Our advice when objecting to the LiveWest Planning Application

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The planning application

LiveWest (LW) has submitted a Full Application for the “Erection of 74 dwellings” under Application Number 2023/0864/FUL. Full details of the application can be found on Somerset Council’s website here.

People for Packsaddle (PfP) is urging local residents to view and oppose this application. Below is PfP’s guidance on how to do so. We have tried to highlight and condense the key points. Please take the time to read and consider our recommendations.

How to respond

There are several ways you can respond to the planning application:

  • You can make comments on the Somerset Council website planning portal here (note, you will need to register if you’ve not used the portal before but this is fairly easy to do.)
  • You can email your response to planningeast@somerset.gov.uk 
  • You can post your response to Somerset Planning East Team, Somerset Council, Cannards Grave Road, Shepton Mallet, BA4 5BT.

However you choose to respond, please:

  • make sure you mark your response with the word OBJECT
  • quote the Application Number (2023/0864/FUL)
  • Please also send a copy of your comments to the FromeTown Council Ward Councillors – Tracey Ashford (tashford@frometowncouncil.gov.uk), Andy Jones (ajones@frometowncouncil.gov.uk), Sara Butler (sbutler@frometowncouncil.gov.uk) and the Somerset Council Ward Councillors – Adam Boyden (adam.boyden@somerset.gov.uk) and Dawn Denton (dawn.denton@somerset.gov.uk)
  • If you’re happy to do so, please copy to us at hello@peopleforpacksaddle.org
If you or someone you know needs help writing a letter, perhaps due to frailty or ill-health, please let us know!

Deadline

EDIT – the deadline has now been extended until Tuesday 4th July but we would still urge you to submit your response as soon as possible and not leave it until the last minute, just in case you encounter any problems with submitting it.

Please ensure that responses are submitted by the end of the working day on Tuesday 4th July. This may not be the date shown on letters sent to local residents or on signage around the sight, but this is the most recent deadline that we have had confirmed by Somerset Council.

Responses sent after 4th July “may not be taken into consideration.”

The number of responses is critical

If you can, please send more than one per household. If you’re a couple, please send one each. If you have kids old enough, and they’re sufficiently engaged, please encourage them to write one as well – these would be really valuable.

Make it polite, but also personal!

Polished perfection is not the aim here. Your response will be read and considered by the 13 elected Somerset Councillors who sit on the Planning Committee. They are human beings who care about Somerset residents. Be yourself, write from the heart, speak honestly about the issues which matter to you (eg mental health, loneliness, community spirit) and why you care, but, CRUCIALLY…..

Base your objections around ‘material considerations’

DO NOT waste time, energy and space on objections which aren’t ‘material considerations’. Official guidance states that “perceived loss of property value, loss of views, boundary disputes and personal opinions about the applicant are not considered to be material”. Any such comments won’t be taken into account and they could potentially be counterproductive.

DO make reference to the very real, very significant ‘material considerations’. Your response must be your own but our advice is to build your objection around one or several of the key ‘pillars’ below:

PACKSADDLE COMMUNITY FIELDS ARE AN ASSET OF COMMUNITY VALUE (ACV) AND A LISTED GREEN SPACE

It has been decisively, conclusively proven that the area “furthers the social well-being of the local
community” and is an “accessible space for informal countryside recreation”. NOWHERE in LW’s Application is the ACV status referred to, and the potential (colossal) loss to the community must not be ignored and cannot be ‘mitigated’. The Green Space listing is dismissed by LW, who say “the Council undertook no analysis”.

IT IS NOT ACCEPTABLE FOR LW (AND ELEMENTS OF SC, TOO!) TO BELITTLE AND UNDERMINE THE ACV AND GREEN SPACE CONSIDERATIONS. THE PROCESSES BY WHICH THESE STATUS’ WERE AWARDED WERE TRANSPARENT, FAIR, RIGOROUS. THEY WERE COUNCIL PROCESSES! WE MUST FORCEFULLY MAKE THE POINT THAT THEY ARE VALID AND SIGNIFICANT, AND THAT THEY TESTIFY TO THE GENUINE FEELINGS OF THIS COMMUNITY. AGAIN, BE HUMAN AND TELL YOUR STORY.

‘BIODIVERSITY NET GAIN’ (‘BNG’) AND ‘SUSTAINABILITY’ FALLACIES

THE ‘BIODIVERSITY NET GAIN’ (‘BNG’) AND ‘SUSTAINABILITY’ FALLACIES at the heart of LWs proposals need to be challenged and exposed.

