Millfield Road, Market Deeping

Lincolnshire County Council have applied to the District Council for outline planning permission to build up to 260 houses on Market Deeping’s Mill Field. It is neither the right time or the right place for such an application.

It isn’t the right time because it is disrespectful of the County Council to preempt the decision on whether the site is registered as a village green ahead of the January’s inquiry. It isn’t the right time because the District Council are writing a new local plan that will allocate new sites for housing in The Deepings and this will complicate the process of it being finalised.

It isn’t the right place because it is the last green area inside the bypass and is widely used by residents. It isn’t the right place because it is a significant walk from a bus route and served by a single-track road.

Whilst I support house building in Deeping, I won’t support building just anywhere without consideration of the impact on existing residents and those potential new residents. Here’s just a few reasons why I will be objecting to this application:

1. The application is contrary to the Core Strategy SP1: Spatial Strategy

   The proposal is for a site that is not allocated and is a less sustainable site due to poor highways access and distance to local facilities and bus stops. The applicant provides no explanation as to why this site is required to meet the development needs of the Deepings when there are clearly other, less constrained sites that are available which would not compromise the nature and character of the area in the way that development of Millfield would do.

   Those better sites are those allocations in the draft local plan. They all benefit from better vehicle access, better access to public transport, easier access by bike/foot to local facilities, and are mostly further away from noise and air quality issues presented by the bypass. It is clear from the consultation undertaken by SKDC as part of their local plan preparation that the proposed allocations are much less locally controversial.

   It should also be noted that SKDC’s latest draft local plan neither allocates this site nor allocates other additional sites in The Deepings which would suggest it is not required to meet the development needs of the town.

2. The application is contrary to Core Strategy EN1: Protection and Enhancement of the Character of the District

   The proposal would be detrimental to the character of the Millfield Road area by requiring the widening of the road and removal of trees. It would have a negative impact on the public access to the landscape and the contribution that the site makes to the setting of the road. Through increased traffic, it would damage the tranquil nature of the road which, in combination with the site, provides an area with a unique character and is attractive for a range of outdoor activities which contribute to the well-being of local residents.

3. Inadequacy of the pre-application consultation

   The applicant’s consultation event only invited comments on development of site, not specific proposals. Other than by an invitation to the consultation event, the applicant failed to engage with the Town Council or neighbourhood plan group.

   It is particularly unfortunate that greater details weren’t provided at the consultation event given it is clear that based upon the dates of the various submitted documents, they would have been available.

   The lack of details at the consultation event makes it difficult to assess to what degree comments received have actually influenced the design as it isn’t clear what the design would otherwise have been.

   The responses to the public consultation provide little evidence of local support for the development of this particular site, only support for the general concept of increasing housing supply which can be achieved by development of other sites.

4. Prematurity

   Whilst the village green application for the site may itself not be a material consideration, the impact that any decision about this application would have on the ability of the local plan to meet required housing need (or not) is relevant and so this application is premature because it may risk sufficient land not being allocated in the local plan if this application is approved and considered as part of assessing the requirement for site allocations but the village green application is successful and makes development impossible.

   The proposed development may also have effects that impact upon allocations in the emerging plan. This includes the potential increase of traffic at the Peterborough Road/Towngate East junction and the A15/A1175/Peterborough Road roundabout junction that are likely to be relevant to several of the allocations and other future development.

   Therefore it would be inappropriate to approve this application whilst there remains uncertainty as to the site’s viability.

5. Access to Sustainable Transport

   Due to the distance from local facilities and bus routes, the proposal is contrary to NPPF paragraph 91 and section 9 (Promoting sustainable transport).The application’s Transport Assessment notes that the site is approximately 1000 metres from the nearest bus stop. This is significantly further than the maximum 400 metre distance in the Chartered Institution of Highways & Transportation’s Planning for Public Transport in Developments guidelines of 1999 as highlighted by the applicant.

   Despite this, the applicant then still considers the site “to be within sufficient distance to provide an alternative travel modal option”. It is unclear both why the applicant thinks bus travel should only be an “alternative” option, not a viable principal mode, and also why it should be considered that their suggestion of acceptable walking distances to bus stops is better than the CIHT’s widely accepted guidance.

   It should also be noted that more recent recommendations from the CIHT (Buses in Urban Developments, January 2018), suggests a much more  rigorous approach, considering more factors than simply distance. Applying these newer recommendations would result in a maximum walking distance of 300 metres, even less than the previous 400 metres which this site significantly fails to achieve.

6. Highway Safety

   The application should be refused as it is contrary to paragraphs 108 and 109 of the NPPF due to the absence of a robust transport assessment and the inadequate measures to promote sustainable transport. The use of a single-track road for access would present an unacceptable impact on highway safety.

   Millfield Road north of site

   The application claims to have considered the highways impact but does not address the obvious risk of greater traffic on the northern, single-track section of Millfield Road. This would obviously likely to be an attractive route for both vehicles, cyclists, and pedestrians accessing destinations to the north and east.

   The Transport Assessment (section 6.2, page 30) assumes that all development traffic will use the Millfield Road/Stamford Road junction.  No detailed explanation of the basis of this assumption is provided. This is a very significant assumption that means the impact on Millfield Road north of the proposed access hasn’t been considered.

   Given this is a single-track road with no lighting, a blind corner and no footway, this is an important issue. With the assumption that no traffic is using this route, there is also therefore no assessment of the impact of the development on other junctions, such as Towngate West/Peterborough Road, which will be subject to significant changes through other developments (e.g. Larkfleet Towngate East, Larkfleet Peterborough Road, new local plan allocation for west of Peterborough Road).

   It is clear that in the absence of appropriate consideration and mitigation, the northern section of Millfield Road and associated junctions beyond could see an unacceptable impact on highway safety and thus the development should be refused in accordance with paragraph 109 of the NPPF.

   Visibility splays

   Visibility splays are proposed to be designed based upon the 85th percentile speed as surveyed in March 2017 but the development proposes not just to create an access onto Millfield Road but also to widen the road in the vicinity of the access.

   This is highly likely to result in greater speeds in the proximity of this access and therefore it isn’t appropriate to design the visibility splays based upon the 85th percentile speeds before the road is widened. The visibility splays should therefore be designed based upon a speed higher than the surveyed 85th percentile speed.

   This would present an additional unacceptable impact on highway safety and therefore provides grounds for refusal in accordance with paragraph 109 of the NPPF.

7. Lack of a Minerals Assessment

   The application is not supported by a minerals assessment that is required to satisfy policy M11 of the Lincolnshire Minerals and Waste Local Plan because the site is included within a Sand and Gravel Minerals Safeguarding Area. In the absence of such an assessment, the application should be refused due to the risk that the development would constrain potential future use for mineral working, in accordance with paragraph 206 of the National Planning Policy Framework (NPPF).

With the public inquiry to consider the application to register the site as a village green just a week away, it is unfortunate that we are forced to be considering how to respond to this planning application that may be irrelevant if the site becomes a village green.

I hope that the village green application is successful but regardless of its outcome, the County Council’s proposals to develop the site must still be resisted.

Here’s the planning application: S18/2146