TOWN AND COUNTRY PLANNING ACT 1990
Planning Appeal By Mr & Mrs B & H Tudgee
Against The Decision Of Bath And North East Somerset Council To Refuse Outline
Planning Permission For The Erection Of 9 Dwellings
LAND AT THE JUNCTION OF HAM LANE AND STITCHING SHORD LANE,
BISHOP SUTTON.
WRITTEN STATEMENT
Submitted on behalf of
Bath and North East Somerset Council
Local Planning Authority Reference 14/00336/OUT
Appeal Reference APP/F0114/A/14/2217941
Date June 2014
1.
Introduction
1.1
The delegated report for the application is detailed and comprehensive and
covers all the issues fully. Therefore the Council intends to rely primarily on
this document. However the appellants ground for appeal require further
commentary and this is set out below, in relation to each Reason for Refusal
and in relation to other relevant issues.
1.2
The application consists of a vacant field on the junction of Ham Lane and
Stitching Shord Lane, on the western edge of Bishop Sutton, a rural village.
The site lies outside of the Adopted Housing Development Boundary.
2.
Policy Position / 5-year Housing Supply
2.1
At the time of writing the Council accepts that it is unable to demonstrate an
agreed 5-year housing land supply, however it is not far from being able to do
so.
2.2
In early January the Inspector made preliminary conclusions in relation to the
SHMA hearings that were held December 2013 (reference ID/44, Appendix
A). These are very important as he has advised (1) that there is nothing
fundamentally wrong with the SHMA that would prevent him finding the Plan
sound and (2) that he was not persuaded that the Council should increase
provision beyond the 13,000 homes that are planned.
2.3
Subsequent hearings, taking place in March/April 2014 have been focused on
delivery of the 5-year housing supply, the spatial strategy and primarily the
justification for Green Belt release and where that should be (Bath, Keynsham
and Bristol being the options). Arguments put forward by those advocating a
greater role for the Somer Valley and the rural areas in lieu of the Green Belt
were few, and not particularly well articulated or justified.
2.4
The Examination has now finished and the Council awaits the Inspectors final
report, which is expected to be published on 27th June. The Council is
confident that within the anticipated lifespan of this appeal the Inspector will
conclude that the Council can demonstrate a 5-year housing supply.
2.5
Aside from the position in respect of the NPPF presumption in favour of
sustainable development, which is likely to change in the near future, the
Council has concerns about the impact of speculative housing development
on plan-making in the district.
2.6
The NPPG, published 6th March 2014, strengthens advice previously set out
in the National Planning Policy Framework regarding the issue of prematurity.
The NPPG advises:
“… In the context of the Framework and in particular the presumption in favour of
sustainable development – arguments that an application is premature are unlikely to justify
a refusal of planning permission other than where it is clear that the adverse impacts of
granting permission would significantly and demonstrably outweigh the benefits, taking the
policies in the Framework and any other material considerations into account. Such
circumstances are likely, but not exclusively, to be limited to situations where both:
a) the development proposed is so substantial, or its cumulative effect would be so
significant, that to grant permission would undermine the plan-making process by
predetermining decisions about the scale, location or phasing of new development that are
central to an emerging Local Plan or Neighbourhood Planning; and
b) the emerging plan is at an advanced stage but is not yet formally part of the development
plan for the area.
Refusal of planning permission on grounds of prematurity will seldom be justified where a
draft Local Plan has yet to be submitted for examination, or in the case of a Neighbourhood
Plan, before the end of the local planning authority publicity period. Where planning
permission is refused on grounds of prematurity, the local planning authority will need to
indicate clearly how the grant of permission for the development concerned would prejudice
the outcome of the plan-making process.”
2.7
2.3
This supersedes guidance that was previously set out in “The Planning
System – General Principles” and omits text (in paragraph 17 of the General
Principles) which previously advised (in summary) that proposal for
development which impacted on only a small area would rarely be so
substantial or result in cumulative effects so significant that granting
permission could prejudice decisions which are being addressed in
Development Plan Document policy. The implication of this omission is that
the cumulative impacts of even small schemes are capable of justifying
refusal on prematurity grounds.
2.8
At the time the application was determined, the Council, had yet to come to a
corporate view as to the degree to which speculative development was
threatening the Core Strategy, and therefore no reason for refusal was drafted
citing pre-maturity concerns, however the Council has growing concerns, as
set out below.
