transport services.”

The abandoned Joint Spatial Plan cannot be relied on

In section 2.8 of their planning statement, the applicant relies on evidence of the sites prior inclusion in the unadopted Joint Spatial Plan (JSP) by stating, “Whilst the JSP was therefore never formally adopted, the previous identification of the land as an SDL is a strong endorsement of it’s sustainability and planning pedigree."

But the JSP cannot be used as evidence. It was found by the Planning Inspector at enquiry that there were fundamental and irreparable issues with the soundness of the submitted plan. In particular the Inspectors took issue with the way that the proposed SDLs had been selected against reasonable alternatives.

The applicants acknowledge that the plan was found to be unsound in section 2.7 or their own *planning statement. Additionally, the *South Glos Planning Policy Team's submission to this application, is clear that the abandoned JSP should be given no planning weight when determining this application.

The proposal is for inappropriate development in the Green Belt

The draft Local Plan will redraw some Green Belt boundaries, but not the Green Belt land proposed by this application. Therefore this application's use of Green Belt land should be judged against existing policy: NPPF Section 13, CS5 and PSP7. 

The National Planning Policy Framework (NPPF), in paragraph 143, remains clear that the five purposes of the Green Belt remain unchanged: 

a) to check the unrestricted sprawl of large built-up areas

b) to prevent neighbouring towns merging into one another

c) to assist in safeguarding the countryside from encroachment 

d) to preserve the setting and special character of historic towns

e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 

The Land east of Coalpit Heath meets the first four of these purposes. It:

Checks the unrestricted sprawl of the already contiguous dormitory settlement of Coalpit Heath, Frampton Cotterell and Winterbourne.

It prevents the dormitory settlement town of Coalpit Heath, Frampton Cotterell and Winterbourne from merging with the town of Yate, and prevents the city of Bristol from merging with the town of Yate.

It safeguards the countryside East of Coalpit Heath from encroachment.

It preserves the setting and special character of the dormitory settlement town of Coalpit Heath, Frampton Cotterell and Winterbourne - in particular with reference to nearly heritage assets such as The Manor Hall; Rose Oak Farmhouse; The Ring O' Bells Public House; St Saviour's Church; and the street of Roundways itself which, with housing along the west side only, affords residents an unimpeded view of the fields and hedgerows comprising the application site. 

The proposal is for inappropriate development in the Green Belt

The draft Local Plan will redraw some Green Belt boundaries, but not the Green Belt land proposed by this application. Therefore this application's use of Green Belt land should be judged against existing policy: NPPF Section 13, CS5 and PSP7. 

The National Planning Policy Framework (NPPF), in paragraph 143, remains clear that the five purposes of the Green Belt remain unchanged: 

a) to check the unrestricted sprawl of large built-up areas

b) to prevent neighbouring towns merging into one another

c) to assist in safeguarding the countryside from encroachment 

d) to preserve the setting and special character of historic towns

e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land. 

The Land east of Coalpit Heath meets the first four of these purposes. It:

Checks the unrestricted sprawl of the already contiguous dormitory settlement of Coalpit Heath, Frampton Cotterell and Winterbourne.

It prevents the dormitory settlement of Coalpit Heath, Frampton Cotterell and Winterbourne from merging with the town of Yate, and prevents the city of Bristol from merging with the town of Yate.

It safeguards the countryside East of Coalpit Heath from encroachment.

It preserves the setting and special character of the dormitory settlement town of Coalpit Heath, Frampton Cotterell and Winterbourne - in particular with reference to nearly heritage assets such as The Manor Hall; Rose Oak Farmhouse; The Ring O' Bells Public House; St Saviour's Church; Mayshill Farmhouse; Says Court Farmhouse and The New Inn. 

The Green Belt around Coalpit Heath can not be considered “grey belt”

In their planning statement the applicant claims "The site is 'Grey Belt'" (para 6.10). The latest NPPF defines the concept of "grey belt" as land which should be considered first when reviewing Green Belt boundaries - but the definition of Grey Belt cannot apply here. 

The NPPF defines "grey belt" as "land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143". The Land East of Coalpit Heath is not previously developed, but it strongly contributes to purposes a, b and d - as established above.  The land therefore cannot be considered to be "grey belt". 

Therefore, as Green Belt land, the NPPF is clear (para 145) that "Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified through the preparation or updating of plans." 

The draft Local Plan is the closest document we have related to the preparation or updating of plans. It has examined Green Belt boundaries in great depth and, despite releasing some Green Belt nearby, has concluded that no such exceptional circumstances exist and chosen not to release the Green Belt of this application site. 

Turning to local policy: In the Core Strategy, CS5 clearly defines a number of situations where development may be acceptable within the Green Belt but none of these situations apply to the large-scale development being proposed here. 

