commentary | weymouthneighbourhoodplandemocracy.org.uk

Commentary on the WNP.

This is the culmination of several years’ work by residents, their examination of the thousands of pages put up on the WTC website and further thousands of pages of evidence obtained under Freedom of Information which had not been made available to residents.

A print copy of the 300-page plan is available from Fleur Graphics for £12.40 (www.fleurgraphics.co.uk 01305 780216). The data on the WTC website is not the same as what has been sent to Dorset Council. Dorset Council are only considering what they show on their own site https://www.dorsetcouncil.gov.uk/w/weymouth-neighbourhood-plan

Dorset Council have said that comments can be made either in writing, through their website portal or by email. The online form will offer you the opportunity to download a pdf version of your response from an acknowledgment email. The online form allows for two attachments (up to a combined 10MB file size) to be uploaded. Should you wish to submit further information these documents should be submitted by email. My own preference will be to use their form (either Word or PDF), pre-complete it with the personal details required and then send it through attached to an email multiple times, each time amending the page number/section referred to and so on. Each time I will be able to say whether my submission is an approval or disapproval or just a comment. I will be able to attach to my emails documents in my possession which I consider The Inspector may not have had sight of.

Weymouth Town Council voted on 26 February 2025, which was lawful this time, and so Dorset Council restarted the Statutory Consultation Period of 6 weeks which will now end on 10 April 2025. Dorset will put the Plan in front of the Independent Inspector with their own comments. Residents addressed the Full Council again on 26 February 2025 and warnings were given to them about Housing Needs, WNP Boundaries and House Building under Policy W23C "Old Tip". Council voted for Old Tip Housing as per page 107 of the Plan even though they were promised on 20 November 2024 that this would be taken out of the Plan. There was a recorded vote and one can see how each Councillor voted on the website of WTC. As to Boundaries and Housing Needs, they were told by the Steering Group that they did not want to delay the Plan to get these things right; there was a point in time when the Plan just had to be submitted and it seemed to residents that it was a case of expediency over accuracy, especially as their vote was perverse with regard to Old Tip Housing being sent forward to Dorset. The Inspector does have the power to recommend that the Plan be suspended whilst the Boundaries are sorted out and better development sites sought for Weymouth. They are clearly there. Everyone is encouraged to comment to The Inspector before 10 April and about getting the Plan right and not just quick.

Unnumbered Page “Foreword” (or this can be made as submission to the “Whole Document” without a page number)

I comment on the Process and the Lack of Democracy in response to the Foreword

My submission is that the Weymouth Neighbourhood Plan (WNP) has been a political process carried out by the LibDem controlled Weymouth Town Council) WTC and, in particular, to support their flagship policy of Affordable Housing. The opening line says that “Weymouth Town Council determined that a Plan was required for the whole of Weymouth rather than individual Plans from each area”. Residents were not asked what they thought but the Government says Neighbourhood Plans (NP) are supposed to be a bottom-up process led by residents and not a top-down process imposed by politicians. Weymouth is not a ‘Neighbourhood’, it is a conurbation of approx 54,000 and a feature running through the published Minutes of the Steering Group (SG) is that the people did not feel engaged about their local area and, as a consequence, it was constantly minuted that engagement was very poor. I will show that the SG relied on an input from just 34 residents for their policies, that is 0.06% of the population.
The leader of WTC is Libdem Cllr Harris and the chair of the SG is Libdem Cllr Northam. Both of these people strongly objected to the democracy of residents of Sutton Poyntz to form their NP. When they did this, WTC voted to reject the SP’s Plan but Dorset Council subsequently allowed it. It is a curiosity, therefore, that there is a plan-within-a-plan and the Sutton Poyntz NP shows within the WNP against the wishes of WTC. Cllr Harris and Cllr Northam did a copy-and-paste submission in opposition “I feel it would be wrong that a small group should be able to declare independence from Weymouth Town, and would like re-assurance that as the Weymouth Neighbourhood Plan is developed, and supported by the newly elected Weymouth Town Council, that it is acknowledged that this may lead to a need to modify the Sutton Poyntz Neighbourhood Plan.” https://www.dorsetcouncil.gov.uk/documents/35024/294468/Sutton+Poyntz+Neighbourhood+Plan+-+Summary+of+reps.pdf/e44be6fc-87ce-07d3-8179-6db48a75bdbf
It has been a feature of the WNP that the SG has worked in secrecy whereas normal business of WTC takes place through democratic committees and these committees meet and discuss in public and the business is video recorded for dissemination and full minutes of decisions are provided. The SG composition was not approved by residents, they have met in secrecy, they change their composition by their own internal elections, are unaccountable to the people, there is dissent within which is voted on in secrecy and not made public. The WNP states: “Steering Group members have supported regular monthly meetings”. “Supported” should say “attended” and these meetings are poorly supported by very truncated public minutes. I hope The Inspector will examine these and agree that they can only possibly have any sense to those people who were actually present.
WTC declared a Climate and Ecological Emergency in 2019. This Foreword talks about “major concern”, “critical” and “flooding in the Town Centre”. The plan was substantially delayed while waiting for Dorset Council to provide current flood information for the town centre. Residents to the east of Weymouth, in Preston, have submitted complaints about flooding to their Council over decades but this area has been ignored by the WNP as regards flooding. It has been known for many years that Weymouth and Preston will be underwater and was confirmed on 24 April 2022 by this link: https://www.dorsetecho.co.uk/news/20090052.areas-weymouth-underwater-2030/
The Foreword goes on to say that the approx. 1,450 Reg 14 Consultation responses have been “analysed” and this led to a mandate of 147 responses in favour of the plan and 141 against (Page 20 of the Consultation Statement). Importantly, Policy W20 of the Plan (previously Policy WNP25) has been omitted from this Statement, but WTC published that there had been about 1450 Reg 14 responses from this Consultation in December 2023. Despite residents FOI requests, and more than 1 year elapsing, WTC have not published a breakdown of this, the largest consultation response over 5 years. Document https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/12/Reg-14-Consultation-Analysis-of-Post-Codes.pdf shows that there is overwhelmingly negative comments from residents affected by flooding to the east of Weymouth.
The closing statement of the Foreword thanks residents for “responding to our surveys that have shaped a plan for all of us”. It has been a feature of the process that the “surveys” were subjective, selective, undemocratic, and rejected when they did not suit the political objective. On the face of it, the SG constantly implored residents to react and comment. In particular for the 3^rd Consultation an inflexible questionnaire was put forward for response, but no free comment allowed. This questionnaire (Survey Monkey) could only be responded to on a basis of ‘1 per household’ not per resident and so as many as half of the residents were not able to respond. WTC subsequently apologised for this and promised to improve. But this consultation achieved the largest ever response of 573 people. Please see page 14 of the Consultation Statement. The SG say that there was “interference” to their process by the very people they implored to comment. The “interference” was that Preston Councillors called a public meeting on 25 Jan 2023 during this very tight consultation period of 17-30 January to explain their concerns that 500 new houses would be built in Preston. The Consultation Statement https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/12/WNP-Consultation-Statement-December-2024-4.pdf at page 14 does not show that from the 573 responses about building 500 new houses 18% were in favour, 64% were not and 18% didn’t know. This is all documented extensively on the site weymouthneighbourhoodplandemocracy.org.uk. The Party-Political leaflets from the time are at https://www.weymouthneighbourhoodplandemocracy.org.uk/the-leaflets. Cllr Northam reported the Preston Councillors to Jonathan Mair, the Dorset Director of Legal & Democratic (Monitoring Officer) for sanction for their behaviour. Cllr Harris wrote that the Preston leaflet was “lies” as to the 500 houses, but the figure subsequently became apparent at 570. Mr Mair refused to become engaged in this. Cllr Northam then wrote to Locality for their advice, they responded with the advice “you might also want to re-survey individuals to gauge their views on the sites”. This is all shown at https://www.weymouthneighbourhoodplandemocracy.org.uk/dorset-council-democratic-director and https://www.weymouthneighbourhoodplandemocracy.org.uk/my-letters-to-the-dorset-officer-for-democracy. He did not do this. Instead, he organised the 4^th Consultation which resulted in a response from 34 residents (0.06%) across the whole of Weymouth and just 9 people from Preston. The Preston session was held on a Bank Holiday Friday afternoon in late August 2023, with little or no publicity and the admission that the advert for the Dorset Echo had “been delayed” somehow.
To this day the SG have refused to meet with residents from Preston wanting to engage with them on a resident-to-resident basis to inform them of the particular difficulties in the area for people making decisions when they don’t live there and seem to work from a paper-based 2-D view of the area and allocated housing sites which they have never visited and have refused site meetings with concerned residents. Mr Cheeseman has been a member of the SG since its inception and he wrote in the Dorset Echo on 22^nd May 2024 (https://acrobat.adobe.com/id/urn:aaid:sc:EU:edc3a30c-0dc4-4c62-85a1-a8211c97cca0?locale=en-US&x-product=AdobeHome%2F1.0&guid=521eeed3-fd99-4ea7-80c4-e0e6e0b5e2cd&mv2=ahome&viewer%21megaVerb=group-discover ) “if you want to talk to us about the plan and its contents then you can come and talk to us”. His comments about the “wealthy and vocal residents of Preston” said it all. I have been trying to meet with the SG since my email of 11 April 2024 and so Mr Cheeseman’s words are disingenuous. The Chair of the SG, Cllr Northam, also assured Weymouth Town Council in Full Council on 20^th November 2024 that he would meet with residents but has refused to do so since.