The proposed development is sustainable in name only. It falls significantly short of modern sustainability standards which should be expected of a new development. This is a bare minimum proposal full of conspicuous omissions and flimsy pledges. Where are the solar panels, the heat pumps, the triple glazing, the meaningful water-saving measures?! Instead, it’s just more of the same; lip service, shortcomings and more gas boilers!

Contrast what’s being promised in this proposal, with Packsaddle Community Fields as they stand today: calling this a ’sustainable development’ is an insult.

With regard to Biodiversity Net Gain (BNG), there are three key points to be made:

  1. The clearance of the fields in July and August 2022 were, we have strong reason to believe, a calculated, coordinated and cynical attempt to set a lower ‘BNG baseline’. At best, they were an act of gross negligence which undermined and fatally invalidated the ecological surveys in progress at the time. Our position, in line with the Environmental Act 2021, is that “the pre-development biodiversity of the onsite habitat is to be taken to be its biodiversity values immediately before the carrying out of the activities.”
  2. The ‘Planning Statement’ is wrong and misleading. The correct BNG figures are set out in detail in the ‘Ecological Impact Assessment’ (EIA) and these figures show a BNG below the required figure of 10%. This requirement does not come into statutory effect until November 2023 but it would be reprehensible if Somerset Council did not insist on it for permissions granted prior to that date, particularly where it is the landowner.
  3. An objective, ‘layperson’ assessment of any BNG claim would conclude that it is risible and ridiculous. The fields cover an area of nearly 9 acres, of which nearly 6 will be covered in houses, roads, car-parking spaces, lighting and so on. ONE tree is given Class A status. ONE! The EIA concedes that over 300 metres of hedgerows will be removed. The disturbance caused by the development will result in irreversible habitat loss, and the positive impact of new ‘ornamental’ planting will be negligible. Again, the proposals should be compared with the fields as they exist today. It is currently a mature, varied, rich habitat, and to claim that the proposed development would “improve the existing ecological value” is laughable.

THIS APPLICATION IS NOT MOTIVATED BY A DESIRE TO TACKLE THE HOUSING ISSUES IN FROME

This is a false premise. In fact, the application guarantees nothing in terms of affordable and social rent homes.

This is a ‘jam tomorrow’ application. Disregard whatever it implies and pledges, the truth is that LiveWest is applying for permission to build 74 ‘market homes’.

The modest allocation for ‘affordable’ and ‘social rent’ homes (22 of them in total), which the application says will be delivered by this development, is wholly contingent on grant funding from Homes England. This is not secured, not guaranteed, not certain. It is a pledge built on ifs, buts and maybes.

LiveWest was specifically chosen, Somerset Council has repeatedly told us, because of its expertise in the delivery of affordable and social rent housing. The truth is now laid bare; this is, and has always been, about money.

EVEN IF THE 22 AFFORDABLE AND SOCIAL RENT HOMES ARE EVENTUALLY DELIVERED, THE MODEST BENEFIT OF THIS PROVISION WOULD NOT OUTWEIGH THE HUGE, PERMANENT HARMS OF THE DEVELOPMENT.

THERE’S MORE!

We suggest that you also consider:

  1. Packsaddle Community Fields fall outside the existing development boundary for Frome.
  2. ‘Landscape and Visual Impact’ – this development would irrevocably alter the character of North Frome and constitute a significant change to an ancient rural landscape.
  3. ‘Heritage value’ – this site has a rich agricultural past and still boasts notable ‘non-designated heritage assets’ (stone walls, ancient hedgerows, an agricultural structure). They are not ‘just fields’.
  4. Access and traffic implications – congestion, parking, pedestrian safety.
  5. Somerset County Council’s ‘pre-application advice’ in Dec 2022 stated that it had “significant concerns in relation to the suitability of the location, landscape impact, fly nuisance. Based on the information submitted, harms are considered significant and demonstrable that would not be outweighed by the benefit of market and affordable housing delivery.”

CPRE SOMERSET’S OBJECTIONS TO THE APPLICATION

We were fortunate to be joined at our public meeting on 1st June by Fletcher Robinson from CPRE Somerset, the countryside charity, who set out a number of compelling reasons why CPRE Somerset will be objecting to the planning application. You might also find some of these points useful to add, in your words, to your objection. 

Please find attached Fletcher’s speaking notes here: