July 2020 Furzehill Planning Application - response to comments

It is important to us that our sites become embedded not just in the local landscape but also the local community. As such we endeavour to ensure that we engage meaningfully with the local community and that where possible our proposal responds to this engagement. To this end, we held a community meeting prior to submitting our pre-application, a summary of the issues raised and our response was also uploaded on our website.

However, it is clear from some of the public comments so far that there may still be some confusion over the nature of our proposal and our aims as an organisation as well as some concerns that need to be addressed. We are committed to playing a positive role in the local community, and we welcome constructive engagement from those who would like us to do even better.

Below we have identified key areas which have come up in the comments so far and provided additional information, which we hope will satisfactorily address the issues that have been raised.

The Ecological Land Cooperative (ELC)
Ecological Land Ltd known as the Ecological Land Cooperative is a not for profit organisation. We are run cooperatively for the public good registered under the Co-operative & Community Benefit Societies Act 2014 as a Community Benefit Society with Somerset Rules 2014, ref 30770R. We are registered with the Financial Conduct Authority. You can read the rules of the ELC here.

Our core objectives include :  
●    securing land for low impact, residential, agro-ecological smallholdings    
●    creating rural jobs and employment
●    creating research and data freely available online and accessible to all
●    creating opportunities for people and communities to have access to land and become involved in growing.

We have over 440 members who are committed to the work of the cooperative, who are part of the decision making process within the ELC. Local neighbours to our land may join the ELC and become members too.

We have an asset lock in our rules to prevent land being sold for private gain in the event of the closing down of the cooperative.  If you are interested in the structure and running of our organisation can find out more on our website, our rules are available on request.

We have a sister organisation, The Ecological Land Trust (ELT), registered charitable incorporated organisation, number 1158032, which is expressly focused on wildlife and habitat conservation, ecology and biodiversity at our Ecological Land Cooperative (ELC) sites across England and Wales. You can read more about the ELT here.  The objectives of the charitable trust are to support sustainable development in England and Wales, specifically the preservation, conservation and protection of the environment. You can view the Ecological Land Trust's annual returns to the Charity Commission here. 

Cae Tan
Cae Tan lease 5 acres of the land owned by ELC at Furzehill and by virtue of this are steward members of our organisation. For clarity please note that none of the land leased to Cae Tan is within the planning proposal area.

One Planet Development (OPD)
There may be some confusion over the nature of our proposal for a One Planet Development or OPD. For those who are unaware of OPD, this is a Welsh planning policy which aims to support sustainable living. It presents an exception to the strict control over development in the countryside if demanding criteria are met to ensure that “the development provides for the minimum needs of the inhabitants in terms of income, food, energy and waste assimilation”. The policy requirements for OPD are very different from those of a rural enterprise dwelling, which is the policy ELC has followed in England.

OPD policy presents tough criteria which need to be met in order for permission to be granted and which will continue to be monitored annually, by the ELC, for the lifetime of the development. If, other than in exceptional circumstances, the requirements are not met after the five year period then the tenants will be asked to leave, as is required by OPD policy.

OPD is not a loophole for an easy means to a rural lifestyle. Meeting the criteria requires a significant shift away from dependence on global trade and consumerism and towards dependence on meeting one’s own needs from the land. It does not provide a realistic, achievable or attractive option for everybody, but it is an available policy route for anybody in Wales who wishes to make that choice.

You can read more about the OPD planning policy and the Welsh Assembly's practice guidance document here

Agricultural Appraisal

We note the objection from Reading Agricultural Consultants, commissioned by the Gower Society. We would like to emphasise that we are currently in dialogue with Swansea LPA and the independent agricultural consultant whom they have employed to assess the application and we will be submitting additional information in support of our application within the next few weeks. Much of this will be a re-presentation of the information which has already been submitted, but some, such as the elevations and details of the dwellings, is new. This will, we hope, address many of the concerns raised in this objection.  If, after this point, there are any issues which remain outstanding, we will respond to them then.

Small Scale Farming Enterprises
We understand that there is some scepticism as to the viability of small farms, as this goes against the direction of travel in UK farming over the last 50 years. This push for farms to get bigger and bigger has led to the loss of many tens of thousands of family farms over that time, and we think that is a tragedy of lost skills and local knowledge. Because of this we believe there is a place for small family farms in the modern world, and moreover we know they can be financially profitable. In our experience, small farms are a viable and effective way of producing local food and can provide adequate reliable income for the farmers. After initial support we would expect these businesses to run by themselves without external aid. This has proven to be the case with our existing sites. We have produced a booklet; Small Farm Profits, which addresses this issue and demonstrates the viability of small scale agricultural enterprises.  You can find this on our website at: https://ecologicalland.coop/small-farm-profits

We also believe that the production of local food is of key importance to tackling the climate crisis and issues of rural economic regeneration; the provision of small scale agro-ecological farms is an effective and viable way to achieve this. On this matter there is substantial research into creating a more sustainable agricultural future, these include for example the IPES-Food report; From Uniformity to Diversity,; or the huge IAASTD report from the United Nations and World Bank:  ‘Agriculture at the Crossroads’. If you are interested in this issue please contact us for more details.

We assess all potential business plans to ensure that they are robust and viable and that the proposed enterprises have the best chance of success. This involves a rigorous selection process to make sure that the applicants have the necessary experience to bring the plan to reality and that the details of the business plan are suitable to the site and the existing local markets.

It should also be noted that the LPA will use the services of an agricultural consultant to ensure that the submitted business plans are sound and that policy requirements will be met.
 