Page 1

Para 1.1. “applies to the parished area”. In April 2024 the boundaries of Weymouth were changed to the north and west and, in particular, a very large area added to the north, shown in orange https://acrobat.adobe.com/id/urn:aaid:sc:EU:4b9e096d-5725-4d9a-93c7-a1fef6dea893?locale=en-US&x-product=AdobeHome%2F1.0&guid=9b953cf7-f1d7-4fcb-a060-7915e69c40e3&mv2=ahome&viewer%21megaVerb=group-discover . This now brings in the substantial 500+ new houses at the development Bincombe Park, who should not now be excluded from the WNP. There are no policies for this significant new area. It also leaves a substantial area adjoining Bincombe Park to the east which appears to be far more suitable for development than the W20 Policy site “Wyke Oliver” just to the south across Littlemoor Road. It would now be possible to both build within the WNP at W20 as well as apply to build to the north opposite because it would not be protected by NP policies. Indeed, there is already a prominent advertising board displayed by DJ Developments offering this land for speculation. It is also not disclosed in WNP that Dorset Council (officers Nick Cardnell and Ed Gerry) have agreed that housing needs do not need to be confined to Map 1. Therefore, the WNP is already obsolete and should be paused and re-considered under these new boundaries and all the development possibilities that come from that. At a Full Council meeting of WTC held on 26 February 2025 boundaries were again raised by the public but Councillors voted to proceed with the outdated boundaries. There was a crucial meeting held between WTC and DC on 31 May 2024. https://docs.google.com/document/d/1-e1FZvlfjEwjkdPV0AsDQvx968PUvDGd?rtpof=true&usp=drive_fs

This shows the concerns from WTC about boundaries prior to that meeting and in particular about the opportunities now possible on the northern boundary and the inclusion of the 500+ houses at Bincombe Park to be brought into the Plan. It reflects the difficulties WTC had had in identifying suitable development sites, the preponderance in the Preston area and the Party-Political difficulties between the LibDems controlling WTC and the Conservatives controlling Preston. The final agenda was drawn up to exclude these issues since it would have meant pausing the Plan whilst the obsolete boundaries were sorted out. Nick Cardnell from DC has said that the agenda change was at the behest of WTC and not from the DC side.

“Jurisdiction of Weymouth Town Council”.

In 2024 the Weymouth town clerk wrote repeatedly that the WNP was not WTC, it was run by a “Steering Group” who were unaccountable, unelected, met in secret without any public scrutiny, changed membership by their own internal elections and people came and went. The wording used was: “The production of the Neighbourhood Plan is led by a steering group, not Weymouth Town Council”

Para 1.2 “Sutton Poyntz Plan is respected”. The Libdem Leader of WTC Cllr Harris and the Libdem chair of the Steering Group fought hard against the Sutton Poyntz NP saying that they should be able to decide their own future but should subside into the Weymouth Conurbation. As a result, the SP NP was voted down by WTC and only allowed by the intervention of Dorset Council. No other areas of Weymouth were to be allowed to have their own NP’s by edict of WTC. https://www.dorsetcouncil.gov.uk/documents/35024/294468/Sutton+Poyntz+Neighbourhood+Plan+-+Summary+of+reps.pdf/e44be6fc-87ce-07d3-8179-6db48a75bdbf

Para 1.4 “Strategic Policies in the Local Plan” There is no definition of this, but it is assumed to be the 228-page document West Dorset, Weymouth & Portland Local Plan 2015. This document is not shown to be listed for consideration by WTC or DC among the thousands of pages listed for comment and so the WNP can only be properly considered when laid against the West Dorset, Weymouth & Portland Local Plan 2015

Page 3 Map 1. This map is obsolete and believed to have been replaced by map in April 2024 with changed boundaries and officers of Dorset Council Nick Cardnell and Ed Gerry have confirmed that development need not be confined to the old parish boundaries of Weymouth. https://acrobat.adobe.com/id/urn:aaid:sc:EU:4b9e096d-5725-4d9a-93c7-a1fef6dea893?locale=en-US&x-product=AdobeHome%2F1.0&guid=9b953cf7-f1d7-4fcb-a060-7915e69c40e3&mv2=ahome&viewer%21megaVerb=group-discover .

Page 5 para 2.3 “Lodmoor have extensive reed beds and areas of open water from the flood plain”. This is not correct and Lodmoor is not “open water” or a “flood plain” under this definition but it is part of the sea with a causeway built across it and as such should be designated as “tidal water” as the sea pours in out on every tide through the many interconnectors which have no sluice gates or any preventative controls

Page 6 2.10 and 2.11. Preston is described as lacking community facilities and Overcombe is described as “access to services and jobs is somewhat limited”. Yet at Policy W20 the largest single housing development in the WNP is to be put there

Page 7 Para 2.14 “Preparing a Neighbourhood Plan for an area of the size of Weymouth ….is challenging”. This is because Neighbourhoods were not to be allowed to have NP’s once Sutton Poyntz had done that and it was a political decision of WTC to refuse that and to impose a Neighbourhood Conurbation without the agreement of the people. This para refers to Key Findings and Messages Document https://www.dorsetcouncil.gov.uk/documents/d/guest/weymouth_np_key_findings_and_messages . The very first sentence of this document says: Key Local Findings from the Evidence: • The neighbourhood area is a series of distinct settlements and communities each with their own unique identity

Page 12 para 3.8. The WNP does not consider other relevant documents because it runs counter to their plans for development. In particular, the SEA on Policy W20 limits itself to about one-half of the number of houses contemplated and ignores the conflicting work done in the years before:

https://www.dorsetcouncil.gov.uk/documents/35024/296265/Sustainability+Appraisal.pdf/86f627ea-0374-adf7-a5e3-a19101a23f50 as a combined Site G on page 48. February 2017

https://www.dorsetcouncil.gov.uk/documents/35024/296265/20180802+-+Sustainability+Appraisal+Preferred+Options+%28FINAL%29.pdf/4c515ee5-159c-4b10-d646-24ec390b9735 at page 80, August 2018

https://www.dorsetcouncil.gov.uk/documents/35024/307470/DCLP-Jan-2021-SA+reduced.pdf/00cdaaf8-87f8-e74e-0ac0-423383e50467 . Site WEY G had reappeared at page 180(pdf page 183). January 2021

Page 16 para 5.9. The SEA is deeply flawed, especially with regard to Policy W20 because it considers only one-half of the number of houses to be built. This is dealt with in a separate Commentary on SEA.

