We object to this outline application for up to 186 homes at Court House Farm on the following material grounds, focusing on key impacts to safety, amenity, and the environment as per planning policy.

If refusal is not forthcoming, we request the following mitigations be secured through conditions, Section 106 obligations, or scheme amendments to address these harms.

Traffic Congestion and Safety

We note no formal statement from National Highways on Junction 19’s overcapacity, despite pre-application scoping; this junction is already at breaking point and added trips (even if low per the assessment) risk unacceptable safety and delay impacts under NPPF paragraphs 104-113.

The transport assessment underestimates cumulative effects from nearby growth, such as Bristol Port expansion and the Pill rail station reopening, ignoring the Joint Local Transport Plan’s forecast of a 26% rise in trips by 2036.

Proposed measures like car-sharing schemes and travel vouchers aim for a 10% drop in single-occupancy car use over five years, but these are aspirational and lack substance – they do not amount to a robust policy to mitigate real harms.

Local roads like Marsh Lane, St George’s Hill, and Church Road are already narrow, steep, and prone to severe congestion, especially at peak times with tailbacks from M5 Junction 19. This development could add 900-1,000 daily vehicle trips, worsen gridlock and create dangerous rat-runs.

Local schools add to these concerns: Crockerne Primary is at capacity with a waiting list, forcing some children to Portbury School, which lacks a safe footpath connection—increasing car dependency and traffic on already strained roads.

As mitigation, we request a condition for an independent full traffic impact assessment of Junction 19, including peak-hour modelling and cumulative scenarios – if overload is confirmed, we request Section 106 contributions for upgrades.

Additionally, we request Section 106 funding for enforceable controls on Marsh Lane/St George’s Hill such as traffic calming (chicanes, extended 20 mph zones).

We also request strengthened sustainable transport via Section 106 obligations for subsidised bus passes for five years, electric vehicle charging at all homes, and contributions to MetroWest rail/bus links, with penalties if mode shift targets are unmet.

Cycling Safety

The proposals fail to provide safe, direct infrastructure for cyclists, risking significant harm under NPPF paragraphs 104–113 and Core Strategy CS10, both of which require prioritising sustainable transport and suitable access for all users.

The developer’s own Transport Assessment confirms baseline traffic on St Georges Hill is ~4,000 two-way vehicles per day at 30 mph, well above Local Transport Note 1/20 thresholds for safe mixed cycling without segregation (max. 2,000–3,000 vehicles/day at 20 mph).

This road forms part of the Avon Cycleway, forcing cyclists into dangerous conditions with high-speed traffic. Marsh Lane (under 1,000 two-way vehicles/day at 20–40 mph) and Church Road (lightly trafficked but narrow) also lack protected lanes, relying on inadequate “virtual footways” that do not meet LTN 1/20 core principles for separation and directness.

The suggested rerouting via the site’s internal spine road (shared foot/cycleway) is illustrative only at outline stage and unenforceable, risking future omission or mixing cyclists with pedestrians and vehicles, leaving gaps in the wider network.

As mitigation we request guaranteeing the internal shared cycleway via reserved matters condition to reroute the Avon Cycleway through the site, avoiding St Georges Hill. Conditions for the delivery of segregated cycleways along the site perimeter and key routes (2–3 metres wide, LTN 1/20 compliant), including upgrades to the western boundary path. We also request the securing of Section 106 funding for cycle connections to Pill station, schools, and the Avon Cycleway, including lighting, signage, and independent safety audits.

Accessibility and Pedestrian Safety

The site’s perimeter lacks safe, continuous footpaths, endangering pedestrians on routes to schools, shops, and the future Pill station. Narrow or absent pavements on Marsh Lane, Church Road, Debecca’s Lane, and Court Hay force walkers into the carriageway, heightening collision risks.

The developer’s own Transport Assessment admits ‘pavements are missing or stop suddenly on key walking routes to Pill and Easton-in-Gordano and some lanes have no lighting or are too narrow for people to walk safely’.

Proposals for “virtual footways” (painted lines and contrast surfacing) and minor widenings (1.2–2m) are inadequate – they are not segregated and will not protect vulnerable users, contradicting Manual for Streets and LTN 1/20 standards for safe active travel.

This fails Core Strategy CS10 and NPPF requirements for suitable access for all, particularly disabled users. Virtual footways risk breaching Building Regulations M4(2) and the Equality Act due to uneven surfaces, lack of level resting points, and absence of tactile guidance.