The "Development in the Green Belt" SPD examines the "very special circumstances" that may allow developments to take place within the Green Belt. It says that "Circumstances that are accepted as being 'very special' are very rare, but will usually involve a specific judgement being made that no other option is available in light of the unique circumstances and individual case. These circumstances are not common and are unique 'one-offs'". It also says that "the onus is on the applicant to prove that the exceptional nature of the proposal outweighs the harm that it would cause to the Green Belt." PSP7 in the adopted Policy, Sites and Places plan makes the very same point: "Inappropriate development is harmful to the Green Belt and will not be acceptable unless very special circumstances can be demonstrated that clearly outweigh the harm to the Green Belt, and any other harm." 

This application clearly causes very substantial harm to the Green Belt. We do not consider that the applicant has demonstrated the "very special circumstances" that outweigh that harm and therefore planning permission should be refused.

The Green Belt around Coalpit Heath can not be considered “grey belt”

In their planning statement the applicant claims "The site is 'Grey Belt'" (para 6.10). The latest NPPF defines the concept of "grey belt" as land which should be considered first when reviewing Green Belt boundaries - but the definition of Grey Belt cannot apply here. 

The NPPF defines "grey belt" as "land in the Green Belt comprising previously developed land and/or any other land that, in either case, does not strongly contribute to any of purposes (a), (b), or (d) in paragraph 143". The Land East of Coalpit Heath is not previously developed, but it strongly contributes to purposes a, b and d - as established above.  The land therefore cannot be considered to be "grey belt". 

Therefore, as Green Belt land, the NPPF is clear (para 145) that "Once established, Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified through the preparation or updating of plans." 

The draft Local Plan is the closest document we have related to the preparation or updating of plans. It has examined Green Belt boundaries in great depth and, despite releasing some Green Belt nearby, has concluded that no such exceptional circumstances exist and chosen not to release the Green Belt of this application site. 

Turning to local policy: In the Core Strategy, CS5 clearly defines a number of situations where development may be acceptable within the Green Belt but none of these situations apply to the large-scale development being proposed here. 

The "Development in the Green Belt" SPD examines the "very special circumstances" that may allow developments to take place within the Green Belt. It says that "Circumstances that are accepted as being 'very special' are very rare, but will usually involve a specific judgement being made that no other option is available in light of the unique circumstances and individual case. These circumstances are not common and are unique 'one-offs'". It also says that "the onus is on the applicant to prove that the exceptional nature of the proposal outweighs the harm that it would cause to the Green Belt." PSP7 in the adopted Policy, Sites and Places plan makes the very same point: "Inappropriate development is harmful to the Green Belt and will not be acceptable unless very special circumstances can be demonstrated that clearly outweigh the harm to the Green Belt, and any other harm." 

This application clearly causes very substantial harm to the Green Belt. We do not consider that the applicant has demonstrated the "very special circumstances" that outweigh that harm and therefore planning permission should be refused.

Mitigating transport infrastrucure is no longer planned

The proposed development would introduce unacceptable levels of new traffic onto already congested roads, including the A432 Badminton Road, but there is no longer any planned infrastructure designed to mitigate this impact.

In section 2.8 of their *planning statement, the applicant relies on evidence of the site's prior inclusion in the unadopted Joint Spatial Plan by stating, “Whilst the JSP was therefore never formally adopted, the previous identification of the land as an SDL is a strong endorsement of it’s sustainability and planning pedigree.”

During the time the JSP was being proposed there were additional infrastructure changes also planned which would have partly mitigated the transport impact:

• A Winterbourne / Frampton Cotterell Bypass
• A Coalpit Heath / Westerleigh Bypass
• Junction 18a on the M4

• Metrobus lanes along the A432 Badminton Road

   

None of these changes are currently proposed, making the site even less suitable than when it was previously rejected in the JSP enquiry.

Additionally, the *South Glos Planning Policy Team's submission to this application, is clear that the abandoned JSP should be given no planning weight.

Mitigating transport infrastrucure is no longer planned

The proposed development would introduce unacceptable levels of new traffic onto already congested roads, including the A432 Badminton Road, but there is no longer any planned infrastructure designed to mitigate this impact.

This site was previously put forward in the abandoned Joint Spatial Plan (JSP) (See the Local Planning History section)

During the time the JSP was being proposed there were additional infrastructure changes also planned which would have partly mitigated the transport impact:

• A Winterbourne / Frampton Cotterell Bypass
• A Coalpit Heath / Westerleigh Bypass
• Junction 18a on the M4

• Metrobus lanes along the A432 Badminton Road

   

None of these changes are currently proposed, making the site even less suitable than when it was previously rejected in the JSP enquiry.