Page 19 Blue Aim “Climate Change Management” says “All new developments are expected to result in no increase in the risk of flooding and provide resilience to extreme weather events”. This conflicts with Policy W20 where evidence has been provided (but not included in any part of the WNP) that shows present and historic flooding can only be exacerbated by flooding through reducing infiltration land with buildings and taking no account of the LLFA advice that provision must be made for a 45% increase in surface water run off caused by Climate Change. No attempt on W20 has been made to address water for this development which lies in a Flood 3 Area and can only disgorge to other Flood 3 areas.

Page 20 Aim 1: “establish an appropriate mix of dwellings on new developments”. The figures shown in WNP are that there is a demand of 60+% for 1-bedroomed homes but Policy W20 achieves its viability approval by assessing it for about 6% of 1-bedroomed homes.

Page 21 Aim 2: “Aim 2: - Allocate sustainable sites for new homes and jobs which are within walking distance to town or a neighbourhood centre”. Policy W20 is not within walking distance of either a town or a neighbourhood centre. This is shown in the Commentary on the SEA https://docs.google.com/document/d/1WAZZRlawNM1jp0NAHLVhf65-ptyvT4NK?rtpof=true&usp=drive_fs on the maps at https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs

Page 22 Aim 5 “Reduce Car Movements”. On Page 56 of the SEA https://www.dorsetcouncil.gov.uk/documents/d/guest/weymouth-np-sea-environmental-report-november-2024 It is clear that site W20 has “the likelihood of (sic) bring forward high private vehicle use.” Throughout the report on this site, the consultant makes these comments based on just 112-135 new homes (p52, p54,) whereas the WNP pencils in 250 homes and the (now-departed) developer was asking for 270 homes

Page 23 Para 7.2 “rising sea levels”. No consideration has been made in the plan about this except for the town centre. The flooding areas to the east of the town and particularly the River Jordan and Preston Brook have not been considered. There are constant government flood warnings to residents about this (floodline.uk/111WAFWEYR, latest flood warnings were issued on 23 and 26 November 2024 and 4 December 2024) and the flood map on page 65 makes this clear, as well as the proposed W20 development site voiding into Flood Zone 3 areas without any mitigation being put forward. This is unsound.

Page 23 Para 7.3. This says: “Consistent with the Town Council’s declaration and action plan is the preparation of a Neighbourhood Plan that promotes sustainable development and is pro-active in its approach to mitigating and adapting to climate change, including building community resilience by taking into account the long-term implications for flood risk, coastal change, water supply”. The definition of Sustainable Development is that existing residents should not be put in harm’s way by new development. Policy W20 would do this with flooding and increased raw sewage discharges to bathing waters.

Page 23 para 7.4 “Wherever required, it also means physical flood protection and effective sustainable drainage systems”. In regards to W20, none of this has been done. The Viability Report https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/11/Weymouth-NP-Viability-Report-Compiled-Sept-2024.pdf at page 11 states: “We cannot test the impact of flooding prevention costs. What we can do is identify the potential scale of spare capacity – or “headroom” into which such a policy might be inserted.” At around pages 79 (the page numbering of the report ceases at this stage in Appendix 3) it shows clearly that the budget for a turnover of £70,360,182 can only make a profit of £100 and so there is no “headroom” for SUDS and therefore this Allocated Site should be dropped. The developer has walked away from it. The housing mix is distorted with 7% of 1-bedroomed houses whereas the identified need is for 66% of 1-bedroomed and it is believed this unsuitable mix was chosen to make the site artificially “Viable”. These figures are shown on page 75 on the Plan in the tables.

At page 75 of the SEA. https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/12/Weymouth-NP-SEA_Environmental-Report-November-2024.pdf it says: “Land at Wyke Oliver Farm North – A small strip of land in the middle of the site, to the west of Wyke Oliver Farm, is within Flood Zone 2 / 3 and at medium / high risk of surface water flooding. In addition, the site borders an area of land within Flood Zone 2 / 3 and at medium / high risk of surface water flooding to the north.” This report is completely flawed because it repeatedly refers to W20 on pages 52, 54 as having a capacity of 112-135 homes whereas the Plan calls for 250 homes and the developer (now quit) wanted 270 homes (Reg14 Morrish Homes). W20 used to be called WNP25 and before that WEY14. It was one and part of WNP24 (since dropped, citing the SEA as its reason) which was for 240 homes. Therefore, the SEA has wrongly cited all its criteria on one half of the proposal and its weighting, therefore, is deeply flawed. WNP24 (as the same field) has 4 red flags out of 8 (see page xiii) (A) based on 240 homes and W20 (page xiii) (E) has 6 “uncertains” or not knowns out of 8 criteria, 1 red flag and 1 “no effect”. It has no “positive effect” on environment at all. Clearly, had the consultant based the findings on 250/270 homes the findings would have been different. This conflicts with page 77 of WNP at para 9.14 which states: “Affordable Homes (at 50% for 400 homes) outweighs the adverse impacts identified in the SEA”. This figure of 400 is false if one adds the consultant’s 112-135 together with Policy W21 Redlands at 150 homes, gives 262 to 285, not 400.

The same consultant AECOM in its Final Assessment Report https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2023/01/Weymouth-Neighbourhood-Plan-Site-Assessment-Final-Report.pdf at page 165 and 166 discounts the W20 site in its Conclusions: “The site is located outside the development boundary and within land of local landscape importance and an important open gap. Unacceptable landscape impacts. An unsuitable site. Suitability: The site is located outside the development boundary and within land of local landscape importance and an important open gap. Existing development is already intrusive; particularly areas on upper slopes. Unacceptable landscape impacts. Farm buildings could be converted, development unacceptable in undulating and elevated open landscape.”

The WNP Character Area Assessment https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/11/WEY-Character-Asassessment-2021.pdf at pages 7 and 9 confirms: “Lodmoor Nature reserve and an area to the south of Broadway and north of Nottington have large areas prone to flooding”. These reasons are listed as a Constraint on the Plan.

In contradiction to this AECOM report, the 2017 West Dorset, Weymouth & Portland Local Plan Review of 328 pages, https://www.dorsetcouncil.gov.uk/documents/35024/296265/Sustainability+Appraisal.pdf/86f627ea-0374-adf7-a5e3-a19101a23f50 equates closely with Policy W20 as “Area G” at pages 48, 50 and 51 shows site W20 to have 6 red flags out of 11 criteria, 4 neglible effects with housing as the 1 positive effect. The red flags were for: Biodiversity, Water, Air, Climate Change, Flooding & Coastal Change and Landscape. The conclusions drawn on page 51 were: “8.1.7 The River Wey and its tributaries, and the flood plains associated with this river system and other surface water features surrounding Weymouth, occupy large areas of the land surrounding the town. Development would result in adverse impacts upon water quality and expose property and residents to flooding in areas to the west of Broadwey and Redland (areas I and K), in those areas surrounding the Lorton Valley Nature Park (areas F and G), around Preston (areas A and B) and the coastal areas to the West of Weymouth (areas M). It says further: “8.1.9 In terms of landscape impacts, whilst the more central areas of Weymouth are not designated as Dorset AONB, areas to the north, east and west are. There are a number of open gaps which are of aesthetically importance, as well as maintaining local character, such as the gap between Sutton Poyntz and Preston, and between Littlemoor and Preston/Overcombe. The coastline both to the east and west of Weymouth is designated as the East Devon and Dorset World Heritage Site.” W20 is the same field as the Policy WNP24 which was dropped for the reason given that it failed the SEA test with 4 red flags out of 8, 2 neutral and 2 uncertain. It is clear that, had the SEA Consultant proceeded correctly with an analysis of 250/270 homes instead of halving it to 112-135, the conclusions would have been very different and, dare one say, identical to WNP24? WNP24 has changed names and boundaries many times over the years of failed development attempts and in this same 2017 report, at pages 53 and 54, it is labelled W1 and broadly equates to WNP24. Consistent with this recent SEA report, it scored then 5 red flags out of 11 criteria, only 1 positive effect (housing) and 5 neutral effects. The conclusion stated at page 54 under 8.2.6 was: “Development at Option W1 would greatly decrease the width of the wildlife corridor between Lodmoor SSSI and Lorton Valley Nature Park and the open countryside to the north, resulting in significant effects upon biodiversity. Also, W1 is adjacent to the Lodmoor SSSI and Lorton Valley Nature Park, and development here may increase recreational pressure, resulting in significant impacts upon these wildlife designations”