All of our sites are monitored annually to maximise their chance of success and to ensure they are meeting the management plan requirements. The ELC has ecological and agricultural targets for all of our sites which are monitored annually. In addition, OPD planning policy has its own set of required monitoring targets which will need to be met on our Furzehill site. A copy of a monitoring report for another of our sites was submitted with the application for reference (see attachment ref: FZH17) though it should be noted that this is for a rural enterprise dwelling in England and not an OPD site so it reflects only the ELC’s monitoring requirements.

We appreciate that there is always a risk that any proposed new businesses will not be successful. The guidance and support given by the ELC to the tenants ensures that this risk is minimised and that any potential areas of weakness are identified and addressed. Furthermore, if businesses do fail, we would then identify new tenants as quickly as possible, taking on any land management responsibilities ourselves in the interim, if necessary. As an established community benefit society with a substantial membership we are in a good position to be able to recruit new tenants.

 If, in the unlikely event that the ELC ceases to exist, then any assets would be transferred to other named organisations with similar asset locks and objectives. ELC has a very strong legal model and aims to never sell the freehold to the land.

Dwellings
The provision of a modest scale and affordable dwelling is of paramount importance to a successful small scale farm. Our model for increasing opportunities for new entrants to ecological farming usually involves purchasing undeveloped agricultural land, providing infrastructure and obtaining planning permission and then passing those on to a leaseholder at cost price, without the usual uplift. It is not usually a viable option to buy local housing and still keep our holdings affordable. As many people will appreciate there is a significant gap between the price of rural housing with land and most farming incomes, especially for new entrants. This is one of the main reasons why there are so few people able to get started in farming compared to the numbers who want to.  Bridging this gap is what we mean when we say ‘affordable’.

As an environmentally conscious and community minded enterprise, the availability of affordable housing or housing with agricultural ties in the area is an important issue for us. If there were suitable, affordable and available dwellings within walking distance of the site then we would factor this into our proposal.  This issue was raised at the community meeting and we asked for further information as well as making our own investigations, but we were unable to identify any such dwellings. Contact was made with the owner of one local empty agriculturally tied dwelling; however, it was not available for purchase, only for rent, which meant it was not a secure tenure and so would not be suitable for our purposes.  On this matter, it is important to highlight that the usual planning policy requirement for consideration of existing dwellings in the area, with or without an agricultural tie, is not the same for OPD as it is for rural enterprise dwellings.

With regards to the need for a dwelling for the running of the proposed ecological small farms there are 2 key points; First, as noted above, the provision of local and affordable housing is key to the success of small farms and second, the requirements for OPD are very different than for a rural enterprise dwelling and it is not a necessary policy requirement to demonstrate essential or functional need in the same way. Both OPD policy and the ELC have their own requirements regarding the level of agricultural activity that will be required at the site.

The importance of strong agricultural ties on rural enterprise dwellings is of utmost importance to us. In our campaign for planning policy change this is a key issue we raise. We aim to ensure, through our tenancy and legal agreements, that our holdings will remain for agricultural purposes in perpetuity. However, please note that OPD policy is different from rural enterprise dwellings policy and it is OPD policy that dwellings are removed if the stringent requirements of the policy are no longer met.  

Permanent dwellings on ELC sites are restricted to a modest size - a maximum of 140m2, this helps to facilitate continued affordability and minimises any landscape or biodiversity impact.  Further, this loss of land to buildings will be compensated for by the varied environmental benefits of the ecological enterprises.  At our site in Devon, of a similar size to Furzehill, our three farm holdings have created a huge improvement in biological diversity, making it a site of some local importance, in only five years, according to an independent ecologist.

Land Management
Regarding ELC’s land management. It will not be necessary for any herbicides, insecticides or artificial fertilisers to be used, indeed, to the contrary, their use is prohibited on all ELC sites and all OPD sites - except in exceptional circumstances. Smaller farms by necessity have a high labour input, and agro-ecological farmers will look for targeted natural solutions rather than broadscale chemical treatments to address problems.

All existing hedgerow and trees will be well managed, and we are already working with a local hedge-laying contractor on Gower. A small section of hedgerow may be lost around the existing access to ensure that adequate visibility splays on the road are maintained but we will ensure that this is kept to a minimum. Any hedgerow removal will take place outside of nesting season and will be compensated for by additional hedgerow planting, some of which has in fact already taken place.

Coppice has been proposed on the site for self-sufficiency in wood as this is an OPD policy requirement.

Visual Impact
It is important to us that our sites are truly low impact and have a light touch on the land. As such we would hope that all our developments conserve and/or enhance the local landscape. As our Furzehill site is located in the AONB this is clearly of even more paramount importance.  As such, prior to putting together the application proposal we sought the guidance of a landscape architect to ensure that we were aware of the main view lines into the site and of how best to ensure that any visual impact is kept to a minimum. Both short range and long distance views into the site are relatively limited and all structures have been restricted to a modest size and low height. Additional landscaping is also proposed and design, location and materials of all structures will be sensitively and appropriately chosen.  

Transport / Traffic
The public transport opportunities from the site are relatively good for a rural site. The bus stop in Parkmill, which is accessible on foot or by bike and provides a good regular service.   

In our view, the existing access to and from the site is good and we will ensure that appropriate splays are created and maintained. Additional information is being prepared for submission to the LPA on this matter and this includes details of visibility splays and provision for parking, which is proposed on the hardstanding area by the barn. We will be advising any OPD steward of ours not to generate coach trips.

Conclusion
If you are interested in learning more about the ELC and our sites please take the time to look at the other information available our website. If you have any further questions regarding our application please get in touch and we will answer as best we can.