2.9
Subsequent to the determination of this application, the Council has begun to
refuse similar speculative housing applications as being premature to the
Core Strategy, and therefore these concerns should be brought to the
attention of the Planning Inspector.
2.10
Addressing criteria b) of the NPPG guidance as above, the Core Strategy is at
an advanced stage of the plan-making process.
2.11
Addressing criteria a), the Core Strategy, has been drawn up seeking to
locate new development in the most sustainable locations or in locations
which can be made sustainable. The overall strategy has been to steer growth
to the more sustainable locations at Bath, Keynsham and the edge of Bristol,
distributing development in the rural areas outside Green Belts at a lower
level, proportionate to sustainability of these settlements.
2.12
Overall the distribution of housing growth to 2029 (as set out in the Changes
to the B&NES Core Strategy, published 4.03.13, appendix B) is proposed to
be as follows:
2.13
-
Bath - 7,020 homes
-
Keynsham - 2,150 homes
-
Rural Areas - 1,120 homes (Bishop Sutton as an RA1 village
would receive 50 dwellings over this 15 year period)
-
Somer Valley - 2,470 homes
-
Edge of Bristol/ Whitchurch - 200 homes
Taking into account this spatial strategy, the Council proposes to remove sites
from the Green Belt to accommodate 1,100 dwellings in total as follows:
-
Odd Down/South Stoke - policy B3A - 300 dwellings
-
Land Adjoining Weston - Policy B3B - 150 dwellings
-
Land Adjoining East Keynsham - Policy KE3A - 250 dwellings
-
Land Adjoining South West Keynsham - Policy KE4 - 200
dwellings
-
Land At Whitchurch - Policy RA5 - 200 dwellings
2.14
(The Council’s modified housing strategy and the proposed Green Belt
allocations are summarised in the “Consultation on the Core Strategy
Amendments” at Appendix C and set out in greater detail in the Report to
Council dated 4.3.14 at Appendix D.)
2.15
The exceptional Circumstances justifying the proposed Green Belt housing
releases relate to the need to accommodate the 5-year housing need and to
meet the District’s affordable housing need. Within the period of examination,
any development permitted beyond that set out in the draft Plan will reduce
the exceptional circumstances to justify the removal of land from Green Belt,
and thus contribute towards undermining the Council's spatial strategy, which
based a sustainability appraisal, is centred on the release of Green Belt land
for development in sustainable positions around Bath and Keynsham.
2.16
Under the auspices of the NPPF Presumption in favour of sustainable
development, the Council has experienced high development pressures on
land outside the green belt, typically on land on the edge of small towns and
villages in the southern part of the district.
2.17
At the time of writing an additional 130 dwellings have been approved or
allowed outside Housing Development Boundaries across the district, over
and above the level of growth anticipated in the Core Strategy.
2.18
Of this number Bishop Sutton has seen the lions share, with 76 dwellings
approved or allowed since 2012, exceeding the level of growth anticipated in
the Core Strategy to 2026 by 26 dwellings.
2.19
Furthermore, across the district, taking into account the applications which are
currently pending committee decisions or awaiting appeal decisions (and
including this appeal), an additional 586 dwellings might be either approved
locally or allowed at appeal. A full schedule of approved / allowed appeals
and pending applications / appeals is attached at Appendix E. Other housing
schemes which have been refused but not yet appealed will not show up on
this list.
2.20
The Council is concerned that this level of speculative housing growth
threatens the proposed Green Belt releases. For example, the 130 dwellings
already approved or allowed in the district beyond the Core Strategy
commitments would remove the majority of the need for the proposed Green
Belt release in Weston (Policy B3B).
2.21
Were the pending planning applications or appeals in the district to be
approved or allowed, the exceptional circumstances for the South Stoke
Green Belt release (Policy B3A) would be undermined.
2.22
It should be stressed that these sites are being promoted as the most
sustainable locations for development. Due to the particular circumstances in
the District, the most appropriate strategy is to allocate relatively modest
urban extensions and a number of urban fringe locations. The cumulative
impact of development elsewhere will more readily affect this strategy, and
threatens to bring about a less sustainable pattern of development compared
to that promoted in the Core Strategy.
2.23
The Council is concerned that there is a high risk that 5 year land supply
matters will short circuit the Core Strategy examination and result in
unsustainable outcomes. Clearly in isolation, the development will have no
material effect on the Core Strategy, but the cumulative impact of the appeal
scheme with other allowed or approved speculative housing developments is
substantial and would pre-determine decisions about the scale, location and
phasing of new housing development that are central to the Council's
emerging Core Strategy.