Page 24 Para 7.9 This is the key statement about Policy W20 in the whole document: “Any plan made now that does not consider radical reductions in carbon and help build our resilience to things like flooding will simply not be fit for purpose”. W20 only exacerbates the Flood Zone 3 problems immeasurably and so the WNP is not “fit for purpose”

Page 25 Objective 4 (26) Sustainable drainage Systems. The steeply sloping site is unsuitable for normal SUDS and the Viability Report shows this factor has been omitted from costings in order to artificially make it “Viable”. The water can only go into an already overloaded and flooding culverted system 1058m long and cause more flooding at the site in Flood Zone 3 and further downstream in Flood 3. See Reg 14 comments from LLFA and Wessex Water. Further, this water can only discharge into the Lodmoor Reserve, which is a nationally significant protected site (see page 31 8.18 and map 6 page 33) and so, even if SUDS were possible, the costs would be far higher because the water would need to be cleaned before discharge.

Page 28 Para 8.11 “The area’s greenspaces play a significant role in flood alleviation. Many are low-lying and prone to flooding”. This is clear for Policy W20 and removing this area of infiltration, but changing it to highspeed run-off due to its inclines, will not lead to flood alleviation.

Page 30 Para 8.13 “Para 177 of the NPPF requires plans to avoid inappropriate development in vulnerable areas, whilst not exacerbating the impacts of physical changes to the coast”. Policy W20 is a vulnerable area in Flood 3 and the Lodmoor Reserve is part of the sea and the coast and will be physically changed by W20 discharges.

Page 30 Para 8.16. Flooding has only been considered for Weymouth Town Centre and the area to the east of Greenhill has been ignored even though it is Flood Zone 3

Page 31 Policy W02. (2) “Any development brought forward must ensure that it can be implemented with adverse effect upon the integrity of the Habitat sites. Proposals that will adversely affect the integrity of Habitats will not be supported”. Development site W20 conflicts with this through water discharges in Flood 3 of uncleaned water. Sewerage is avoided in the WNP as being outside its remit. W20 will discharge sewage into an overloaded system which has increased its untreated “emergency” discharges by 100% at Bowleaze Cove (Environment Agency site WSX0770 from 20.3 to 39.9 between 2021 and 2023) and Melcombe avenue (EA site WSX0989 from 3.07 to 6.57 between 2021 and 2023). Wessex Water has said that improvements are unlikely until into the 2040’s so the entire life of this Plan is blighted. All this sewage sweeps from east to west in Weymouth and Ringstead Bays through a quirk of currents at all states of the tide https://images.app.goo.gl/tfqJnWfJoZVdUaiYA and so is immediately thrown onto Weymouth Town Beach, a premier bathing area which has just lost its Blue Flag award through presence of sewage https://www.dorsetecho.co.uk/news/24837673.weymouth-beach-risk-losing-blue-flag-status-due-pollution/

Page 36 para 8.30. “Development impacting national and locally important sites will only be supported in the most exceptional and unavoidable circumstances”. Is Policy W20 really these circumstances when more suitable development sites are available nearby but are not within the 2020 Plan Boundaries chosen?

Page 75 Housing Needs for 1-bedroomed properties. This shows the need at 66% but the Viability Report https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/11/Weymouth-NP-Viability-Report-Compiled-Sept-2024.pdf has been calculated for Policy W20 at 6% need for 1-bedroomed

Page 77 para 9.14. the statement “Affordable Homes (at 50% for 400 homes) outweighs the adverse impacts identified in the SEA.” is false if the consultant’s figures of 112-135 for Policy W20 is added to the figure of 150 homes under Policy W21 so is the figures 262-285 and not 400.

Page 78 Policy W14. In the April 2023 draft plan https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2023/10/Weymouth-NP-Initial-Draft-April-2023.pdf at page 61 It was stated: “Development shall be focused within the defined development boundary as identified in the Plan”. In 2024 the boundaries of Weymouth were altered to include land which would have been more appropriate for development and this could have been incorporated into the Plan, according to emails from Ed Gerry and Nick Cardnell at DC in May 2024. But the policy W14 has not been adapted to take into account the 2024 boundary changes. Policy W14 further says that: “Development on brownfield sites….shall be prioritised” but all previously identified Brownfield Sites have not been pursued and policy W19 shows all Residential Development taking place on Greenfield sites”.

Page 78 para 9.21 Page 88 Para 9.45 If one looks at the previous draft of the Plan https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/11/Weymouth-Neighbourhood-Pre-Submission-Plan-v2.5.1-1.pdf at page 70 under 9.51 “Sites allocated for development by policy WNP23 have emerged as those most supported by the community to achieve our housing objectives.” We can see the untruth that the community supported those housing objectives. This has now been quietly corrected and dropped.

Page 94 Policy W20 at (4) states: “Development proposals should conform with relevant policies in the Neighbourhood Plan and satisfactorily address the following criteria: “iv. a drainage regime that minimises flood risk and the impact of the development on local water courses; “viii. alignment with the environmental objectives and targets of the Neighbourhood Plan”. It is a Development Proposal but there is no drainage regime provided that minimises flood risk, indeed flood risk has not been addressed at all by any of the consultants. Nor has the impact on Lodmoor Reserve as the water course to receive all the flows. It is in conflict with the following environmental objectives and targets of the Plan:

W01 Shoreline Protection

Para 8.13 says: “para. 177 of the NPPF requires plans to avoid inappropriate development in vulnerable areas, whilst not exacerbating the impacts of physical changes to the coast.” Policy W20 can ONLY drain into the Flood Zone 3 Lodmoor SSSI, which is a sea marsh already liable to flood by 2030 https://www.dorsetecho.co.uk/news/24516938.areas-weymouth-portland-underwater/ and so W20 will add to flood risk and loss of LVNP to the sea

W02 Conservation of the Natural Environment

This Policy says at (1): “country parks, nature parks and reserves must be retained and protected from detrimental negative impacts likely to arise from development.’ Policy W20 can only void into the LVNP SSSI and country park of national significance. The run-off also has the potential to bring pollution to a nature site. The sites are confirmed at 8.18. At 8.20 it says Policy W02 “not only protects existing designated areas”. It does not protect LVNP of 8.18. At para 8.21: “Policy W02 supports all measures to enhance the resilience of all the protected sites and to gain and maintain a favourable condition for all SSSI sites in accordance with UK government's 25 year environmental plan, 2018.” Policy W20 cannot enhance the SSSI it can only be detrimental.

