Site Allocations Plan - Main Modifications Consultation

Document Section Site Allocations Plan - Main Modifications Consultation 1. General comments [View all comments on this section]
Comment ID 14824321//1
Respondent Oliver Matthews [View all comments by this respondent]
Response Date 31 Oct 2017
Comment

North Somerset DC Site Allocations Plan Unsoundness (Oct 2017 Consultation) – Rectory Farm, Yatton unlawful emittance of evidence

I write in two separate parts in respect of the North Somerset District Council Site Allocations Plan (SAP) on which you are currently consulting. This first submission is specifically made in respect of what Rectory Farm consider to be the unlawful emittance and oversight of evidence which has been provided to date in support of development of Rectory Farm, Yatton to the SAP evidence base.

This submission should be read alongside and not independently of our second submission of the same date (27th October 2017) which makes detailed representations on the methodology and other evidence presented in respect of the emerging SAP.

I wish to highlight Rectory Farm, Yatton’s grave concerns in respect of the incomplete and unsound evidence base on which North Somerset DC are proposing to continue to update and modify their proposed site allocations plan. 

Rectory Farm Yatton has consistently made representations to NSDC identifying land both north and south of Biddle Street, Yatton for development. Whilst the land comprising circa 25 acres to the north has been assessed (ref HE14350) land south of Biddle Street comprising 7 acres has not (either for or against, it has totally been omitted from any assessment). The 7 acres has capacity for circa 100 – 110 dwellings.   We have consistently asked NSDC to rectify its oversight through representations and to fairly assess the 7 acre site on its own merits. To it has made no efforts to do this and the site has once again been omitted from the evidence base within the “new sites to be assessed” (ref CD2A attached to NSDC interim response dated 20th July 2017).  

I have identified below a chronology of the representations and correspondence with NSDC alerting them to this issue to date:

  • 27th April 2016. North Somerset Allocations DPD. Representations submitted by Rectory Farm including land north and south of Biddle Street, Yatton. Plan attached including land to south that has not been assessed.
  • 8th September 2016. Policy Representations. Submitted by Rectory Farm in respect of land north and south of Biddle Street, Yatton. Plan attached including land to the south that has not been assessed.
  • 16th February 2017. Representations to call for sites. Submitted by Rectory Farm on land to the south of Biddle Street, Yatton. Plan attached including the land to the south that has not been assessed.
  • 23rd February 2017. Email from Rectory Farm to Graham Quick, NSDC with site plan including land to south of Biddle Street calling for the sites consideration as an allocation.
  • 19th June 2017. Email to Graham Quick NSDC. Submission of site layout and opportunities and constraints analysis again requesting its inclusion within SAP.
  • 19th June 2017. Out of office response from Graham Quick, NSDC to Rectory Farm. On annual leave until 26th June 2017.
  • 26th June 2017 response from Graham Quick NSDC to Rectory Farm, confirming land south of Biddle Street had been assessed as part of the evidence base. 
    • 19th June 2017. Out of office response from Graham Quick, NSDC to Rectory Farm. On annual leave until 26th June 2017.
    • 26th June 2017 response from Graham Quick NSDC to Rectory Farm, confirming land south of Biddle Street had been assessed as part of the evidence base.
    • 26th June 2017 email to Graham Quick NSDC from Rectory Farm re-confirming that land had not been assessed despite consistent and renewed representations for it to be. Attached resubmitted representations demonstrating this fact.
    • 26th June 2017. Graham Quick NSDC accepted a meeting request to discuss the development potential of the site.
    • 26th June 2017. Rectory Farm accepted the earliest meeting date available for 14th July 2017.
    • 14th July 2017. Meeting held with Graham Quick NSDC. Layout, opportunities and constraints, housing trajectory discussed. Housing trajectory and layout left with Graham Quick. Chronology of representations and SAP evidence base discussed and the omission of the 7 acres to the South within it emphasised and acknowledged by NSDC. Pre-application process discussed and submission welcomed.
    • 17th July 2017 pre application submission formally made to NSDC by Rectory Farm following recommendation by Graham Quick.
    • 24th July 2017 confirmation of an appointed officer Graham Quick NSDC to the application.
    • 24th July 2017 NSDC email forwarding link to interim letter to Inspector and schedule of new sites to be considered. Omission of Rectory Farm from this schedule.

    We can once again make any of the above correspondence available to you at your request.

    The time table attached to NSDC’s interim statement para 6 page 2 should have provided sufficient time for Rectory Farm to have submitted any necessary information and to be considered within this revised assessment process thereby rectifying the historic oversight. NSDC has made no attempt to contact Rectory Farm nor raised this matter in person at the meeting on 14th July 2017.   I can only conclude that this was purposeful.

    The submission by Rectory Farm on 19th June 2017 included a detailed layout and promotional document demonstrating its feasibility. This can be provided on request. It is a highly sustainable location, outside any environmental restriction such as flooding, sssi or green belt and meets the three tests as set in the Inspectors Examination Response (ID4 dated 14th July 2017) in para 24.

    Rectory Farm also left with Mr Quick a housing trajectory on 14th July as well as further architectural layout work. On 17th July a detailed land viability assessment and further accompanying material including SSSI, drainage maps, agricultural land classification map and other supporting material was submitted to Graham Quick NSDC.

    It is now clear from NSDC interim response that it wishes to exclude what is in our view an available, sustainable and deliverable sites from any consideration whatsoever from its evidence based on an arbitory date set by them of 26th June 2017.   Clearly Rectory Farm has made very meaningful and purposeful attempts to engage NSDC well in advance of this date (I stress that it is Rectory Farm’s view that this date has absolutely no meaning or relevance) and yet remain totally overlooked. This in our view must be unsound and should be remedied immediately by NSDC.  

    Rectory Farm considers it has been unfairly and unlawfully omitted from due consideration in this allocations process. I ask that NSDC take the necessary steps to ensure that this matter is now rectified in advance of submitting the next modifications of the SAP to the Inspector for consideration.

    I very much look forward to considering your response and modifications proposed to remedy this matter in due course.

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