2.24
The Council realises that the NPPF intends the 5-year housing supply to be
the minimum level of housing identified in a district and does not expect the 5year supply to be a “cap” on further development. This approach whilst
acknowledged, does not take into account the peculiar circumstances in
BANES where 70% of the district lies within the Green Belt. If further
speculative housing applications are allowed ahead of the Adoption of the
Core Strategy, it would mean that the Council’s favoured, sustainable housing
allocations (which lie in the Green Belt) would be sidetracked in favour of less
sustainable sites which lie outside of Green Belt.
2.25
The Council considers that the harm to the sustainability of the spatial
strategy, by permitting sites that do not accord with the draft Plan significantly
and demonstrably outweighs the benefits of immediate housing delivery.
3.
Reason for Refusal 1. Flood Risk Considerations
3.1
The First reason for refusal was as follows:
The development would introduce a more vulnerable use in an area
known to be at high risk of surface water flooding, and would increase
vulnerability to flooding contrary to the National Planning Policy
Framework and its Technical Guidance Note. The site suffers from
critical drainage problems and frequent and well documented flooding
and is not served by surface water drains. Insufficient evidence has
been submitted to demonstrate that the development could be
effectively drained, that the development would be safe in the event of a
flood, or that the development would not exacerbate flooding problems
elsewhere. As such the proposed development would be contrary to
saved policies ES.5 of the Bath & North East Somerset Local Plan
including minerals and waste policies Adopted October 2007, policy CP5
of the draft Bath and North East Somerset Council Core Strategy March
2013.
3.2
The sole vehicular access to the site is via Ham Lane. Whilst the site and the
lane is located within Flood Zone 1, residents report that Ham Lane suffers
from frequent surface water flooding, as documented in the letter at Appendix
F from Mr Betton and the clipping from the ITV news website below, which
shows the site frontage, on the junction of Ham Lane and Stitching Shord
Lane.
3.3
Further evidence in the form of a youtube video of the floods on Ham Lane
and Stitching Shord Lane can be viewed online at the following link:
http://www.youtube.com/watch?v=ME6FbjAVUQs
3.4
The Maps from the Environment Agency at Appendix G back up these
anecdotal claims. Map 1 shows a medium risk of surface water flooding along
Ham Lane and an overland surface water route which passes through the
centre of the site in a northerly direction during flood events. Maps 2 and 3
also below show that on the approach to the site there is a low chance of
surface waters of over 900 mm in depth and a high chance of surface waters
of between 200 – 900 mm in depth on the approach road to the site, Stitching
Shord Lane.
3.5
There are two main issues in connection with the flooding issues:
a. The safe diversion of the overland surface water flow that currently
passes through the site to a watercourse and provision of surface
water drainage
b. Obtaining safe means of access during flood events
a. Diversion of Surface water flows and provision of surface water
drainage
3.6
Whilst there is a convenient foul drain which runs along Ham Lane, there is no
such surface water drain, and Wessex Water have confirmed that adding
surface water to the foul water network would not be permitted. The
application proposed an infiltration pond, but this had no positive outfall and
the Council raised concerns that 1. it would not be effective in that the ground
was impermeable and 2. The outfall from this infiltration pond appeared to be
to a neighbouring garden.
3.7
The appellants have prepared a revised Flood Risk Assessment which
addresses the management of surface water from the site. The proposal is to
attenuate surface water on the site before discharging to a requisitioned
sewer from Wessex Water and ultimately out-falling to a drainage ditch. In
principal this approach would provide a suitable positive outfall from the site,
and on the face of it this would resolve these concerns. However the Council
would need to review and approve a detailed design strategy. This proposal
would also need to be agreed with Wessex Water and any land owners
affected.
3.8
The Council’s Drainage team question however why the surface water bodies
to the north east of the site (as identified by Wessex Water) are not the
preferred destination for positive outfall. Hydraulically these would seem to be
a simpler option.
b. Safe access during floods.
3.9
Inadequate information has been submitted to demonstrate that safe vehicular
access to the site can be maintained during flood events. Stitchings Shord
Lane and Ham Lane border the development site and, according to the latest
surface water mapping data from the Environment Agency, both roads are at
risk of surface water flooding to a significant depth (up to around 900mm on
Stitchings Shord lane) during the 1in100year rainfall event.