W03 Wildlife Habitats and Areas

At para 8.30 it says: “Development impacting national and locally important sites will only be supported in the most exceptional and unavoidable circumstances”. Development at Policy W20 could simply have been avoided had the WNP considered areas outside of the parish boundaries, as it was entitled to do. In 2024 the boundaries of Weymouth were changed to bring in some of this land but that has not been reflected I the Plan, e.g. Bincombe Park of 500+ houses at Littlemoor.

W04 Wildlife Corridors

Policy W20 conflicts with policy W04 because the wildlife corridor will be reduced in width to approx. 130m, house-to-house, (Map 19 page 96) and this is not sufficient to retain wildlife such as deer, who will not approach to within 65m of noisy development, traffic etc.

W09 Green Gaps

At Para 1 and 3 it is clear that development should not bring “coalescence” or alter the “landscape character”. This is expanded at para 8.66. Site W20 conflicts with this because the significant existing green Gap is to be closed down to 165m wide (Map 12 page 96). Site W20 scores a red flag https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/12/Weymouth-NP-SEA_Environmental-Report-November-2024.pdf at page 55 (page 77 of pdf) which says: “The open nature of the site extends south, and it is considered that development could set the precedent for urban sprawl / coalescence effects, closing the existing gap between development to the east and west. Overall, negative effects are considered likely if this site is allocated. This reflects the potential negative impacts on the National Landscape to the north, and the loss of open greenfield land that forms a gap between development to the east and west. Development here has the potential to bring forward urban sprawl effects to the south.” There has been eastwards creeping infill by development at Littlemoor (Lodmoor Sands) towards W20 because W20 was always protected. There should be no further westwards creeping infill as coalescence.

At para 8.60 the Plan states: “The site allocation arising from policy W20 provides for future protection of the remaining gap through transfer of 23 Hectare of land to Lorton Valley Nature Park.” This may not necessarily be true, and the Plan has not been altered to reflect that site WNP24 was dropped and will remove the connection from W20 to the LVNP. There is no update shown from either Dorset Wildlife Trust or the SSSI that they are prepared to take on the land as an isolation, nor from any developer showing willingness to make the financial contribution to such bodies to maintain these 23ha.

W12 Riversides

At (3) it is stated: “Development proposals should be accompanied by a site-specific Flood Risk Assessment.” Policy W20 is a development proposal but no Flood Risk Assessment has been provided and so the WNP should not have the effect of changing the Development Boundary of Weymouth unless and until it can be proved that W20 will not cause more risk of flooding. At 8.79 it talks of “flooding because of tidal effects” (Map 14 page 65). There is a distinct difference not shown for the Lodmoor Flood Zone because it is sea marsh where the levels rise and fall with every tide. The rest of Weymouth Flood 3 causes flooding mainly by surface water run off not being evacuated to sea, either because of sea levels or high rainfall but the Lodmoor Marshes and main arterial road Preston Beach Road could be lost to the sea by 2030 https://www.dorsetecho.co.uk/news/24516938.areas-weymouth-portland-underwater/ At 8.80 it says: “ The NPPF (para. 165) makes clear that inappropriate development in areas at risk of flooding “should be avoided”.”

W14 Development Boundaries

At para 9.21 it says: “Any development proposals that are considered permissible should be accompanied by a landscape character assessment to establish that there will be no adverse visual impact on the character and sensitivity of the landscape.” This has not been done for Policy W20, or if it has in the form of the SEA, W20 fails with a red flag for Landscape

W16 Major Housing Sites

Under Policy 2 it says: “Development proposals should take account of the concept of ‘Walkable Neighbourhoods’ and include links to new or existing community facilities that will promote walking, cycling and sustainable transport”. Policy W20 is in conflict with this because it will promote private car use as shown in the SEA for the site on page 56 of the AECOM report: “This reflects issues with access as well as the likelihood of (sic) bring forward high private vehicle use”.

Under Policy 3 it says: “application should be accompanied by an appropriate landscape and visual impact assessment,”. This has not been done, or if it has been done under the SEA report, it attracts a red flag at page 33 in the AECOM report

Policies 9.30 and 9.31 are conflicted by Policy W20 with regard to Walkable Neighbourhoods. We rely on pages 34 and 56 of the SEA Statutory Report, which compares Transportation. This was given a Red Flag to WNP24 and an “uncertain” flag to W20/WNP25. It was not given as a criterion in either the 2017 or 2018 Review of Dorset Local Plan reports.

A. It is a nonsense for W20 that: “This allows for access to services in the centre via the B3159.” This is illustrated on maps 4 and 5 https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs. If the footpaths were even in existence (which they are not) google earth shows it to be well in excess of 2km by foot to reach the B3159. Nor is the B3159 reachable by bus. It is a nonsense (map 6) that “There are bus stops in proximity to the northern site boundary – approximately 75m to the north”. The bus stop to the north is shown on Map 6A as 255m from the centre of the northern part of the site and either impossible or much further from the southern part of the site. There are no services from this stop which go along the B3159. Just a few times a day it might be possible to catch a bus to Dorchester from this stop, then change route further along the line at Littlemoor for the B3159 bus to Weymouth. Even the bus stop shown closest to the northern part of the total site (the southern part of the site is much further) would also involve great elevation changes of at least a 10-storey building, make it further unwalkable. No account has been taken of changes in elevation in the area. The bus stop at Charlbury Corner, for example, is at an elevation of 13m and the top of the site is 40+m. Walking around the hills would add many hundreds of metres instead of the “as the crow flies” approach (Map 7 at least 723m). Map 8 shows that the statement in WNP24 on page 34 is misleading that the nearest bus stop was 740m away. This might have been to the entry of the site, but Map 8 shows the median point to be 885m away and the end of the site to be about 1000m away.

B. Page 82 of WNP at 9.30 suggests that a “walkable” neighbourhood should have facilities “within 800m”. Dorset Council has no policy on this in NP’s since each site is different. This particularly applies to W20 with the very large changes in elevation, making both walking and cycling very challenging. Policy suggested by Sustrans in 2022 https://www.sustrans.org.uk/our-blog/research/walkable-neighbourhoods-building-in-the-right-places-to-reduce-car-dependency/ was that “LPAs should develop Supplementary Planning Documents that set accessibility standards based on 800m walking and wheeling distances to key services, and 400m to bus stops.” Map 9 shows the practicable bus stop at Charlbury Corner to be no less than 800m away using a mixture of “crow flies” and existing roads, evidently final site design will make this much further.

C. In giving an “uncertain” status to W20, the SEA report concludes there will be: “high private vehicle use” to the site for the above reasons, in contradiction to Policy W51, Traffic Impact: “Development proposals to reduce the volume and impact of motor vehicles” therefore making the site unsustainable for Transportation. The Maps referred to above are available at https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs

W17 Housing Mix

This policy states: “The proposed housing mixes on major sites should be based on an up-to-date local housing needs analysis.” The Plan figures on page 75 show the need is for 66% of 1-bedroomed homes but PolicyW20 has been worked for Viability by considering only about 6% of 1-bedroomed homes.

W18 Affordable Housing

This policy says at 2(i): “the proposals meet the minimum target of at least 35% affordable housing on brownfield sites and at least 50% on greenfield sites unless a Financial Viability Assessment or other material consideration demonstrates a robust justification for a different percentage.” The 50% on greenfield sites is a requirement of national legislation and is not open to variance by the WNP, particularly by something as loose as the assessment referred to, which has no criteria. This site cannot be treated as an Exception Site as it lies outside the DDB and Dorset Council policy states in their document https://moderngov.dorsetcouncil.gov.uk/documents/s21982/20201208%20-%20Section%204%20-%20Housing.pdf :

“4.4.1. An exception site is a small site that is allowed as an exception to normal local plan policies, in areas where housing would not normally be permitted, in order to deliver affordable housing in perpetuity. Requiring these exception sites to provide 100% affordable housing keeps land values relatively low, helping to meet identified local housing needs. 4.4.2. Exception sites should be small scale (proportionate in size to the existing settlement) and located within or on the edge of villages or towns. Small-scale exception sites within the green belt may be appropriate in accordance with national policy for green belt and the impact of the proposal on the Green Belt purposes. Larger-scale sites that could result in unbalanced communities are not normally acceptable as exception sites.

