Dear Members of the Weymouth Neighbourhood Plan Steering Group (SG)

 

I am writing to address the draft Viability Plan for WNP24 (“Land off Brackendown/Budmouth Avenues”), which I find incomplete and unsafe.  I will reference documents already in your possession or attach them if necessary.  If you require the source again for previously considered documents, please let me know.  I have received FOI documents from Weymouth Town Council (WTC), also 850 pages from Dorset Council (DC) in connection with this matter.  These only reached me in the last few days.

 

According to your Minutes, it appears that WNP24 is deemed non-viable and is to be “tweaked” to become viable.  As I have the second longest frontage to WNP24, I believe I can provide informed input as a local resident familiar with the site and its surrounding area.  Other members in my Focus Group have lived here for decades longer than me in some cases, thus this represents the collective input of at least 7 residents.  I would like to highlight that much of this also pertains to the adjoining Wyke Oliver site (WNP25).

 

My submission suggests that it would be wise for the SG to consider that this Site may not be suitable for development at all, especially for affordable or social housing, which would be the primary consideration.  

 

PREAMBLE

 

1. The Leader of the WTC, Cllr Harris, has used the Dorset Echo to criticise me as a “Nimby”.  However, I believe the SG should be fully informed, understand the site’s background, and appreciate why it has not been developed previously and cannot be developed now due to sound technical reasons.  I am aware that “NIMBY” is not a valid planning objection. 

 

2. The SG could have made better decisions by consulting local residents.  It is unfortunate that politicians persuaded the SG to disregard the 573 comments received in the 3^rdEngagement, particularly the 436 comments in the days between 23-30 January 2023 as opposed to the 137 comments received in the preceding months.  Cllr Harris dismissed as “lies” the information presented to residents that 500 new houses could be built in Preston.  However, the actual figure adopted by the SG is 570, revealing the truth.  Additionally, residents were excluded from the consultations because only one device/IP address per dwelling was allowed.  The consultations were structured, as admitted by WTC, in a pro-forma format that restricted responses to specific questions.  My submission aims to elaborate on this issue, as Preston residents feel their voices have not been heard. 

      Let us look, by contrast, what this politician David Harris "promoted and printed" in his Liberal Democrat Flyer just a few years          ago:  "The concerns already raised are many and varied and a local campaign group may have already suggested some of                these to you.  Other concerns that we have are the apparent lack of knowledge of the contours by the planners, with the flood.          relief ponds on the other side of the ridge from the main building area; and the idea that this land is on Wyke Oliver Farm,                  which it is not, but which was a convenient name to use as an area of this farm, not now included, had been approved                        previously.  To make a difference please act now as time is running out! What you can do. If this proposal is adopted into the.          local plan by our Council, houses will undoubtedly be built.  Make your comment in writing to the Council either on line by                  email or letter."

3. It is unfortunate for residents to be embroiled in this local party-political spat and to learn that the SG attempted to persuade Jonathan Mair at DC to reprimand the local councillors who spoke truthfully about the 500+ new houses.  It is also regrettable that the SG did not heed Locality’s suggestion to re-survey the residents once the situation had calmed and the full truth had been revealed.  The Liberal Democrats have prioritised “truly affordable homes” astheir Number 1 concern in the upcoming elections and Mr Simon Clifford claimed this as one of his “key fights” during the January local election but is no longer contesting in Preston.  As a resident of Sutton Poyntz, he is now standing in Chickerell.

 

HISTORY

 

4. The attachment is sourced from the National Archives and can be accessed at https://maps.nls.uk/geo/explore/#zoom=17.0&lat=50.63622&lon=-2.43849&layers=168&b=1&o=90

My residence is represented by the blue circle and, upon opening the link, you can use the slider at the bottom left to overlay present day information on this interactive map from the year 1901.  This will be revisited later.  WNP24 is roughly to the north and west of me.  Bellway Homes purchased outright in 2018 (not an “option”), roughly the plot number 195, with Land Registry records indicating the consideration as £670,000 under their ref DT53032.  Bellway holds options on the land to the west of this plot to complete WNP24.  The former owner of Plot 195 was a land speculator who made repeated attempts to develop the land.  They succeeded in constructing  “Spanish-style” houses at the top of Budmouth Avenue, upon appeal, after it was rejected by Planning.  These houses have experienced structural defects due to being constructed on unstable land. This cul-de-sac serves as the primary access for WNP24.  Bellway expressed a genuine interest in WNP24 and corresponded with the SG on 14 August 2023 “achieving early delivery via the neighbourhood planning process”.  