3.10
The Council’s drainage and flooding team has combined flooding depth data
and flow rates to produce maps of overall flood hazard, (Map 4, appendix G),
which shows a significant level of hazard on the approach to the site
immediately outside the site on Stitching Shord Lane and Moderate level of
hazard on Ham Lane. The water levels modelled would cause significant
damage to vehicles trying to get in and out of the site and represent a threat
to their occupants. These water levels would also have the potential to trap
vulnerable residents within their properties. Given the rural location of the site
and the relatively few services available within the village this would be a
significant inconvenience to residents.
3.11
The revised Flood Risk Assessement submitted with the appeal provides no
finer grained assessment of the flood levels and flow rates on the approach
roads to the site to alleviate these concerns, and proposes no solution to this
problem.
3.12
The proposed development would introduce housing to an area at known risk
of surface water flooding. This is contrary to the NPPF (paragraphs 100 and
101) which advise that development should be directed away from areas at
highest flood risk and that consideration should be given to all sources of
flooding.
3.13
Paragraph 14 of the NPPF advises (incorporating relevant footnotes) that
where the development plan is absent, silent or relevant policies are out-ofdate, Local Planning Authorities should grant permission unless:
–– any
adverse impacts of doing so would significantly and
demonstrably outweigh the benefits, when assessed against the
policies in this Framework taken as a whole; or
–– specific policies in this Framework indicate development should be
restricted, (the footnote goes on) For example, those policies relating
to …… ; and locations at risk of flooding or coastal erosion.
3.14
The evidence clearly demonstrates that the site is a location that is at risk of
flooding, and therefore the presumption in favour of sustainable development
does not apply.
4.
Reason for Refusal 2. - Highways Safety
4.1
The second reason for refusal was as follows:
The traffic generated from this proposal would use lanes which, by virtue of
their function in the highway network and their inadequate width, junctions
and lack of pedestrian facilities, are considered unsuitable to accommodate
the increase in traffic from this development and would be likely to lead to
additional hazards and conflict with all users of the highway. As such, the
proposed development would be contrary to saved policies T.1, T.3 and T.24 of
the Bath & North East Somerset Local Plan including minerals and waste
policies Adopted October 2007 and the guidance set out in the National
Planning Policy Framework.
4.2
The appeal site is located off the unclassified road known as Stitchings Shord Lane,
located at the junction of Stitchings Shord Lane and the unclassified road known as
Ham Lane. A location plan is attached as Appendix H.
4.3
Stitchings Shord Lane is a no through road and has a carriageway varying in width
from 2.85m to 3.05m along its 5.07m length. The lane does not have any footways or
pedestrian refuges (in the form of level verges), with the lane being bounded on both
sides by high hedges.
4.4
Ham Lane, in the vicinity of the appeal site has a carriageway varying in width from
4.0m to 4.75m, widening to a maximum of 4.95m towards The Street, to the south
east. There are no footways or pedestrian refuges. To the north of the junction with
Stitchings Shord Lane, Ham Lane is bounded by hedges to both sides, and to the
south east of the junction the lane is bounded by boundary walls and dwellings.
4.5
Stitchings Shord Lane and Ham Lane are both subject to a local speed limit
restriction of 30mph and Stitchings Shord Lane does not have street lighting and
does not have any road markings, except dashed junction markings.
4.6
Ham Lane also does not have any street lighting, but has stop junction markings at
its junction with The Street, located 73m from the junction of Ham Lane with
Stitchings Shord Lane. There are also double yellow lines around the junction of The
Street with Ham Lane.
4.7
The available visibility at the junction of Stitchings Shord Lane with Ham Lane is
considered to be satisfactory to the north from a point measured 2.4m back into the
junction when exiting central to the junction (as tends to be the general practice), and
is generally acceptable to the south east, although clear vision is obscured by
overhanging vegetation.
4.8
The available visibility at the junction of Ham Lane with The Street, measured from a
point 2.4m back into the junction is satisfactory to the north east but is restricted to
just 15m to the south west.
4.9
There is a stepped Public Footpath link from Stitchings Shord Lane into Lovell Drive
approximately 138m west of the junction of Ham Lane.
4.10
The village of Bishop Sutton offers some local facilities and public transport, but
access to them would rely on the use of the unlit, narrow lanes of Stitchings Shord
Lane and Ham Lane to reach the shop, school and bus stops.