4.4.10. National policy indicates that small numbers of market homes may be permitted on rural exception sites at a local planning authority’s discretion. This is not supported because it: would reduce the likelihood of 100% affordable housing sites being delivered”

Policy W20 cannot be an Exception Site because it is neither small nor 100% Affordable.

W19 Site Allocations

At point (2) the WNP says: “2. Support for development proposals on each of the allocated sites will be subject to them satisfying the criteria set out in their respective Neighbourhood Plan policy and conforming to all other relevant Policies in the Neighbourhood Plan.” We are showing that site W20 conflicts with so many other policies of the WNP.

Para 9.45 has been altered from the previous text in the October 2023 draft at para 9.51 on page 70 (page 73 pdf) which said: “Sites allocated for development by policy WNP23 have emerged as those most supported by the community” https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/11/Weymouth-Neighbourhood-Pre-Submission-Plan-v2.5.1-1.pdf . Clearly democracy has been failed because there is no support from the community for Policy W20.

At para 9.50 on page 89 of the WNP it says that the selection of sites to be allocated was made after the SEA Environmental Report. This report is deeply flawed for site W20 as it considers only 112-137 houses instead of the 250-270 allocated in the plan. An exhaustive Commentary on the SEA has been made. The Maps referred to are at: https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs and the text is at https://docs.google.com/document/d/1WAZZRlawNM1jp0NAHLVhf65-ptyvT4NK?rtpof=true&usp=drive_fs

At para 9.52 on page 89 it says: “The criteria of the individual allocation policies that follow, reflect the need to address the identified development constraints of each site and ensure that the resultant development is suitable, sustainable, and beneficial for neighbourhood area, as well as satisfying the requirements of NPPF para. 135, which states that developments should: • function well and add to the overall quality of the area • be visually attractive as a result of good architecture, layout and landscaping • be sympathetic to local character and history, including the surrounding built environment and landscape setting • establish”. It is shown in the SEA report that the site W20 is not sustainable because of the red flag for landscape. The SHLAA assessment says that this site is not suitable.

At para 9.54 on page 90 it says: “To meet the local affordable housing need 3 sites are allocated on Greenfield sites across 16.7ha providing 425 Homes with 212 Affordable (70% to Rent, 30 to Buy). The loss of Greenfield land is compensated for by adjacent land 31.9ha being allocated for either Public Open Space or added to the Lorton Vally (sic) Nature Park. This preserves Green Gaps and wildlife corridors between Littlemoor and Preston”. Having dropped site WNP24 from the Plan, it is no longer sure that the 23ha of land at Site W20 can be transferred to the LVNP. The chart Table B on page 92 is also wrong.

W20 Land at Wyke Oliver Farm North

At para 9.50 on page 89 of the WNP it says that the selection of sites to be allocated was made after the SEA Environmental Report. https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/12/Weymouth-NP-SEA_Environmental-Report-November-2024.pdf This report is deeply flawed for site W20 as it considers only 112-137 houses instead of the 250-270 allocated in the plan. An exhaustive Commentary on the SEA has been made. The Maps referred to are at: https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs and the text is at https://docs.google.com/document/d/1WAZZRlawNM1jp0NAHLVhf65-ptyvT4NK?rtpof=true&usp=drive_fs This shows that there is no possibility of Site W20 having “adequate provision” for public transport.

Map 19 at page 96 of WNP shows 2 distinct sites within the site. It shows only 1 vehicle access for the northern sector and none for the southern sector. It shows that this would not be possible without demolishing existing property. There is no access possible between the 2 sectors as there is a buried foul sewer and a pressurised sewer in this valley, shown at Map 10 https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs . In their Reg 14 response, Wessex Water https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/11/Wessex-Water-Response-Weymouth-Neighbourhood-Plan-Reg-14-Consultation-Feedback-Form-Dec-2023_.pdf say: “Draft Policy WNP25: Land at Wyke Oliver Farm North There is an existing pressured pumping (rising main) which crosses the proposed development site. There must be no building over or near the main. This is to ensure that buildings do not damage the pipe and to enable continued access for future maintenance and repair.”

At Policy 4(iv) it states: “a drainage regime that minimises flood risk and the impact of the development on local water courses;”. There is a ‘Development Proposal” but nothing to “address this criteria”. There is a detailed budget for the site in the Viability Assessment https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/11/Weymouth-NP-Viability-Report-Compiled-Sept-2024.pdf at pages 89-96 of the pdf in the Annexe 3 and 3b which shows the site having a profit of no more than £100 on a turnover of £71,185,402. The developer has now walked away from the site. There is no allowance shown for the obligatory contribution to maintaining the 23ha of land supposed to be ceded to LVNP nor for any sewerage contribution to Wessex Water in respect of upgrading the present overwhelmed system where the EA shows emergency discharges to local bathing waters has doubled in the past 2 years. There is commentary at page 10 of the report as follows: “It is obviously impossible to test the financial impact that the imposition of an unknown share of an unknown cost might have on the viability of ordinary development. Moreover, viability assessments are required to test the impact of policies that are known in effect now and those that are proposed in the document under review – the Neighbourhood Plan. We cannot test the impact of flooding prevention costs. What we can do is identify the potential scale of spare capacity – or “headroom” into which such a policy might be inserted.” This makes it clear that SUDS has not been considered and that, with a profit of only £100, there is no “headroom” for it. Since the effect of passing the WNP would bring this site from outside the DDB to inside it, Policy W20 should be excluded NOW because it is simply not deliverable or achievable. This artificial concept of "Viability" does need to be put against real world concepts. The Map 19 on page 96 of the WNP does not show contours. This is shown at: https://drive.google.com/open?id=1-UuXf1EjivhoPRdG_VT8mObv1mAf93CO&usp=drive_fs The southern slope of the northern section and the northern slope of the southern section both slope steeply downwards into the Flood Zone 3 shown on page 65 of the Plan. All surface water flows must go into that valley since SUDS and Attenuation Ponds do not work on the steep slopes of hills. However, no SUDS can be built in that valley since Wessex Water make it clear that can be no building on or near their buried foul sewer and pressurised sewer in that valley, as shown on page 10 of these maps: https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs . Therefore, there will be loss of whatever infiltration there is currently on these slopes, but the water will rush downhill into the flood 3 Zone. Wessex Water have said that all water needs to be dealt with on site and the LLFA agree that the downstream system is severely at risk, with proven flooding already of houses below.

The Viability Report does not cover the subject of National Policy about the Building Safety Levy. In 2022 this was reported as being around £2000-£3000 per new house but recent figures for the south of the country put this nearer to £3000-£5000 per house. Final Government figures are awaited.

At Policy (5) and para 9.63 and 9.67 there is reference to ceding 23ha to the LVNP but this is unlikely to proceed as site WNP24 was dropped and there is no access from W20 to LVNP. It is unlikely this 23ha can exist in isolation from the LVNP. 9.67 says this is Map 20, but it is not. It is Map 19.

At para 9.61 it says: “Following a robust analysis and selection process, which included community consultations”. It does not show that the community is overwhelmingly against development at this site because of flooding. In the third consultation https://www.dorsetcouncil.gov.uk/documents/d/guest/3rd-engagement-report at page 3 it shows some percentage figures to questions 7and 8 and that 573 residents took part. This was the largest ever response from the community until it was exceeded by the formal Reg14 consultation. This showed that 64% of the community was against development on land outside the DDB, such as W20. It shows 137 people responded before a public meeting on 25^th January and one may assume that could have come from the greater Weymouth area. However, the 436 who responded after 23 January will have been primarily from the Preston Neighbourhood and the voting was turned from 32% in favour before 23 January to 74 against after 23 January. This was once it had become known that 500 houses were forecast for the Preston Neighbourhood – it subsequently turned out that the true figure was 570 but 2 sites were removed (90 at Old Tip and 240 at Budmouth Avenue) leaving the 250-270 at Wyke Oliver Farm.