Recent research into the site reveals an unacceptable highways impact

Transport impact was examined in the South Glos Local Plan process and this site was dropped from the draft Local Plan at Stage 3 where it found:

"Criteria 1 - Infrastructure: Development of this site will significantly increase highway trips heading through Coalpit Heath toward Wick Wick Roundabout. This level of additional highway demand on a heavily congested corridor is likely to have significant impacts on journey time reliability. Scheme assessment previously carried out supporting the relevant CRSTS scheme for the A432 and subsequent outline business case has suggested that there is little scope to provide dedicated bus priority measures along the A432 due to the constrained width of the existing highway and the presence of a large number of properties adjoining the road."

The *South Glos Planning Policy Team's submission to this application is clear that the findings of the emerging Local Plan, which does not allocate this site, should be given limited - but not zero - weight.
 

Recent research into the site reveals an unacceptable highways impact

Transport impact was examined in the South Glos Local Plan process and this site was dropped from the draft Local Plan at Stage 3 where it found:

“Criteria 1 - Infrastructure: Development of this site will significantly increase highway trips heading through Coalpit Heath toward Wick Wick Roundabout. This level of additional highway demand on a heavily congested corridor is likely to have significant impacts on journey time reliability. Scheme assessment previously carried out supporting the relevant CRSTS scheme for the A432 and subsequent outline business case has suggested that there is little scope to provide dedicated bus priority measures along the A432 due to the constrained width of the existing highway and the presence of a large number of properties adjoining the road.”
 

The access to the proposed development is unacceptable

Access to the new development is proposed to be through a single entrance close to where Roundways, Henfield Road and St. Anne's Drive meet. 

The access point is directly opposite The Manor Primary School. The bend adjacent to St. Anne's Drive where Henfield Road and Roundways join is already dangerous and already congested with parked cars on both sides of the road; especially at school drop-off / pick-up times. 

Adding another junction here to access the site would compound this danger - which is particularly significant given the need for school children to cross the road at this location to access The Manor Primary School.

It is presumably hoped that new residents will access the new junction via Henfield Road which links directly to the A432 Badminton Road at the Henfield Road / Beesmoor Road / Badminton Road crossroads. 

The section of Henfield Road adjacent to The Manor Playing Field is often already heavily congested with parked cars - meaning existing traffic heading towards the A432 from Henfield Road or Roundways often has to pull into the limited spaces between parked cars alongside the playing field in order to allow cars coming from the A432 towards Roundways to pass. 

This situation is particularly bad when the Manor Playing Field is being used for its regular sports activities. Recent attempts to mitigate this already dangerous position - such as painting "Keep Clear" markings on sections of Henfield Road - have done little to help. 

The increased traffic associated with another 450 homes using this road is likely to make the situation much worse and far more dangerous. If traffic from the proposed new development chooses not to use Henfield Road, it could choose to access the A432 via St. Anne's Drive and Station Road to the south, or Roundways and Woodside Road to the north. 

Neither of these alternatives are suitable. Parking on both Roundways and St. Anne's Drive means there is often little room for cars to pass. This development would elevate the level of use of these roads to inappropriate volumes and introduce unacceptable levels of danger.

The applicant's proposal to offer access to their site to Bloor Homes would result in unacceptable traffic impact

On their consultation website the applicant is proposing to offer access to the Frog Lane site where the site boundaries join at Woodside Road.

This will cause unacceptable levels of traffic (c. 1800 cars from this site alone, c. 2,700 cars from the sites combined) to use the junction at Roundways and the local roads of Roundways, Henfield Road, St. Anne's Drive and Station Road to access the A432 Badminton Road with the most direct route being via Henfield Road.

The section of Henfield Road adjacent to The Manor Playing Field is often already heavily congested with parked cars - meaning existing traffic heading towards the A432 from Henfield Road or Roundways often has to pull into the limited spaces between parked cars alongside the playing field in order to allow cars coming from the A432 towards Roundways to pass. 

This situation is particularly bad when the Manor Playing Field is being used for its regular sports activities. Recent attempts to mitigate this already dangerous position - such as painting "Keep Clear" markings on sections of Henfield Road - have done little to help. 

The increased traffic associated with another 450 homes using this road is likely to make the situation much worse and far more dangerous. If traffic from the proposed new development chooses not to use Henfield Road, it could choose to access the A432 via St. Anne's Drive and Station Road to the south, or Roundways and Woodside Road to the north. 

Neither of these alternatives are suitable. Parking on both Roundways and St. Anne's Drive means there is often little room for cars to pass. This development would elevate the level of use of these roads to inappropriate volumes and introduce unacceptable levels of danger.