The developer’s Framework Travel Plan uses a 4.5 km/h walking isochrone, assuming good-quality routes. This overestimates accessibility given the poor pavements, narrow lanes, lack of lighting, and missing crossings.

North Somerset’s Active Travel Strategy 2020–2030 aims to make walking and cycling the natural choice for journeys under one mile, and the Local Plan Policy SP10 requires developments to limit the need for car travel. Without delivering safe, continuous walking and cycling routes before occupation, this scheme will increase – not reduce – short car trips, undermining local climate and transport goals.

As mitigation, we request that direct, continuous, and safe walking, wheeling and cycling links (LTN 1/20 compliant) to Pill station, schools, shops, and doctors are prioritised and the requirement for all active travel infrastructure to be in place before occupation.

The upgrading and resurfacing of public rights of way to provide year-round accessibility. We also request the securing of Section 106 funding for dropped kerbs, tactile paving, raised crossings, and lighting at all minor junctions and independent accessibility and safety audits completed before occupation.

Noise Levels and Amenity Impacts

Road traffic noise from the M5 is the dominant noise source across the site (Page 8), with baseline daytime LAeq,16hr levels ranging from 54 dB at LT3A to 66 dB at LT1A, and night-time LAeq,8hr from 49 dB at LT3A to 59 dB at LT1A (Pages 11-12). This risks significant adverse effects on amenity under NPPF paragraphs 174-188 and BS 8233, as external areas may exceed the 55 dB LAeq,16hr upper guideline (Page 12), limiting outdoor use in gardens and play spaces. Barriers and glazing reduce internal levels to acceptable (<35 dB day/<30 dB night, Page 19), but in noisier zones, windows must remain closed to meet these targets (implying reliance on alternative ventilation per Appendix A7, Pages 54-60), which could exacerbate overheating and isolate residents—disproportionately affecting affordable housing if placed near the M5, condemning lower-income families to poor living conditions amid pollution and vibration.

As mitigation, we request taller acoustic barriers (4-5 metres) along north and west edges via condition, plus dynamic thermal modelling to ensure windows can open without overheating – secure Section 106 for post-build monitoring and retrofits if levels exceed 55 dB in gardens.

We also request tying to the Health Impact Assessment with Section 106 contributions for local GP/pharmacy expansions to offset pollution-related health strain, plus green buffers/trees for air quality.

Social Housing

The proposals include 45% affordable housing with 77% as social rent (approximately 65 units), which we welcome given local needs in Pill and Easton-in-Gordano, where deprivation indicators like child poverty and housing affordability are high (Health Impact Assessment baseline).

However, this risks dilution through viability assessments (NPPF para 58), potentially reducing social rent to the developer’s preferred 50:50 split, undermining Core Strategy CS16 and NPPF golden rules for grey belt (paras 156-157). Placement of social units near the M5 edge could expose lower-income families to excessive noise (up to 59 dB night-time LAeq,8hr at LT1A, Page 11) and pollution, exacerbating health inequalities and contradicting inclusive design principles.

As mitigation, we request Section 106 obligations mandating the full 77% social rent without post-approval reductions, with a viability review mechanism directing surplus profits to additional units.

Prioritise social housing in quieter southern/central zones via layout conditions and include local lettings agreements favouring PEIG residents.

We also request section 106 funding for enhanced features like air purifiers in social units to offset noise/pollution impacts.

Green Belt

The development of this site would erode the last remaining buffer of open land between Easton-in-Gordano and Bristol Port, effectively merging the village with industrial sprawl and undermining the openness of the countryside, as protected under NPPF paragraph 143 – regardless of the assessment’s claim of a weak contribution to Green Belt purposes.

This poses a clear risk of coalescence with Portishead and Bristol, in direct conflict with Core Strategy CS19, and would set a dangerous precedent for further Green Belt releases without demonstrating very special circumstances.

Ultimately, these harms outweigh any benefits, such as the proposed 45% affordable housing. Maintaining a green corridor from the Severn Estuary SSSI is essential to preserve biodiversity and prevent fragmentation.

As mitigation, we request Section 106 for enhanced biodiversity net gain (20%+ via off-site contributions) and public access to new green corridors preventing visual/physical merging with the port.

We also request scheme amendments to cap at 150 homes, phased post-infrastructure e.g., rail opening, with Section 106 funding for port-village buffer planting/woodland.

We urge refusal or major amendments, including independent Junction 19 studies, segregated footpaths, and noise-tested layouts prioritising quieter areas for social housing.