 

5. Bellway informed you (their letter 30 January 2023) that “site 6 was identified as a prospective housing allocation (WEY 13) in the review of the West Dorset, Weymouth and Portland Local Plan (WDWPLP), but this review was abandoned in favour of a new Dorset Local Plan (DLP)”.  However, this information is incorrect, as it was actually WEY 14, known then as “Wyke Oliver Farm” as shown.DT53032 is circled and is entirely within “Important Open Gaps ENV3” and “Land of Local Landscape Importance ENV 3”.  Bellway wrote on 15 March 2021 in submission to the DLP as shown in the attachment.Their submission was correctly recorded and is shown.  This demonstrates that DT53032 was never included, and Bellway wrote at length as to why this was wrong and why it should be included as an Exception Site.  They cited the planning response: 

‘The site is located outside the development boundary and within land of local landscape importance and an important open gap. There are flooding and access concerns. An unsuitable site’.

However, Bellway concluded by stating: “As set out above, the evidence suggests that this conclusion is unfounded.”

 

6. The site was subsequently included as WEY 14 shown at.Strangely, the surface flooding water is depicted as running uphill from south to north, over the crest to Attenuation Ponds forming a downhill cascade towards the already overloaded Preston Brook.  The comments to this proposal are shown.This all took place during the summer of 2018.

 

7. The SG may not have seen the attached document from November 2018,which is the Planning Response to the previous, speculative landowner and his agents.  This was summarised as:

 

Flooding (from run-off and potentially from groundwater springs);

Land instability (as a result of the underlying geology);

Landscape and visual impact; and

Access to the site.

 

I am reviewing the key planning reasons why this site is unsuitable before delving into the specific aspects of Viability:

 

1. the site lies outside of the Defined Development Boundary
2. the site is designated as an Important Open Gap
3. it is part of the important Lorton Valley Corridor
4. it does not conform to policy for walking, cycling and public transport in Weymouth.  The SG will have seen the report from Ardent Consulting Engineers dated 29 September 2023 “Sustainable Travel Overview”.  You may not have seen their earlier report from May (Ardent -Transport scoping May 23).  They utilised number 75 Budmouth Avenue as the starting point for the site, but this is not correct.  From there, the site extends about 300-400m westwards so, as an average, 200m needs to be added on to all their figures. They suggest that the preferred maximum for walking to Weymouth town centre should be 800m but in fact it is 3400m and they do not show this.  The report advocates cycling instead, but many people in social housing have impairments limiting their ability to cycle.  It says that the nearest bus stop (Sunningdale Rise on Preston Road) is “approx. 750m” away.  Add the average 200m into the site, gives 1000m walk to the nearest bus stop and 1200m for some.  The report says: “It is generally recognised that bus stops should be located so that the maximum walking distance from any dwelling is 400m”.  It is noted that in Manual for Streets (MfS) ‘Walkable Neighbourhoods are typically characterised by having a range of additional facilities within 10 minutes (up to 800m) walking distance of residential area which residents may access comfortably on foot’.  Note the use of the word “comfortably”.  Despite these factors, their report concludes:“It is reasonable to consider that the site is accessible by a variety of sustainable modes of transport and can be considered a suitable location with regards to sustainability”.  However, everyone views this site in a two-dimensional manner.  The bus stop at Sunningdale Rise is at an elevation of 11m and the top of WNP24 is at an elevation of 45m.  Consequently, people are expected to walk with their shopping for up to 1200m and in the process climb the equivalent of a 12-storey building.  No one would put social housing clients in a 12-storey tower block and expect them to walk up it!  It is unlikely that residents will want to cycle such a climb either.  These challenges imply that car ownership will be essential, contradicting policy aspirations for new developments to be limited to 1 car per dwelling.  There are no viable food shops in the vicinity of SNP24, especially for less affluent people.  There are only 3 convenience stores.  The SPAR at Preston Road is more than 1mile and 24min walking.  JOYS at Overcombe Corner is 0.5mile and 12min walking.  The delicatessen at Charlbury Corner is 19min walk and almost 1mile away.  These distances should also be considered with the 12-storey climb.  The only bus service from Preston Road takes one between Preston and central Weymouth, again nowhere near supermarkets except for a Tesco Express in Weymouth.  Contrast this with Bincombe Park, where there is a full-facility shopping complex (including discount shopping) directly adjacent to the site.  I believe the site does not conform to Policy WNP20 because it is not a “walkable neighbourhood”.
5. Landscape.  Bellway have disregarded the Landscape Impact by failing to account for the impact from the East.  Under WNP15 the SG refer to view V8 on Map 16B and I now attach the relevant photographic evidence from Furzy Cliff,which is a popular neighbouring space visited by hundreds of people daily and especially the Look Out Café.  Bellway say that the building on DT53032 can be done close to the back of the houses on Brackendown Avenue and be shielded from view, but this photograph proves that not to be the case and the whole of DT53032 is visible.  It is true that westwards beyond DT53032 the concealment is greater once that rise has been topped, until again the site becomes visible from the west, which has been addressed.  I note from the SG minutes that Colin Marsh raised concerns about Landscape but was overruled by the majority.
6. Heritage.  The attachmentmakes it clear from Planning there is a possibility of a Roman Temple within the site but this has not been investigated. This contravenes Policy WNP19.
7. Affordable Housing.  WNP22 makes it clear that there must be “at least 50% on greenfield sites”.  From everything already said in your minutes about Bellway reneging and the Viability test having failed, this site must be dropped because it is clear it does not, and never will, conform to your own Policy.
8. The entire site lies within the 800m Exclusion Zone of the Lodmoor SSSI.