In the box “Relevant Environmental Targets” on page 95 of the WNP Objective 4 Targets 26 and 31 (as defined on page 25 of the plan) are not met.

It should be confirmed under W20, if allowed to stay in the Plan, that it cannot be an Exception Site. Page 125 of the Plan says at 9.150: “Much of the land outside the DDB however is protected from development by other policies in the Neighbourhood Plan. This land will not be suitable for exception site residential development”

Page 98 Land at Redlands

Para 9.70 says Map 21 but it actually Map 20. This was pointed out on page 25 of the Health Check https://www.dorsetcouncil.gov.uk/documents/d/guest/weymouth-neighbourhood-plan-health-check-november-2024 but was not done.

Policy 23C Lodmoor Old Tip South Section

Page 107 of the Plan At Policy 2 (viii) it states: “the development should include a compliant level of affordable housing including social housing and provide a high quality of design and landscaping”. At page 292 of the minutes of Weymouth Full Council held on 20^th November 2024 and ratified in Full Council on 15 January 2025, Cllr Northam stated to the Council: “Cllr Northam responded that Lodmoor Tip is no longer included for housing.” This statement appears to be false and development should be deleted from the Plan. Dorset Council, as owner, have said all along that they do not agree with development at this site so it is incomprehensible as to how the site even made it into the Sites Considered for Allocation.

Policy W30 Exception Site Development

This policy is incorrect at (3) where it says: “Exception site housing schemes should normally comprise 100% affordable housing”. Dorset Council policy is clear that Exception Sites need to be 100% Affordable Housing: https://moderngov.dorsetcouncil.gov.uk/documents/s21982/20201208%20-%20Section%204%20-%20Housing.pdf : so, the word “normally” should be removed

Policy W33 Timing of Infrastructure

Para 9.170-9.173 are conflicted by W20. It is stated: “The efficacy and capacity of the area’s flood defence infrastructure is of constant concern. It has recently been reviewed.” This is only true for Weymouth Town Centre and the Flood Zone 3 areas east of Greenhill have not been considered. It is further stated: “Development should only be permitted where it is supported by appropriate infrastructure that is provided in a timely manner. Development proposals should include a realistic assessment of their impact on the existing local infrastructure, services and facilities and demonstrate how any such impacts will be addressed so as not to disbenefit existing residents and businesses or harm the natural or physical environment.” With regard to sewage spills, there is only reference to the town centre and not the spills from Greenhill and Bowleaze emergency discharges as listed by the EA. It is made clear that Wessex Water may not make the infrastructure improvements until 2045, or after the life of this Plan, so the proposed development at W20 conflicts with this policy. https://www.dorsetecho.co.uk/news/24837673.weymouth-beach-risk-losing-blue-flag-status-due-pollution/

Policy W34 Sustainable Development

The proposed development W20 cannot be sustainable because it is not financially viable to include SUDS. There is a detailed budget for the site in the Viability Assessment https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/11/Weymouth-NP-Viability-Report-Compiled-Sept-2024.pdf at pages 89-96 of the pdf in the Annexe 3 and 3b which shows the site having a profit of no more than £100 on a turnover of £71,185,402. The developer has now walked away from the site. There is no allowance shown for the obligatory contribution to maintaining the 23ha of land supposed to be ceded to LVNP nor for any sewerage contribution to Wessex Water in respect of upgrading the present overwhelmed system where the EA shows emergency discharges to local bathing waters has doubled in the past 2 years. There is commentary at page 10 of the report as follows: “It is obviously impossible to test the financial impact that the imposition of an unknown share of an unknown cost might have on the viability of ordinary development. Moreover, viability assessments are required to test the impact of policies that are known in effect now and those that are proposed in the document under review – the Neighbourhood Plan. We cannot test the impact of flooding prevention costs. What we can do is identify the potential scale of spare capacity – or “headroom” into which such a policy might be inserted.” This makes it clear that SUDS has not been considered and that, with a profit of only £100, there is no “headroom” for it. Since the effect of passing the WNP would bring this site from outside the DDB to inside it, Policy W20 should be excluded NOW because it is simply not deliverable or achievable. This artificial concept of "Viability" does need to be put against real world concepts. The Map 19 on page 96 of the WNP does not show contours. This is shown at: https://drive.google.com/open?id=1-UuXf1EjivhoPRdG_VT8mObv1mAf93CO&usp=drive_fs The southern slope of the northern section and the northern slope of the southern section both slope steeply downwards into the Flood Zone 3 shown on page 65 of the Plan. All surface water flows must go into that valley since SUDS and Attenuation Ponds do not work on the steep slopes of hills. However, no SUDS can be built in that valley since Wessex Water make it clear that can be no building on or near their buried foul sewer and pressurised sewer in that valley, as shown on page 10 of these maps: https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs . Therefore, there will be loss of whatever infiltration there is currently on these slopes, but the water will rush downhill into the flood 3 Zone. Wessex Water have said that all water needs to be dealt with on site and the LLFA agree that the downstream system is severely at risk, with proven flooding already of houses below.

Para 9.178 makes it clear: “The installation of an appropriate SuDS system is critical given the growing flood risk in much of the area. Development proposals should demonstrate that the volume and rate of surface water run-off onto adjacent land and traffic routes is either at a lower or equal level to that prior to the development.” W20 is simply not possible without discharging water from site to increase the risk to downstream flooding in a flood Zone 3. At para 9.180 it states: “Reducing pollution is an often repeated request at community consultations. Air pollution from road traffic is of great concern and highlighted by action being taken in the large cities. The pollution of our water courses is a constant threat”. Discharges from site W20 can only be made into the Lodmoor SSSI and it has not been shown how any SUDS scheme at W20 can clean the discharges to such a water course.

Policy W43 Communities and Neighbourhoods

On page 158 of the Plan at 11.4 it states: “reducing the impact of the motor vehicle”. Site W20 conflicts with this by showing “high private vehicle use” in the SEA report.

Policy W44 Design

At point 4 it states: “Development should not increase the risk of flooding and/or exacerbate existing drainage problems and should be designed to maximise the retention of surface water on the development site and to minimise run-off”. Site W20 will definitely increase the risk of flooding and it will be impossible to retain surface water on the site; it will be discharged into a Flood Zone 3 area.

Policy W46 Transport and Travel

At 11.18 on page 164 of the WNP it states: “The new Local Plan is likely to encourage the move away from car dependency towards healthy, lower carbon travel choices and lifestyles. The policy requires significant new developments to be located close enough to existing facilities or deliver viable new facilities to make walking and cycling a realistic choice. This approach has been taken into account by the housing policies of the Neighbourhood Plan.”. Site W20 does not do this as the AECOM consultant states under Transportation that: “the likelihood of (sic) bring forward high private vehicle use.” Page 56 of their report (pdf page 78) refers https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/12/Weymouth-NP-SEA_Environmental-Report-November-2024.pdf

At 11.19 of the WNP it states: “Adequate provision to ensure a local public transport service can serve the residents of major new residential developments should be an integral part of the design and layout of any scheme.” At para 9.50 on page 89 of the WNP it says that the selection of sites to be allocated was made after the SEA Environmental Report. https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/12/Weymouth-NP-SEA_Environmental-Report-November-2024.pdf This report is deeply flawed for site W20 as it considers only 112-137 houses instead of the 250-270 allocated in the plan. An exhaustive Commentary on the SEA has been made. The Maps referred to are at: https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs and the text is at https://docs.google.com/document/d/1WAZZRlawNM1jp0NAHLVhf65-ptyvT4NK?rtpof=true&usp=drive_fs This shows that there is no possibility of Site W20 having “adequate provision” for public transport.

