11th April 2018

Proposed new medical centre for Mendip Vale Medical Practice

Apologies – this page is a little messy and long. Very much a work in progress – Steve


This is a full planning application for the development of a modern health facility to replace the outdated surgery buildings in Yatton and Congresbury on land between the two villages.

The application seeks permission for: Construction of health centre, ancillary pharmacy, associated access, vehicle parking, bin and cycle storage, ambulance and mobile MRI unit bays, landscaping and drainage works.

Timeline

2018
9 May The application has been ‘called in’ to Committee by Cllr Tom Leimdorfer. This is the first possible date P & R Committee might consider the application. The agenda will be published on 2 May
20 April Try to make your comments by this date
16 April Application will be considered by Yatton Parish Council
12 March Application considered by Congresbury Parish Council. Resolved that the application be recommended as a refusal. The Parish Council is sympathetic to the requirements and need to provide a new facility for Yatton and Congresbury to ensure clinical and administrative needs are met for both the present and the future. However, the Parish Council recommends that the current application is refused and that a response is prepared by the Clerk to be agreed before submitting to include concerns over the lack of consultation, the loss of the strategic gap, safe and sustainable routes for pedestrians and cyclists, lack of access by public transport, concerns over the size of the building and position on the site.
5 March Case file appeared online
31 January Application eventually registered by NSC
2017
21 December Application submitted to NSC on 21 December… pending the submission of further detail

Consultation
Many residents of Yatton and Congresbury (including parish councillors) have complained that the public consultation in 2016 was seriously flawed. I note that the Preliminary Ecological Appraisal was commissioned by Mendip Vale Medical Practice in September 2016 to assess the potential ecological constraints & opportunities associated with the favoured site.

Yatton Parish Council comments following the pre-application process…


The Business Case
The application Planning Statement reveals that…

The sites at Yatton and Congresbury have no room left, we have taken out as much back office and administration space as we can for clinical rooms. Under current guidelines we are over 30% below the recommended space needed to serve our patients. We saw a 3% increase (751) in patients registering with us across our sites in 2017, and without a new build we will struggle to provide sufficient services in Yatton and Congresbury.

By having this new build we would have space to provide a wider range of services closer to home that reduces reliance on acute hospitals e.g. dermatology and ophthalmology. This should assist in providing services more promptly and cost effectively, enabling savings to be reinvested in other pressurised areas such as paediatric mental health.


Site location


Overall site layout


Strategic Gap
The proposed location is within the Yatton and Congresbury Strategic Green Gap.


View from Congresbury Yeo – Photo: Steve Bridger 

The following paragraph is taken from NSC’s Site Allocations Plan Background document on Strategic Gaps (March 2016)…

What development would be controlled by the strategic gap policies?
5.1 Strategic gaps are not intended to stop all development and will inevitably include some development already. There may be opportunities, through appropriate location, siting and design, to accommodate some new development in a strategic gap without significantly adversely affecting the open or undeveloped character of the gap, or harming the separate identity and character of the settlements, or their landscape setting. For example, it might be possible to achieve this by… using a very high standard of design, sensitivity and landscaping as appropriate. However this will need to be satisfactorily demonstrated.


Illustration from Design and Access Statement

Looking north north west from the B3133 across part of the strategic gap towards Yatton, north of development on the west side of the road – North Somerset Council

Car park
The application states that the car park will be tarmacked with block paving in the car bays.

Drainage
The North Somerset Levels Internal Drainage Board has examined the documents submitted and object to the application as it stands.


YACWAG objection in full…

Dear David

YACWAG, with over 200 local members, would like to object to the above application because it is contrary to Local Plan policies including the North Somerset and Mendip Bats SAC SPD in that the proposed mitigation for bats is both inadequate, unsuitable and unsustainable.