 

VIABILITY

 

8. The minutes of the SG indicate that this site is currently not deemed viable but might be if things are “tweaked”.  My FOI has not revealed what these tweaks are yet to be.  The FOI does show that the SG is aware Viability for the adjoining site Wyke Oliver WNP25 is not viable because the profit would be £100 on a revenue of £70+m and that WNP24 “would be similar”.  

 

9. Dorset Council wrote to the SG in January that “The NP is not viable, deliverable or achievable”. The SG will be aware of the comments to them from theCEO of East Boro Housing Association last November: “Whilst I whole heartedly support the 50% sentiment of your aim on greenfield sites I would suggest unless the neighbourhood plan and its incorporation into the overall Dorset Council Local Plan is some years off and the economy/costs are different, the likelihood of developers being able to viably deliver 50% affordable in today’s market will be a significant challenge.  You may end up with planning permissions that are not proceeded with or significant viability challenges that will then be decided by Dorset Council after planning permissions are granted.  Either that or the land will need to be free and it still would be challenging for developers to build that % on a scheme and be able to subsidise them out of only the other half.  Also from the affordable half you would likely need a significant % to be shared ownership to enable the Registered Provider to be realistic to help the developer.  It is more complicated than just choosing a % when it comes to delivery and this is the most difficult economy I have seen to deliver affordable housing in my career (and I don’t say that lightly) . . . . .  add that all up and 50% affordable is a real challenge and believe me I want it but I am also a realist regarding the task.  Taking 30% and getting a scheme delivered because it works is better than nothing if it does not proceed.  You could say we have set it high to negotiate down but it costs £10’s of thousands and a long time to work up planning, get it submitted etc. it’s a big abortive cost risk if you then can’t get a viability challenge through that only really big developers may risk the potential abortive investment if at all given the amount of “in boundary” opportunities they may have with lower affordable % when the Dorset wide plan is approved.  So I applaud the aim but it may not deliver results quickly and or possibly to the level you want due to viability and the economy.” 

 

It seems that the 50% affordable target which the SG have set themselves is unobtainable and that makes the WNP unsound because residents have been misled by this 50% figure when asked for their comments.  Bellway quote their record in Dorset, shown to the SG, as being 25%/15%/30%/25%.  Lovell Homes are building nearby in Littlemoor on a much more level and suitable site; the target there is 35%.

 

10. It is not clear from the present Viability Report whether the following specific difficulties of the site have been considered and, if so, what the financial element is:

 