W47 Public Transport

At para 11.22 on page 165 of the WNP it states: “Neighbourhood Plans are encouraged by the NPPF (para. 116) to promote public transport use.” At 11.19 of the WNP it states: “Adequate provision to ensure a local public transport service can serve the residents of major new residential developments should be an integral part of the design and layout of any scheme.” At para 9.50 on page 89 of the WNP it says that the selection of sites to be allocated was made after the SEA Environmental Report. https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/12/Weymouth-NP-SEA_Environmental-Report-November-2024.pdf This report is deeply flawed for site W20 as it considers only 112-137 houses instead of the 250-270 allocated in the plan. An exhaustive Commentary on the SEA has been made. The Maps referred to are at: https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs and the text is at https://docs.google.com/document/d/1WAZZRlawNM1jp0NAHLVhf65-ptyvT4NK?rtpof=true&usp=drive_fs This shows that there is no possibility of Site W20 having “adequate provision” for public transport.

W51 Traffic Impact

At (1) it states: “1. Development proposals to reduce the volume and impact of motor vehicles”. AT 11.39 on same page it states: “The NPPF para. 108 requires plans to ensure the “potential impacts of development on transport networks can be addressed… “opportunities to promote walking, cycling and public transport use are identified and pursued”. Site W20 does not do this as the AECOM consultant states under Transportation that: “the likelihood of (sic) bring forward high private vehicle use.” Page 56 of their report (pdf page 78) refers https://www.weymouthtowncouncil.gov.uk/wp-content/uploads/2024/12/Weymouth-NP-SEA_Environmental-Report-November-2024.pdf

SECTION 13 OF WNP “ASPIRATIONS”

At page 192 of WNP under “Sustainable Environments” it states: “• In high risk areas develop a community flood plan”. It is admitted throughout the Plan that the Preston Brook Valley is a Flood Zone 3 risk. A Flood Risk was done only for Weymouth Town Centre and not for this area. The community flood plan should be developed and considered before putting forward development proposals such as W20 which can only void into this Flood Zone 3 area.

At page 194 of WNP under “Walkable Communities” it states: “Support the creation of walkable neighbourhoods where all facilities are within a ten-minute walk and maintain existing pedestrian access routes”. Policy W20 is in violation of this: The contours are shown at: https://drive.google.com/open?id=1-UuXf1EjivhoPRdG_VT8mObv1mAf93CO&usp=drive_fs so, before considering the distances which people have to walk, they also have to climb effectively up to a 10-storey building.

A. It is a nonsense to say for Policy W20 that: “This allows for access to services in the centre via the B3159.” This is illustrated on maps 4 and 5 https://drive.google.com/open?id=1nzjLG3WUl408g6Tf-Wx8N2NCL33lW_h0&usp=drive_fs. If the footpaths were even in existence (which they are not) google earth shows it to be well in excess of 2km by foot to reach the B3159. Nor is the B3159 reachable by bus. It is a nonsense (map 6) that “There are bus stops in proximity to the northern site boundary – approximately 75m to the north”. The bus stop to the north is shown on Map 6A as 255m from the centre of the northern part of the site and either impossible or much further from the southern part of the site. There are no services from this stop which go along the B3159. Just a few times a day it might be possible to catch a bus to Dorchester from this stop, then change route further along the line at Littlemoor for the B3159 bus to Weymouth. Even the bus stop shown closest to the northern part of the total site (the southern part of the site is much further) would also involve great elevation changes of at least a 10-storey building, make it further unwalkable. No account has been taken of changes in elevation in the area. The bus stop at Charlbury Corner, for example, is at an elevation of 13m and the top of the site is 40+m. Walking around the hills would add many hundreds of metres instead of the “as the crow flies” approach (Map 7 at least 723m). Map 8 shows that the statement in WNP24 on page 34 is misleading that the nearest bus stop was 740m away. This might have been to the entry of the site, but Map 8 shows the median point to be 885m away and the end of the site to be about 1000m away.

B. Page 82 of WNP at 9.30 suggests that a “walkable” neighbourhood should have facilities “within 800m”. Dorset Council has no policy on this in NP’s since each site is different. This particularly applies to W20 with the very large changes in elevation, making both walking and cycling very challenging. Policy suggested by Sustrans in 2022 https://www.sustrans.org.uk/our-blog/research/walkable-neighbourhoods-building-in-the-right-places-to-reduce-car-dependency/ was that “LPAs should develop Supplementary Planning Documentsthat set accessibility standards based on 800m walking and wheeling distances to key services, and 400m to bus stops.” Map 9 shows the practicable bus stop at Charlbury Corner to be no less than 800m away using a mixture of “crow flies” and existing roads, evidently final site design will make this much further.

There are no facilities within a 10-minute walk of some of the houses proposed for Site W20 but beyond this there is just one, small up-market delicatessen at Charlbury Corner, certainly not “all facilities”.

APPENDIX A WEYMOUTH SUPPORTING ENVIRONMENTAL TARGETS

At Page 203 of WNP it states: “Climate Change Management - All new developments are expected to result in no increase in the risk of flooding and provide adequate resilience to extreme weather events”. The Policy at W20 can ONLY increase the risk of flooding:

At page 219 of the WNP under OBJECTIVE 4 CLIMATE CHANGE MANAGEMENT it states: “Extreme weather events intensifying across the globe present an urgent need to adapt our buildings, infrastructure and communities to the impacts of the climate emergency. From extreme heat in our summers to repeated flash flooding across the UK, 60% of the UK’s climate-related risks are currently rated in the most severe urgency category. It is recognised that there is a need to set science based targets and measurable metrics for climate resilience which at the time of writing are not available but are expected to become so during the life of the Weymouth Neighbourhood Plan and will be a matter for review. The measures outlined in Targets 1 to 25 will each contribute to climate change management to varying degrees. Other factors do however need to be considered. Significant for Weymouth are the effects of coastal and surface water flooding. Coastal management is a strategic issue addressed through the Shoreline Management Plans as per W01 of the draft Weymouth Neighbourhood Plan (5). The topography of the area in which steep calcareous grassland with little vegetation and multiple underwater springs create excessive surface water run-off into the chalk bed rivers of the lower valleys and then enter the sea creates a significant flood risk, particularly at times of high tide. Whilst some of these contributing factors cannot be controlled at source and mitigation is necessary, other contributors to floodwater generation such as run-off from impervious surfaces within new developments can be addressed.”

The comment “at the time of writing” is not strictly true. The LLFA of Dorset Council has confirmed that provision already needs to be made NOW to deal with surface water run-offs 45-50% greater than today. Policy W20 conflicts with this because it has been confirmed that there is no possibility of dealing with this extra amount of surface water when the site already voids into a Flood Zone 3.

At TARGET 31 “SUSTAINABLE TRANSPORT” on page 223 of the WNP it states: “• Promote walking- People are encouraged and supported to get walking. • Reclaim places for communities - Green routes and spaces are designed with communities and open to all Local authorities have in recent years set a range of distance criteria for ‘walkability’ (10); the following distances from a neighbourhood centre are typical and provide a useful reference point. Key services e.g. Surgeries, Food Shops, Social Hubs - within 800 metres (10 minutes single journey); Bus stops – within 400 metres ( 5 minute single journey); Primary schools – within 800 metres; Green space over 2 Ha – within 1 kilometre (12 minutes journey); Play parks and small open spaces – within 400 metres”. Site W20 has been shown that most or all of the new homes planned do not meet this target.

Create Your Own Website With Webador