YACWAG responded to the applicant’s ecological consultant (Landmark Practice) on 18th May 2017. No further communication has occurred. As we stated in our comments to Landmark the proposed development is in a sensitive area. It is in a strategic gap and is part of Yatton Moor SNA. It therefore constitutes part of an important ecological network and the NPPF states that local authorities should take a strategic approach to its biodiversity. In this context the North Somerset and Mendip Bats SAC Guidance on Development SPD is highly relevant. YACWAG agrees with the ecologist’s statement that this development has the potential to disrupt the flyways of horseshoe bats between Kings Wood and Yatton Moor.

YACWAG notes that the survey work carried out by the ecological consultants shows that this field, along with the wider area around it, is very important for commuting and foraging bats of at least eight species. This should not be underestimated. It is not expected that a survey would show greater numbers of rare bats than common bats! The important evidence is that both Greater and Lesser Horseshoe bats were found on surveys not always conducted in optimal conditions, also bearing in mind the difficulty in recording these species. What is also significant is the high incidence of Serotine. Our National Bat Monitoring Survey for this species scores consistently very high regionally and nationally.

While the applicant’s ecologist has taken the SPD into consideration, we do not agree with their analysis and their subsequent conclusions regarding mitigation. The development is within Bat Consultation Zone A and the consultant has stated it is within Zone B. It should be noted that the site is within 2.2 km of a Greater Horseshoe Bat maternity roost in Kings Wood. This is fundamental because it affects the Habitat Suitability Index (HSI) score and in consequence the habitat units for mitigation. YACWAG considers that the HSI score should be higher than 3, at least in the order of 9. It is accepted that any assessment can be rather subjective and therefore it requires further independent examination.

It would be important that there is no lighting on the northern boundary and the application mentions a 5 metre unlit boundary, but there needs to be no light spilling from the building. The ecological consultant’s bat surveys also demonstrate the importance of the lane to the south of the proposed development site and lighting on this side would also need to be minimal and at ground level. A large car park in this location is likely to present a problem in terms of lighting that will suit both bats and people.

The Guidance clearly states that ecological mitigation should be in perpetuity and this, YACWAG believes, is essential. The applicant has publicly stated that the site allows for expansion. If the building is extended in the future this would compromise the mitigation.There should be a robust management plan with agreed monitoring to ensure any mitigation measures are working.

With regard to the proposed mitigation, it appears to be an afterthought, fitted in around the building and car parking. The latter constitutes approximately two-thirds of the development. What is required is an integrated approach, with the building line running parallel with the boundary in order to give it greater potential for reducing harm to bats. We agree with the importance of a corridor on the northern and western boundaries of the site. However, the northern boundary proposals are not of a consistent width and indeed we would question whether 5 metres is sufficient. Bearing in mind the sensitivity of this site, and that the NPPF principle states that there should be enhancement for biodiversity, the proposals for mitigation are inadequate.

We note that a North Somerset Council pre-application consultation suggested enhancements including a green/brown roof. That could help increase the area of compensatory grassland with flowers. Areas designated on the plan as amenity grass areas should be managed for areas of long grass, wild flowers, etc. Car parking surface materials should be ecologically and environmentally sustainable and could be designed to attenuate for run-off. As stated earlier, the site needs to be designed in an integrated and sustainable way, with the maximum benefit for biodiversity. This application lacks imagination and is unsympathetic to its location.

YACWAG is committed to promoting the public benefits of the natural environment; we recognise the contribution it makes to the health and well-being of the local community. We find it disappointing that the incongruous design and greenfield location of this proposed development does not reflect a similar concern from a public health organisation.

Regards,
Tony Moulin, Chairperson,
Yatton and Congresbury Wildlife Action Group
Registered charity no. 1076362


Questions

Q. Is there an alternative location for a purpose-built surgery which will give the space needed to provide GP services for now and the future?

Q. Has the former Roundtrees site been discounted?

Q. Without S106 contributions, who would pay for a pedestrian crossing across the B3133?