Heritage assets would be harmed by the development

The proposal would cause significant harm to the following Grade II listed heritage assests:

• Rose Oak Farmhouse
• St. Saviour's Church
• The Manor Hall
• The Ring O' Bells Public House

The South Glos Conservation Officer's comments on this application state that the proposal will: 

• “result in a change in setting to the Grade II listed Rose Oak Farmhouse as a result of the urbanisation of its rural setting” 

   

  and that this will 

   

• "diminish the historic interest of the farmhouse, thus harming its significance and that this finding of harm gives rise to a statutory presumption against the granting of permission."

We support this Conservation Officer view.

The applicant makes reference to Rose Oak Farmhouse and St.Saviour's Church in their *planning statement, but there is no reference to The Manor Hall or the Ring O' Bells - both of which are closer to the proposed site than St. Saviour's Church.

Heritage assets would be harmed by the development

The proposal would cause significant harm to nearby Grade II listed assets such as 

• Rose Oak Farmhouse
• Mayshill Farmhouse
• Says Court Farmhouse
• The New Inn
• The Ring O'Bells
• The Manor Hall

The proposed development is in danger of ground instability

Coalpit Heath has a strong mining heritage and is located within a Coal Mine Reporting Area, but the Land East of Roundways and St. Anne's Drive is particularly affected by old mine workings. 

An examination of the Mining Remediation Authority Map shows around 12 mine openings to the western side of the proposed site - acknowledged in the Coal Authority response as consultee, as well as the site being entirely in the abandoned mines catalogue area and the development high risk area. Areas to the west of the site also show evidence of past shallow coal mining.

The *Coal Authority report submitted to this application also considers the risks of escaping Mine Gas, Shallow Coal Seams and the public safety risk posed by the impact on ground stability of installing SUDS basins on the site. It concludes that coal mining features on this site should be a Material Consideration.

Therefore we have concerns over ground stability issues on this site. Local people report that ventilation shafts have opened up in the field over the years and residents notice ground level changes on the fields indicating significant ground movement over the passage of time.

The proposed development is in danger of ground instability

Coalpit Heath has a strong mining heritage and is located within a Coal Mine Reporting Area, but the land around Frog Lane is particularly affected by old mine workings having previously been within the working area of Frog Lane Colliery.

An examination of the Mining Remediation Authority Map shows approximately 6 mine openings to the western side of the proposed site as well as the site being entirely in the abandoned mines catalogue area and the development high risk area.

Therefore we have concerns over ground stability issues on this site.

The proposed site is at risk of flooding

The site regularly floods and residents report the run-off from the fields flooding the back gardens along St. Anne's Drive. 

This run-off will be compounded by housing development on the site and should be considered alongside the *Coal Authority's concern about the ground stability effect of installing SUDS basins. The Coal Authority states:

“It should be noted that where SUDs are proposed as part of the development scheme consideration will need to be given to the implications of this in relation to the stability and public safety risks posed by coal mining legacy. The developer should seek their own advice from a technically competent person to ensure that a proper assessment has been made of the potential interaction between hydrology, the proposed drainage system and ground stability, including the implications this may have for any mine workings which may be present beneath the site.”

The proposed site is at risk of flooding

Further details will be provided in this section once Edward Ware Homes have submitted their proposals for the site at Frog Lane.

Unacceptable impact on Education and Healthcare services

Local education and healthcare services will be overstretched if required to serve another 450 homes on this site. 

This is confirmed by the *NHS consultation response that states, "There is not sufficient existing primary healthcare capacity locally to address demand generated by the development." 

In their response, the NHS request a financial contribution of £457k towards the capital cost of delivering additional primary care and say that this additional capacity will be generated through refurbishment / extension of existing healthcare facilities in the Yate and Frampton PCNs.

We do not think it is clear whether sufficient land exists at existing facilities to extend them or, indeed, whether these extensions could happen quickly enough to meet the rapid population growth generated by this site.

Unacceptable impact on Education and Healthcare services

Local education and healthcare services will be overstretched if required to serve another 900 homes on this site. 

Important wildlife Habitats would be lost to the development 

The applicant's *ecological impact assessment attempts to explain how ecological loss will be mitigated - but still concludes that: 

• "Site clearance would result in the removal of grassland, cropland, hedgerows and scrub, which provide suitable nesting habitat for common/widespread species and birds of conservation concern, including up to 13 skylark territories and five yellowhammer territories. This could also lead to direct effect (i.e. killing or injury) on nesting birds, their eggs and young if undertaken during the breeding season." 

  
  and 

• "It is likely that the majority of skylark and yellowhammer territories would be permanently lost from the site."

We consider these habitat losses to be unacceptable.

Important wildlife Habitats would be lost to the development 

Further details will be provided in this section once Edward Ware Homes have submitted their proposals for the site at Frog Lane.