1. Roads and Access

Bellway’s submission to the SG is that: “although access could be taken from Budmouth Avenue or the residential streets south of the site, these are all long and narrow cul-de-sacs which are unlikely to have capacity to serve development of the whole site, and it is unlikely that the proposed capacity of 250 dwellings could be achieved without significant highways improvements. The current Bincombe Park development of 500 houses has mandated 3 (ratio 1:166 even allowing for the fact that there are bus stops and cycle paths at the front door) separate accesses to Littlemoor Road.  There are about 633 current houses on the Weymouth Bay Estate (WBE) with only 2 accesses to equally busy Preston Road so that the proposal is that 1113 houses on WBE (Budmouth and Wyke Oliver) should share the same 2 accesses, ratio 1:556.  It is not clear why Highways believed that the modern standard for Bincombe Park should be 3.3 times more generous than would be the situation on WBE.  Further, the access via Melstock Avenue to Preston Road is blighted by a blind summit to the right and limited visibility to the left.  There are regular Road Traffic Accidents there.  Your Exception Site is based on outdated reports, specifically TRANSPORT SCOPING NOTE, REPORT REF., 190131-R-01, May 2023 from Ardent (Ardent -Transport scoping May 23).  DC have given it to me, along with the Highways Scoping Note from 20 June 2023, in your possession.  This shows that no access is possible via Brackendown Avenue as suggested by Bellway, except for a dropped kerb serving no more than 5 dwellings.  Thus, Moordown Avenue remains as the only alternative access to the main access off Budmouth Avenue.  The plan, however, has been modified to reduce the construction of the site to the west so this will be a very expensive access link to construct, 510 metres long, just to reach the outskirts of the site, as shown on Bellway’s plan.  The Viability costings need to show that these total Highways costs have been calculated.  

 

 

1. Land Stability

This is shown in the earlier Planning letters as a problem on this estate.  There has been considerable underpinning of property close to WNP24 because foundations in the 1960’s were not as they are today.  I have made two changes to my property in the last 5 years, neither of which were even single-storey extensions, but Building Control were rigorous that the new/existing foundations should be extended beyond 1m downwards until through the clay layer.  This clay layer varies through soft/medium/firm and each property is different.  The latest property at 21 Budmouth Avenue is being extended and the single-storey has gone through 1m and the double-storey has had special foundations required.  Houses on Oak Way have needed 5m piling for extensions. I have noticed that Lovell have now started piling at Bincombe Park.  Bellway, in March 2022, sent in a specialised drilling rig to DT53032 and their report is known to the SG.  They did not carry out this work over a full year, as required by DC for Planning.  The Viability will need to show that costings for foundations of a minimum of 1m for each dwelling have been included, as well as an allowance for rafting/piling/special foundations on a dwelling-to-dwelling basis.  We are all too aware that developers including affordable units often put their first shovel in the ground then try to reduce downwards the number of affordable units and this is why Planning will expect no surprises of this type.  Local Building Control here expect that the ground will be more stone and less clay towards the ridge but, obviously, the ridge cannot be built.  Viability should liaise with Bellway to share their full data so that Land Stability can be costed in for foundations and all infrastructure such as roads etc.

 

1. Springs

Bellway assertion to the SG on 10 July 2023 that “Having Reviewed the historic maps back to 1888 there is no other reference of springs on or nearby to the site” is not sound.  The historic spring, now to the west of Bodkin Lane, was built over but causes flows elsewhere on the WBE and houses between Brackendown Avenue and Southdown Avenue all complain on this as they pass their surface water downhill to each other in a cascade.  It’s very much a “Whack-a-Mole” situation and the suppressed spring now appears to rise directly on the land owned by Bellway, DT53032 and video evidence of this running in July (so year-round) can be accessed here:

 https://drive.google.com/file/d/1QRisICW2uV7oXP05dD380sEjbuZbG63_/view?usp=sharing

Their tenant farmer is certainly well aware of it and avoids it for planting.  

Investigation needs to be made of the historic tunnel running across nearby, as evidenced by the “Ventilators” and “Air Shaft” to this tunnel on the 1901 map. The tunnel originated at the junction of Coombe Valley Road/Littlemoor Road and was designed to bring mains water across the WBE. 2 Ventilators have been built over on Budmouth Avenue and the last SW Ventilator is shown today as buried on Eastdown Avenue.  It is likely this tunnel will be a conduit for springs and surface water to follow.  There are also sink holes within 200m to the west of the site, which can be evidenced from the public right of way running up and over to Littlemoor.  We have not gone onto private land to examine whether these sink holes extend onto the site, but they do confirm the presence of water running underground on and close to the site. Viability will need to decide how to intercept and manage these springs as part of Flood Management.