4.11
The following policies/guidance documents are considered relevant to the
consideration of the above proposal.

Policies T.1, T.3 and T.24 of the Bath & North East Somerset Local Plan
(including minerals and waste policies) Adopted October 2007.

The National Planning Policy Framework.

Manual for Streets (MfS) provides guidance on appropriate widths of
carriageways. Relevant extracts are attached as Appendix I.
HIGHWAY CONSIDERATIONS
4.12
Figure 7.1 of Manual for Streets (MfS) indicates the minimum widths of carriageways
to accommodate certain vehicles, and it is shown that a width of 4.1m would be
required to enable two cars to pass on a straight section of carriageway. A width of
4.8 metres would be required for a car and a lorry to pass.
4.13
Having regard to 1.2 and 1.3 above, the means of access to the appeal site, via
Stitchings Shord Lane and in places Ham Lane, are considered to be of a single
vehicle width over a considerable part of their length, and would therefore not allow
for two cars to pass one another.
4.14
The junction of Stitchings Shord Lane with Ham Lane is of restricted width and
vehicles emerging from the junction generally do so within the centre of the junction.
4.15
The visibility at the junction of Ham Lane with The Street is restricted to the south
west and the increased use associated with the traffic generated by a further 9
dwellings would increase the risk to the safety of all highway users.
4.16
There are no footways on Stitchings Shord Lane or Ham Lane from the appeal site to
access the local shop, pub, school or public transport, resulting in pedestrians having
to share the road space with vehicles, and given the restrictive width of Stitchings
Shord Lane, in particular, and the lack of street lighting, this would not provide a safe
route for the more vulnerable road users.
4.17
The access roads of Stitchings Shord Lane and Ham Lane, which provide access to
the appeal site have insufficient width for two vehicles to pass over much of their
length, and by virtue of their function in the highway network, and their inadequate
widths, alignment and junctions, together with their lack of separate pedestrian
facilities, are considered to be unsuitable to serve as a means of access to the
proposed development.
4.18
The proposal is therefore considered to be contrary to Policies T.1, T.3 and T.24 of
the Bath & North East Somerset Local Plan (including minerals and waste policies)
Adopted October 2007, Policy 1 of the Bath and North East Somerset, Bristol, North
Somerset and South Gloucestershire Joint Replacement Structure Plan, and the
National Planning Policy Framework.
5.
Reason for Refusal 3. Suburban Design
5.1
The third reason for refusal was as follows:
The application fails to demonstrate that the site would be capable of
accommodating the number of dwellings proposed in a manner that
would be acceptable in terms of its design and layout and its impact on
the character of the area. The indicative plan submitted suggests that
the proposed development would result in an over-dense, suburban and
introverted development that would fail to reinforce local distinctiveness
and would be harmful to the character and appearance of the village. As
such the proposed development would be contrary to saved policies D.2
and D.4 of the Bath & North East Somerset Local Plan including
minerals and waste policies Adopted October 2007, policy CP6 of the
draft Bath and North East Somerset Council Core Strategy March 2013
and the guidance set out in the National Planning Policy Framework.
5.2
The appellants comment that the application is in outline with all details as reserved
matters to be determined subsequently and that the layout plan submitted is purely
illustrative. Clearly this is correct, however the application does specify the number of
dwellings proposed and therefore it is legitimate for the Council to consider the
consequences of accommodating the number of dwellings proposed. The context in
the area of the site is of detached dwellings located within large plots contained
within boundary hedges or stone walls, all of which front onto the road. The
indicative plan shows an introverted, suburban layout with houses hung off an
internal distributor road which is at variance with this context.
5.3
The appellant is correct that the plan is indicative, however given the importance of
substantially retaining the boundary hedgerows, which are of ecological importance,
there are unlikely to be countless different ways in which 9 dwellings could be laid out
within the site. Likewise the applicants propose the removal of substantial amounts of
the southern hedgerow in order to facilitate visibility splays, but nevertheless an
objection remains to the scheme on highway safety grounds. This further
circumscribes the alternative ways in which the scheme could be designed, whilst
substantially retaining the hedgerow and responding appropriately to the context.
6.
Reason for Refusal 4. Loss of Open Space
6.1
The fourth reason for refusal was as follows:
The development would result in the development and loss of a
currently open space which contributes to the rural setting and
character of the village. The development of this open space would
have a harmful effect on the character of the village, and would be
contrary to policy BH.15 of the Adopted Local Plan.
6.2
The appellant refers to the Strategic Housing Land Availability Assessment (SHLAA)
which does discuss the housing potential the site could offer. The SHLAA is purely
an assessment of the housing capacity of sites within the area and is not a housing
allocation as interpreted by the Appellent. Significantly more sites are assessed in
the SHLAA than would be put forward as housing allocations. As is self-evident from
the brevity of the assessment within the SHLAA, the SHLAA is predominantly a desk
based assessment and does not consider design issues in any depth.
6.3
The appellant has dismissed the Adopted Local Plan policies as being out of date
and of limited weight. Whilst it is undeniably true that the housing policies set out in
the Adopted Local Plan are out of date, the NPPF advises that the weight given to
other policies should be determined according to their degree of conformity with the
guidance set out in the NPPF. This reason for refusal refers to Adopted Policy BH.15,
which advises that “Development which adversely affects open spaces that make a
contribution to the character of the settlement or locality will not be permitted.”
6.4
A recent dismissed appeal in BANES (reference APP/F0114/A/12/2183230, see
Appendix J) specifically considered the weight that can be given to this policy. The
appeal decision commented, paragraph 8.
“Support for the provision of green spaces of particular importance to
local communities is included in the Framework. It identifies that local
communities should be able to identify such spaces for special
protection through local and neighbourhood plans.”
6.5
The policy is to be given significant weight as it is in substantial agreement with
paragraphs 76 – 77 of the NPPF. The site is a valuable area of open space which
through its undeveloped appearance contributes substantially to the rural character
of Bishop Sutton.
7.
Conclusion
7.1
The application proposes speculative housing development in a small village which
has already seen a significant level of growth beyond the level anticipated within the
village during the plan period as a whole. The village having limited facilities and little
to no local employment is ill-suited to this level of growth and the Council is
concerned that this unplanned growth is threatening its spatial strategy, which is
predicated on the release of green belt land for housing in more sustainable locations
around Bath and Keynsham. The Core Strategy is now at an advanced stage and the
Council expects to be able to demonstrate a 5-year housing before the appeal is
determined.
7.2
The site suffers from frequent and well documented flooding problems and has no
surface water drainage, suffering surface water flooding within the site and flooding
at dangerous levels on the access road to the site. The revised Flood Risk
Assessment proposes a possible solution to surface water drainage but has no
solution to the flooding problems experienced on the access roads. The NPPF
dictates that even where there is no 5-year housing supply, the presumption in favour
of sustainable development does not apply to locations which are subject to flooding
problems.
7.3
The access road to the site is of inadequate width, has inadequate visibility and no
pavements, and would not offer a safe environment for pedestrians or car drivers.
7.4
The scheme fails to demonstrate that a satisfactory design could be produced for the
number of dwellings proposed which would retain the ecologically valuable boundary
hedges whilst responding to local distinctiveness. The indicative layout shown
suggests a suburban, road dominated layout which would fail to reinforce the local
distinctiveness of the village.
7.5
The development would result in the loss of a prominent undeveloped open space in
the village which contributes to the rural character of Bishop Sutton.
7.6
The evidence clearly demonstrates that the site is a location that is at risk of flooding,
and therefore in accordance with the NPPF, the presumption in favour of sustainable
development does not apply. Notwithstanding this, the adverse impacts of the
development, listed above substantially and demonstrably outweigh the benefits of
additional housing provision. The Council would therefore respectfully request that
the appeal be dismissed.
7.7
Appendices
Appendix A - reference ID/44 - preliminary conclusions in relation to the SHMA
Appendix B - Changes to the B&NES Core Strategy, published 4.03.13
Appendix C - Consultation on the Core Strategy Amendments
Appendix D - Report to Council dated 4.3.14
Appendix E – Schedule of Approved housing Applications / allowed Appeals
exceeding Core Strategy scale of growth. Schedule of pending applications /
appeals
Appendix F – Objection from K Betten, local resident, enclosing photos of floods
Appendix G - Environment Agency and BANES Flood Maps – Likelihood and
severity of surface water flooding
Appendix H – Site Location Plan showing road classifications
Appendix I – Extracts from Manual for Streets
Appendix J - Appeal Reference APP/F0114/A/12/2183230 -