 

1. Surface Water Run-Off

The previous Planning has made it clear that this is a long-standing problem. Bellway are shown as saying: “the risk of surface water flooding is negligible” but resident videos can be viewed to give some scale of the problem:

https://drive.google.com/file/d/1-yZcsxZoDO78vVDcriIYVPKh6XDGSfd-/view?usp=drive_link

https://drive.google.com/file/d/1-rBNBbmPreFfduMruGFWMxZTLTuHmkFe/view?usp=drive_link

https://drive.google.com/file/d/1-l6ZawC2zF8P7YUDVtib-eWK8G2OrHFa/view?usp=drive_link

https://drive.google.com/file/d/1-f2SLsfpqnHjQ38_NNvwc2dEppTNHRbe/view?usp=drive_link

I am forwarding to you herewith my emails and attachments to the DC Flood Team.  We feel that their Statutory Consultation PPE223-010 dated 15 December 2023 regarding WNP24 to you is not current and is unsafe.  Please discuss this with your Viability Consultant.  WNP25 can only void into the Preston Brook, which is already overloaded.  The latest Flood Warnings from gov.uk for Preston Brook were last issued on 13 March and 5 April 2024.  Clearly, Weymouth reports its wettest period since records began, and that by a margin of 30% over the all-time high.  Climate Change now mandates that a 45% uplift needs to be calculated in to anticipate further rises in rainfall.  Map 15 of the WNP shows all water from WNP24 and 25 running to a Flood Zone 3.

The previous application for WNP24 showed the surface water running away UPHILL.  Bellway and Viability now show no schematic of how this is to be dealt with.  There is vague talk of SUDS and Viability needs to show a fully-worked up and costed plan.  It is agreed that Attenuation Ponds will not work (as installed at Bincombe Park) and that it will have to be tanked.  From the resident videos, there is sufficient data to show the flows and volumes presently running.  The main problem is that there is no way to get this ducted away from DT53032 without demolishing property on Budmouth Avenue or pumping it back uphill to intercept storm drains.  The present Storm Water Drain Plan from Wessex Water shows the discharge from WNP24 is likely to be direct into the Lodmoor SSSI, not Preston Brook, and the SUDS scheme will have to show the allowance for cleaning the discharges, which will be dirtier than at present.  The SSSI will be very particular about this.  The major question then is whether Wessex Water can accept any or all of these discharges and at what flow.  The SUDS Viability cannot be calculated for Storage/Attenuation until this is known.  I have flagged this to Wessex Water, please read my mail and attachments which I am forwarding to you herewith.  There has been no response to date.  Certainly, the SSSI is an impressive Attenuation Pond but there has been past flooding at Preston Beach Road and Overcombe Corner when this, too, is overwhelmed.  There was also a very recent Flood Warning for Sea Flooding on Preston Beach Road in the Sea Life area where Wessex do their emergency discharging of raw sewage.  That risked throwing raw sewage back over the Preston Beach Road and nearby land.  The March 2024 reports from the Environment Agency show that Wessex Water have doubled their raw sewage discharges (in line with the national average) at the 2 key Preston beach outlets numbered WSX0989 (Melcombe Avenue) and WSX0770 (Osmington Bay Holiday Park).  No one likes to have their bathing waters contaminated by raw sewage.  Alerts on these overflows can be had by joining Surfers Against Sewage.  I personally have been visited by Wessex Water because they have detected surface water flooding in my immediate vicinity into the foul drains, even though the 2 systems are supposed to be quite separate.

 

Concreting over 19ha at WNP24/25 is going to create massive, new, rapid flows of water to known downstream flooding areas.  Bellway say: “Bellway is cognisant that the development of the site could have potential to exacerbate the risk of flooding elsewhere unless attenuation and SUDS form an integral part of any scheme”.  The costs of preventing known Flooding from getting even worse needs to be costed in Viability and it is hard to see that any extra discharges into a Flood Zone 3, whether momentarily delayed or not by SUDS, can be acceptable.

 

I strongly advocate for these considerations to be incorporated or to be “tweaked” into the revised Viability Assessment.

 

Given these challenges, I believe that WNP24 is not Viable.  The SG have invested a lot of energy and the politicians a lot of political capital in including the site within the WNP, only for it to surely fail ultimately?  Please consider that the 100 houses which adjoin the site are now blighted until this matter is resolved and I urge you to withdraw the site from the WNP before things go any further.

 

I am happy to meet with the SG, or your Viability Consultants, and maybe do a walkabout from Sunningdale Rise bus stop, to the Budmouth Avenue Access, to my house which has an elevated view of the site from a rear 1^st floor deck, to the west end of Brackendown Avenue to inspect the proposed site access there.  This will give the SG a better understanding of the site and my submission.